L'Oreal SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive L'Oréal SA has demonstrated a comprehensive level of transparency in disclosing its climate lobbying activities. The company has clearly identified specific climate-related policies it has engaged with, such as the "revision of the Packaging & Packaging Waste Directive," the "Chemical Strategy for Sustainability," and the "UN Inter-governmental Negotiation Committee for a global plastics treaty (INC -2)." It also disclosed its involvement in Extended Producer Responsibility (EPR) legislation across multiple jurisdictions, including the United States, Indonesia, the Philippines, and France, as well as its engagement with the European Green Deal and France's AGEC law. L'Oréal has provided detailed information about its lobbying mechanisms and targets, including direct lobbying activities such as "meetings with the European Commission (JRC experts, DG JUST and DG ENV)," "discussions with European policymakers," and "meetings with cabinet members within ministries" in France. It also disclosed its participation in public consultations and events like COP15 and COP26, as well as its involvement in the UN plastics treaty negotiations alongside the Business Coalition for a Global Plastics Treaty. Furthermore, the company has been transparent about the specific outcomes it seeks, such as harmonizing national approaches across Europe to avoid market fragmentation, creating conditions for a viable plastics recycling system in France, and supporting policies that ensure "a broad inclusion of actors, a high performance of waste recycling, clear roles & responsibilities and measures that incentivize better performance." These disclosures illustrate L'Oréal's commitment to transparency and alignment with its sustainability goals. 4
Lobbying Governance
Overall Assessment Comment Score
Strong L'Oréal has demonstrated a strong governance process to ensure alignment of its climate lobbying activities with its sustainability strategy. The company has implemented a "Responsible Lobbying Policy," which mandates that employees authorized to lobby must report any real or potential conflicts of interest to their management or designated Ethics Correspondents. Oversight mechanisms are clearly established, with "all members of L'Oréal's Ex-Com and all its country GMs" holding both sustainability and public affairs responsibilities, and being evaluated annually on their advancement of the company's sustainability strategy, including public affairs responsibilities. The Chief Corporate Responsibility Officer plays a central role in governance, regularly meeting with the Global Public Affairs team to "review all PA activities as relates to sustainability, including review of environmental legislative initiatives." Additionally, L'Oréal monitors its indirect lobbying efforts through trade associations, stating that "L'Oréal is not a member of any trade association opposed to climate legislation," and has taken steps to distance itself from misaligned stances when necessary. These measures indicate a robust governance process, with clear monitoring mechanisms, accountability structures, and responsible parties identified to oversee climate lobbying alignment. 3