Written evidence submitted by L’Oréal UK & Ireland (MISS0016)
L’Oréal UK & Ireland is pleased to have the opportunity to submit to the Women and Equalities Committee’s consultation on body image. We would like to address the Committee’s questions around media and advertising.
For context, L’Oréal is the world’s largest beauty company. In the UK & Ireland we manage 36 brands and employ over 4,500 people across multiple sectors. Additionally, we are the UK’s market leader in the professional hair care category, distributing products and services to 12,000 salons directly and a further 12,000 through distributors. We are the number one supplier and training provider to these small businesses, conducting a range of programmes to upskill staff and help them to seize the opportunities offered by digitalization.
Our Purpose – Beauty for all
Our purpose is beauty for all: https://www.loreal.com/en/group/about-loreal/our-purpose/
We believe that beauty is a powerful force that moves us. We know that beauty is more than just looking good. Beauty gives us confidence in who we are, in who we want to be, and in our relationships with others.
We believe that there is no single model of beauty to which people should try and conform, and that we should celebrate what makes people different. We believe that cosmetics can help boost people’s self-esteem which, in turn, can reinforce positive body image. We strongly believe that there is no single model of beauty and people have unique physical features, whether it be age, skin, or hair type, which should be celebrated.
We strive to reflect and celebrate these differences as much as possible which is why you’ll see an ever-changing variety of models used by our 36 unique brands in their advertising and marketing materials. It is reflected through our L’Oréal Paris brand’s ‘Worth It’ slogan, which has been at the heart of our advertising for this brand for fifty years.
Of relevance to the Committee, L’Oréal is the UK’s eighth largest buyer of advertising spend in the UK. We understand the significant responsibility this places on us to be ethical and transparent and to promote a positive message. In every advert, our aim is always to provide a fair and truthful description and visual representation of our products and their effects. All claims made in our advertisements are extensively researched, independently validated and approved before being shown to the public, and we are guided by a strict code of ethics in applying these principles (see Appendix 1 - ‘L’Oréal Code of Ethics’ page 11). Every month our legal, scientific and corporate affairs teams review brand advertising and marketing activities to ensure adherence to relevant internal and external codes. We welcome any moves to ensure that advertising is honest and appropriate.
We strive to make sure all our advertising is planned and executed with consideration given to any potential impact on the self-esteem of those consuming it. This applies to both traditional media advertising and our work with influencers on social media. We have stringent measures in place to ensure, as far as it is possible, that any influencer engaged by us promotes positive ideals which we are happy to be associated with.
All social media influencers that we engage with to help market our products subscribe to our influencer values charter, outlined in the Appendix of this submission (See Appendix 2 - ‘Influencer Values Charter’).
Advertising to children
L’Oréal does not advertise its products to children under the age of 16 even though some products, such as hygiene products (e.g. shower gel and hair care) and skincare products (e.g. face wash and creams) are relevant for younger age groups.
We recognise that everyone, regardless of age, disability, race, religion or belief, gender reassignment status, sex, sexual orientation or marital status is at risk of poor body image. Children and teenagers are particularly vulnerable to poor body image and the subsequent impacts on their mental health. As a purchaser of marketing technologies such as programmatic advertising and retargeting, we welcome measures proposed in the government’s Online Harms White Paper including age assurance tools or a risk-based approach to recognising child users online without undermining their privacy. Privacy is very important to us we do not collect data from consumers without their explicit consent.
L’Oréal is a corporate supporter of Media Smart, a non-profit education programme from the advertising industry that supports children and young people in the UK, aged 7 – 16, to understand and critically evaluate the media landscape which they consume. The Media Smart mission is to ensure that every child can confidently navigate the media they consume including being able to identify, interpret and critically evaluate all forms of advertising. Media Smart provides free teaching resources and parent guides on subjects like social media, body image and influencer marketing.
L’Oréal believes that these skills are crucial as children grow up as digital natives, and we want to play our part in supporting younger generations to interpret advertising in a way which removes any potential negative impact.
Programmes driving Self Worth
L’Oréal uses the scale of our business and power of our brands to drive self-worth and body positivity. Here are some examples of active partnerships and marketing campaigns designed to improve confidence:
In 2016 in the UK, we decided to go further in supporting young people to develop their own individual self-worth. To do this, we partnered with the Prince’s Trust to create a new programme entitled ‘All Worth It’. This works with young people who are not in employment, education or training and is based around four pillars: confidence, communication, relationships and employability.
2. L’Oréal Paris – ‘my Self Worth’
Since February 2017, with ambassadors, employees and The Prince’s Trust, we’re helping young people through the “All Worth It” confidence-training programme, online and in all Prince’s Trust centres. Helping to transform self-doubt into self-worth for thousands of young people across the UK. A spring 2020 marketing campaign for the L’Oréal Paris brand features a diverse range of beauty Ambassadors including:
Other spokesmodels for the brand include Katie Piper, a writer and model who was the victim of an acid attack and is a spokesperson for the L’Oréal Paris brand. The brand also hired American Paralympic Athlete Aimee Mullins as a global Ambassador in 2011.
3. Look Good Feel Better Charity
Look Good Feel Better (LGFB) is the only cancer support charity helping boost the physical and emotional wellbeing of people undergoing cancer treatment.
These are three examples of the work we do to be a responsible company which promotes self-confidence, positive body image and diverse celebrations of beauty.
We are happy to discuss any part of the above with the Committee, should it be helpful, and to provide you with any further information that you might require.
Appendix 1: L’Oréal Code of Ethics – Page 11
Full code available on our website - https://www.loreal.com/-/media/ba14589b7c374360918b9c3716c771a0.ashx
Appendix 2: Influencer Values Charter
L’ORÉAL INFLUENCER VALUE CHARTER
The way we work with influencers
At L’Oréal, we share a common passion for beauty with influencers. Influencers are a brilliant way for us to connect with consumers in a more personalized way and to build closer relationships with them. Because we respect consumers and want to continue to deserve their trust, transparency and integrity are key. We are committed to developing transparent, respectful, and professional relationships with influencers and indirectly, with their respective audiences.
With this vision in mind, and taking into account the ethical stakes associated to relationships, the present Value Charter is a mutual commitment to engage in a genuine relationship in which both our values and those of the influencers are aligned and in harmony.
1. L’Oréal is committed to respect towards all people and celebrates beauty in all its diversity, and collaborates with people of all genders, backgrounds, skin types and walks of life. We seek to work with influencers who share our values and Ethical Principles – Integrity, Respect, Courage and Transparency. We reserve the right to pursue due diligence depending on the nature of the relationship we are entering in. In this case, we only review information already in the public domain.
2. We seek to partner with influencers who have built their following organically through efforts and talent. We check that influencers do not buy or artificially inflate follower count or engagement through paid-for or ‘like-for-like’ means.
3. We are fully transparent when communicating about the nature of our relationship with influencers, not only because we must comply with the applicable regulations worldwide, but also to ensure and retain consumer trust.
4. We outline our expectations, objectives and other details like timing for publications (or posting deadlines) in a clear way. We provide influencers with the creative liberty of relaying the message in their own style and voice as we value their creativity and authenticity.
5. We respect our mutual terms of agreement in terms of image and intellectual property rights (including patents, trademarks, designs, copyrights and neighbouring rights, as well as moral rights) and personal data.
6. We do not work with influencers who are under 16 years old or the legal contractual age.
7. We will act and communicate respectfully with influencers during all interactions, whether virtual or face-to-face.
1. Influencers commit to communicating in an authentic way, sharing creative, engaging and valuable content.
2. Influencers share with L’Oréal the same Ethical principles and values and commit to not posting or have previously posted content which is at odds with our values of respect, tolerance and inclusion. Furthermore, influencers will not share views or engage in behavior which could be interpreted as racism, antisemitism, homophobia, misogyny, religious intolerance, violence, bullying or aggressiveness towards others, pornography or any type of criminal activity.
3. Influencers are free to share honest opinions about our products and brands, while refraining from posting defamatory content on them.
4. Depending on the nature of the relationship, influencers commit to respect terms of agreement including rules of engagement, expectations and objectives, or content posting deadlines.
5. Influencers shall communicate in a transparent way regarding the nature of their relationship with L’Oréal by fully disclosing their commercial interests to their audience, so that there is complete transparency when content has been paid-for or incentivized (paid partnership, #SponsoredBy, etc).
6. Influencers will respect all image and intellectual property rights of third parties (including trademarks, designs, copyrights, neighbouring rights, and moral rights) as well as all consumer rights to data privacy. More specifically influencers will obtain all necessary authorizations from image and intellectual property rights owners (including models, photographers, music publishers and record labels) before using any third parties’ image and works (including music) in any content.
7. Influencers will act and communicate respectfully with L’Oréal teams during all their interactions, whether virtual or face-to-face.