L'ORÉAL SA MULTI-YEAR ACCESSIBILITY PLAN

L'ORÉAL SA MULTI-YEAR ACCESSIBILITY PLAN

Date of last update: 21 May 2025

1. Introduction

In application of Article 47 of Law No. 2005-102 of February 11, 2005, L'Oréal SA (hereinafter "L'Oréal" or "we") presents its multi-year plan 2025-2027 dedicated to its initiatives for digital accessibility (hereinafter the "Plan").

L'Oréal Groupe has been committed to diversity, equity and inclusion for more than 20 years. Our commitments extend to our employees, our consumers and our communities.

L'Oréal is committed to accelerating the inclusion of people with visible and invisible disabilities.

As digital technology becomes central to our interactions, L'Oréal reaffirms its commitment to a digital experience accessible to all. Our strategy focuses on the accessibility of our physical and digital environments, so that every employee and every consumer can fully benefit from L'Oréal's products and services.

This involves ensuring that our platforms, websites, and applications are designed to be understandable and usable by everyone, our consumers as well as our employees, including people with disabilities or those with specific accessibility needs.

L'Oréal is implementing a multi-year plan to improve the accessibility of its platforms and digital tools, in line with its commitments to diversity, equity, and inclusion, for the benefit of its employees and consumers.

The sites concerned by this Plan are:

2. Internal Management of Digital Accessibility and Collaboration with External Partners

2.1.  International and Transverse Governance

Since 2017, L'Oréal has been driving digital accessibility through a dedicated digital accessibility task force, composed of experts from the Diversity, Equity & Inclusion, Digital, IT, Beauty Tech, Legal, Purchasing, and HR Learning teams. This task force has played a key role in developing comprehensive guidelines to address a wide range of needs, from websites and intranets to mobile applications, events, and everyday digital tools, ensuring accessibility is embedded at every stage of our processes.

Several key departments have been identified within the L'Oréal group to contribute to digital accessibility:

  • Global Diversity, Equity & Inclusion for considering the accessibility needs of L'Oréal teams but also for promoting and raising awareness of digital accessibility issues.
  • Information Systems Technologies Department (DSI) for operational implementation in projects (scoping, implementation, and progress measurement).
  • Employee Experience Department (Human Relations) on issues related to workplace adjustments and the accessibility of tools deployed to teams.
  • Training and Development Department for awareness and training actions for teams, but also on questions of accessibility of training programs and the platform for accessing these programs.
  • Legal & Purchasing for regulatory monitoring and contractual framework with the various partners and suppliers of L'Oréal.

Governance bodies bringing these different actors together allow for the coordination of efforts and sharing of progress:

  • A steering committee with bi-annual meetings.
  • An operational committee with monthly meetings.

These different teams define the implementation strategy for digital accessibility, which is represented through this Plan and the associated annual action plans.

To effectively implement accessibility across the company, L'Oréal has appointed dedicated accessibility referents. These referents possess robust expertise in both the methodological and technical aspects of digital accessibility. The team includes a global referent, a dedicated referent for the Americas zone, and a referent for France. These experts undergo continuous training to develop and maintain their skills, while also actively participating in various accessibility working groups.

2.2.   Collaborative Approach to Accessibility within Strategic Partnerships

As testament to its desire to integrate digital accessibility into all its IT and digital assets, L'Oréal is involved in several business coalitions to collectively and sustainably drive progress in this area. Among them:

  • Global Business and Disability Network, a program of the International Labour Organization (ILO) dedicated to the inclusion of people with disabilities in the professional world.
  • Valuable 500, a global business partnership of 500 companies working together to end disability exclusion.
  • Disability:IN, a global organisation that supports and empowers over 500 leading companies to achieve disability inclusion and equality.
  • Ad Accessibility Alliance, a group of trade bodies as well as brand and media owners and partners, whose ambition is to make all advertising accessible to all, especially those with hearing and visual impairments. The Alliance has notably developed a resource hub to provide users with examples of best practices, guidance and practical steps to create more accessible advertising.

2.3.  Financial Resources

L'Oréal invests in digital accessibility by allocating a specific budget to the actions detailed later in this Plan. This investment reflects L'Oréal's desire to place accessibility at the heart of its strategy and to ensure that its resources, workspaces, and digital tools are inclusive and accessible to everyone: consumers and employees alike.

3.  Deployment and Sharing of Digital Accessibility Notions

3.1.  Employee Training and Awareness

L'Oréal regularly conducts awareness and training actions to strengthen the consideration of digital accessibility among its employees. These initiatives include dedicated events, online training modules, and specific sessions adapted to different professions.

Awareness events are organized with online or in-person sessions to reach a large audience. The topics covered are varied, encompassing both an introduction to digital accessibility and guidance on integrating best practices.

L'Oréal offers a comprehensive diversity, equity and inclusion training program, that is available to all group employees both in-person and online, which covers a selection of subjects, including a six-module segment dedicated to digital accessibility.

Furthermore, a network of employees from various professions and geographical areas meets to exchange good practices and champion accessibility throughout the organization and its processes.

These various actions aim not only to transmit practical knowledge but also to strengthen the culture of digital accessibility within L'Oréal.

3.2.  Employee Recruitment

The Group has set a minimum target for direct employment of people with disabilities in all countries where it operates. The goal is to create impact internally and externally for all stakeholders by eliminating stigmas and fostering accessibility. This commitment is reflected in particular by actions in favor of recruitment, employee loyalty, and adaptation of the workplace for greater inclusivity.

4.  Operational Implementation

In addition to awareness actions, L'Oréal deploys resources and tools to assist in taking accessibility into account.

4.1.  Internal Organization

L'Oréal has set up an internal organization to evaluate and maintain the compliance of its digital services with international accessibility standards.

First, L'Oréal is exploring the use of automated testing tools, such as Google Lighthouse, which help detect non-conformities and ensure a first level of control.

For precise and effective monitoring, L'Oréal relies on an internal dashboard (One Report) that monitors public sites on performance, SEO, and accessibility criteria. The evaluation of accessibility is also integrated into this dashboard, relying on automated tests.

This system was supplemented in 2024 by a barometer based on manual tests. Through the help of this barometer, L'Oréal ultimately aims to be able to monitor and prioritize corrective actions and/or audits. The data from it will allow:

  • to quickly identify and correct accessibility problems, which contributes to better resource management and greater operational efficiency.
  • to foster a culture of innovation and inclusion, encouraging the development of accessible solutions that meet the needs of all users.
  • to provide valuable data that can be used to evaluate the effectiveness of accessibility initiatives and to guide continuous improvements, ensuring that L'Oréal and its teams progress in the practices of taking accessibility into account.

L'Oréal also wishes to evaluate and measure the consideration of accessibility with the help of indicators, such as the number of sites and intranets compliant with accessibility standards, the number of audited sites, the number of new projects integrating accessibility, and the number of employees made aware and trained. These indicators will enable the evaluation and communication of progress made in digital accessibility.

4.2.  External Resources and Technical Means

L'Oréal recognizes the importance of offering an inclusive experience that meets the needs of as many people as possible. It is with this objective that L'Oréal mobilizes external resources and technical means to strengthen its expertise and guarantee the conformity of its digital services with accessibility standards.

L'Oréal relies on external experts, recognized for their skills in digital accessibility. They are selected via calls for tenders managed by the IT accessibility referents and support the project teams on:

  • The execution of audits to evaluate the conformity of products and services and to recommend corrective measures.
  • Support in the design and development of projects, by integrating accessibility from the initial phases of product or service creation or redesign projects.

To ensure the conformity of products and services with accessibility standards, L'Oréal relies on a set of technical standards such as the RGAA and WCAG references.

L'Oréal seeks to strengthen its processes with a regular manual testing approach, carried out by trained teams. This approach will allow for the identification of more elements that escape automated tools.

4.3.  Contractual Clauses and Relations with Service Providers

To further support accessibility in digital projects, L'Oréal has made an accessibility clause available for integration into supplier contracts and agreements where relevant. This clause helps to ensure that products and services meet international standards on digital accessibility and reflects L'Oréal's commitment to promoting inclusion.

5.  Compliance Work

5.1.  Integration of Accessibility into New Projects from Inception

L'Oréal aims to take into account digital accessibility and compliance with standards from the inception of its new projects.

From now on, accessibility is systematically evaluated during the internal validation process of IT and digital projects (Design Authority).

Accessibility is integrated from the inception, particularly for B2C projects (sites dedicated to consumers) and the development of master brand sites, both technically and visually.

The objective is now to systematically extend this approach to B2B sites (sites dedicated to professionals), institutional sites, and the L'Oréal group's intranets, in order to offer an inclusive experience for all users, internal and external.

5.2.  User Tests with People with Disabilities

Accessibility cannot be limited to automated analyses alone: the real user experience, especially that of people with disabilities, requires a more in-depth approach.

L'Oréal aims to strengthen the implementation of user tests targeted with people with disabilities. These tests, conducted in addition to expert audits, will allow for the evaluation of the real user experience and the identification of points for improvement to guarantee optimal accessibility and an inclusive experience for all.

5.3.  Evaluations and Compliance Audits

Accessibility audits make it possible to evaluate and improve the accessibility of digital products and services, but also to respond to local regulations which require the publication of declarations of conformity.

L'Oréal's ambition within the framework of this Plan is to audit nearly 40 public B2B or B2C websites with expert support. The objective is to publish accessibility documentation that complies with applicable regulations.

These sites will publish a declaration of conformity according to the standards in force in the target country (EN 301 549 in Europe, RGAA in France, and WCAG in other territories).

5.4.  System of Corrective Measures and User Support

For L'Oréal, ensuring optimal accessibility means putting in place reactive and effective systems to support each user, consumer, or employee with specific needs.

In this sense, L'Oréal is committed to optimizing the accessibility of its contact points, particularly its customer services, by offering channels adapted to the specific needs of users with disabilities.

For any specific request relating to the accessibility of a L'Oréal group brand website, users are invited to use the contact point indicated in the accessibility declaration of the site concerned in order to receive personalized assistance.

L'Oréal aims to set up a process for monitoring reports to identify, analyze, and deal with any difficulty related to digital accessibility.

6.  Action Plan and Objectives

6.1.  Achievements and Progress Made

Examples of concrete actions carried out by L'Oréal:

  • 2018: Implementation of support for design and development teams by accessibility experts, particularly for "master" sites.
  • 2019: Update of the MS Office pack to integrate accessibility features.
  • 2022-2024: Accessibility audits of 7 "master" sites and 19 brand sites on the North American market (WCAG standards).
  • 2024 - 2025:
    • Continuation of brand site audits on the North American and European markets.
    • Creation and provision of tools to support the teams.
    • Integration of accessibility into an internal barometer.
    • Drafting of the multi-year accessibility plan and its action plans.

6.2.  Action Plan and Objectives for 2026/2028

Note that certain actions will be carried out over several years.

Year(s) Theme Action Status
2026 Communication Ensure the publication of accessibility declarations on the concerned public sites and applications. In progress
2026 Communication Simplify access to adapted software and equipment for employees with disabilities. In progress
2026 Monitoring & Measurement Implement means of collecting and monitoring performance indicators. In progress
2026 Monitoring & Measurement Audit and publish the compliance rates of more than 10 internet sites. In progress
2026 Monitoring & Measurement Create and publish the list of audited sites and the results (end of 2026). Upcoming
2026 Monitoring & Measurement Update the data of the accessibility barometer. Upcoming
2026-2027 Process & Governance Strengthen processes to integrate accessibility from the design phase and after the projects go live. In progress
2026-2027 Process & Governance Structure a validation methodology combining automated tests and manual evaluations. In progress
2026-2028 Awareness & Training Awareness and training for digital marketing and IT teams. In progress
2026-2028 Awareness & Training Awareness and training for teams in charge of communication (internal and external). In progress
2026-2028 Awareness & Training Awareness and training for teams in charge of L'Oréal employee training. In progress
2026-2028 Awareness & Training Deploy training on office tools to produce accessible content. In progress
2026-2028 Tools & Resources Communicate on accessibility guides and support their use. In progress
2026-2028 Process & Governance Train teams to carry out manual accessibility tests. In progress
2026-2028 Process & Governance Integrate accessibility requirements into consultations and calls for tenders (legal and purchasing teams). In progress
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