L'Oreal SA – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Comprehensive	L'Oral demonstrates a comprehensive governance process for climate lobbying, integrating transparency, accountability, and alignment with its sustainability strategy. The company has established a "Responsible Lobbying Policy" that mandates employees authorized to lobby to report any conflicts of interest that could contradict corporate responsibility principles, ensuring alignment with its sustainability goals. Furthermore, "employees may report conduct contrary to the sustainability policy to a member of the Group Executive Committee, Zone or Country Management Committee, or Ethics Correspondent," showcasing clear accountability measures. L'Oral ensures that "all members of its Executive Committee and country General Managers have both sustainability and public affairs responsibilities," with their performance evaluated annually on advancing the company's sustainability strategy, including public affairs responsibilities. The Chief Corporate Responsibility Officer regularly reviews public affairs activities related to sustainability and collaborates with the Global Public Affairs team, ensuring consistent oversight. Additionally, "Public Affairs Officers in markets are expected to collaborate with local Sustainability counterparts to advance the sustainability strategy." L'Oral also actively distances itself from trade associations opposing climate legislation, stating that "in the event a trade association takes a position not aligned with our sustainability strategy, we have been known to distance ourselves or inform them of our disagreement." The company has disclosed its lobbying activities under the HATVP in France, further emphasizing transparency. Moreover, L'Oral integrates sustainability into its governance at the highest level, with the Strategy and Sustainability Committee of the Board overseeing climate-related commitments and the Chief Sustainability Officer ensuring strategic consistency across the value chain. The company has also published detailed disclosures in its URD, including remuneration structures linked to sustainability and climate risk management. This indicates a robust governance framework that encompasses direct and indirect lobbying activities, with clear monitoring mechanisms, accountability structures, and alignment with climate goals. View Sources	A

Overall Assessment

Analysis

Score

Comprehensive

L'Oral demonstrates a comprehensive governance process for climate lobbying, integrating transparency, accountability, and alignment with its sustainability strategy. The company has established a "Responsible Lobbying Policy" that mandates employees authorized to lobby to report any conflicts of interest that could contradict corporate responsibility principles, ensuring alignment with its sustainability goals. Furthermore, "employees may report conduct contrary to the sustainability policy to a member of the Group Executive Committee, Zone or Country Management Committee, or Ethics Correspondent," showcasing clear accountability measures. L'Oral ensures that "all members of its Executive Committee and country General Managers have both sustainability and public affairs responsibilities," with their performance evaluated annually on advancing the company's sustainability strategy, including public affairs responsibilities. The Chief Corporate Responsibility Officer regularly reviews public affairs activities related to sustainability and collaborates with the Global Public Affairs team, ensuring consistent oversight. Additionally, "Public Affairs Officers in markets are expected to collaborate with local Sustainability counterparts to advance the sustainability strategy." L'Oral also actively distances itself from trade associations opposing climate legislation, stating that "in the event a trade association takes a position not aligned with our sustainability strategy, we have been known to distance ourselves or inform them of our disagreement." The company has disclosed its lobbying activities under the HATVP in France, further emphasizing transparency. Moreover, L'Oral integrates sustainability into its governance at the highest level, with the Strategy and Sustainability Committee of the Board overseeing climate-related commitments and the Chief Sustainability Officer ensuring strategic consistency across the value chain. The company has also published detailed disclosures in its URD, including remuneration structures linked to sustainability and climate risk management. This indicates a robust governance framework that encompasses direct and indirect lobbying activities, with clear monitoring mechanisms, accountability structures, and alignment with climate goals.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	L’Oréal provides a high level of transparency around its climate-related lobbying. It names numerous concrete measures it works on, including the revision of the EU Packaging & Packaging Waste Directive, the EU Chemical Strategy for Sustainability, France’s Anti-waste Law (loi AGEC), the UN Inter-governmental Negotiation Committee for a global plastics treaty, Extended Producer Responsibility (EPR) legislation in several U.S. states and in Indonesia and the Philippines, the revision of the EU CLP Regulation, and the forthcoming Eco-design and Sustainable Products Regulation. The company also sets out the methods and interlocutors it uses: it conducts “meetings with the European Commission (JRC experts, DG JUST and DG ENV),” holds “meetings with cabinet members within ministries” in France, works “directly or indirectly through its trade association FEBEA with French cabinet-members,” joins state-level legislative discussions in California, Maine, Colorado, Oregon and Washington, collaborates with the Indonesian and Philippine Ministries of Environment to build EPR systems, and “participated in the UN plastics treaty negotiations alongside the Business Coalition for a Global Plastics Treaty.” Finally, L’Oréal is explicit about the policy outcomes it seeks, such as wanting to “ensure that national approaches are harmonized across Europe to avoid fragmenting the European single market and preventing scalable solutions,” to “create the conditions for a viable plastics recycling system in France, which requires enshrining recycled plastic,” and to embed EPR provisions that deliver “a broad inclusion of actors, a high performance of waste recycling, clear roles & responsibilities and measures that incentivize better performance.” By clearly disclosing the specific policies, the mechanisms and targets of its engagement, and the concrete changes it advocates, the company demonstrates comprehensive transparency on its climate-policy lobbying.	A