Human Rights Policy

OUR COMMITMENT

As we (The Estée Lauder Companies or ELC)1 approach human rights in our operations and across our value chain, we aspire to foster respect for people and the environment and to be a positive influence in every community in which we operate and from which we source. As a global company, we comply with laws and regulations around the world where we conduct business. We also expect those who provide us with services or goods (collectively “suppliers”) to operate in compliance with all applicable laws, including, but not limited to, employment laws pertaining to child labor, minimum wages, overtime compensation, hiring, and occupational safety.

This human rights policy outlines our approach to respect human rights across our global operations and supply chain and follows these international protocols:

• UN Guiding Principles on Business and Human Rights
• Universal Declaration of Human Rights

OUR APPROACH

This policy applies to all ELC employees, locations, operating companies and employees of subsidiaries and joint ventures in which we hold a majority interest. We also expect our suppliers to respect human rights in their own operations and supply chains. We promote a culture of uncompromising ethics and integrity and put forth standards to uphold the principles and ideals that make us a global leader in prestige beauty. We have tailored approaches for various stakeholder groups that focus on key risks and opportunities.

As of the date of this policy, we have policies, processes, training and systems in place to identify, assess, monitor and mitigate or eliminate actual or potential human rights impacts, several of which are referenced below.

OUR SALIENT HUMAN RIGHTS RISKS

ELC has conducted a corporate-level Human Rights Assessment (HRA) based on the methodology outlined by the UN Guiding Principles on Business and Human Rights, the global standard for HRAs. Through the HRA process, we assessed human rights risks and impacts across our operations, including our corporate policies and procedures, as well as our supply chain, manufacturing, and retail operations. We continue to evaluate and enhance these processes and policies and engage with our internal and external stakeholders in implementing them.

The HRA provides us with a framework to help identify and prioritize our salient human rights risks and impacts, and to identify key actions for improvement. Our salient human rights risks are:

• Access to Grievance Mechanisms​
• Child Labor and Juvenile Work​
• Discrimination and Equality ​
• Forced Labor and Modern Slavery ​
• Freedom of Association and the Right to Collective Bargaining​
• Harassment and Gendered Impacts ​
• Impacts on Local Communities​
• Occupational Health and Safety ​
• Privacy ​
• Working Hours, Wages and Benefits

OUR OPERATIONS

The continued success of our Company’s business depends on a safe and inclusive workplace in which all employees can perform to the best of their ability.

Our Code of Conduct (“Code”) sets forth basic guidelines that all employees are expected to follow. It also outlines our commitments to our employees, including:

• providing equal opportunities for employment;
• basing employment decisions on merit, considering qualifications and achievement; and
• having a zero-tolerance policy for harassment and strictly prohibiting conduct that constitutes, or that could lead or contribute to, harassment based on a protected class.

All ELC employees are expected to conduct themselves at all times within the letter and the spirit of the Code. New hires are required to sign off on the Code upon hire, and certain employees receive annual Code refresher training. We conduct training for managers, supervisors and other appropriate employees on topics related to our Code, including unconscious bias and inclusion and diversity training.

Inclusion, Diversity, and Equity

At ELC, inclusion and belonging means being a people-first company, respecting and caring for all our employees, communities and consumers. ELC’s strength is rooted in the collective diversity of backgrounds and unique perspectives of our employees, which we believe results in greater innovation and problem solving across our organization. We will continue to empower and engage our employees and are committed to amplifying their talents. With consumers in approximately 150 countries and territories around the world, we recognize that to properly serve the communities in which we live and work, our company must reflect and represent our diverse global consumer base.

We are committed to promoting and maintaining a culture where we welcome each person’s unique strengths and talents, including geography, age, culture, race/ethnicity, gender, gender identity, sexual orientation, religion, physical ability or socioeconomic status. We have a longstanding commitment to inclusion and belonging and to empowering employees at all levels of the company. For more on how we nurture a culture of respect and belonging, please visit our website.

A Healthy, Safe, and Sustainable Workplace

We are committed to keeping our workplace safe, healthy, and welcoming. This means preventing violence, promoting well-being, and providing a safe work environment. We continuously assess our performance and set corporate-wide safety goals in support of our commitment to employee safety. We also provide health and wellness programs for our employees. To meet these objectives, our Company:

• Meets or exceeds requirements of applicable environmental, health, and safety laws and regulations;
• Promotes employee safety and responsible environmental and safety practices; and
• Minimizes the environmental impact of the development, production, and distribution of our products, and applies pollution prevention, resource conservation, waste minimization, and reuse and recycling practices.

Wages and Terms of Employment

We require our employees, business partners, service providers, and suppliers to operate in compliance with all applicable laws, including, but not limited to, employment laws pertaining to child labor, minimum wages, overtime compensation, hiring, and occupational safety.

OUR SUPPLIERS

We recognize that our suppliers operate in diverse legal and cultural environments throughout the world. Our Supplier Code of Conduct (“Supplier Code”) sets forth the basic requirements we expect of suppliers, including vendors, service providers, independent contractors and consultants. We expect our suppliers to operate in compliance with applicable laws and our Supplier Code of Conduct, including, but not limited to, employment laws pertaining to child labor, minimum wages, overtime compensation, hiring, and occupational safety. 

We take a risk-based approach to supplier due diligence. We conduct due diligence as part of new supplier qualifications and assess risk of existing direct and indirect suppliers annually. We risk-rank direct and indirect suppliers globally based on pre-established criteria, such as location of operations, type of goods or services being sourced, and potential impact to our business. Based on the risk ranking of the supplier, we conduct additional due diligence using third-party on-site audits or assessments, as appropriate. This additional due diligence assesses suppliers on environmental impact, labor, human rights, and ethics.

In this regard, we provide guidance to suppliers, which can be found in the ELC Supplier Sustainability Guidelines. This includes ways a supplier can build upon the foundation of the Supplier Code standards, to consider and apply to its business sustainability and human rights best practices and continuously improve.

We have collaborated with suppliers, industry groups, peers, local non-governmental organizations and communities to address certain pressing human rights challenges and advance our practices. We will continue to work collaboratively across our many stakeholders to address these complex challenges and matters as they arise.

OUR CONSUMERS

Consumers around the world trust our brands to deliver a High-Touch beauty experience that is safe, effective and socially and environmentally responsible. We greatly value the trust our consumers place in our extraordinary products for their efficacy and safety. Our Ingredient and Product Testing and Safety commitment outlines how we ensure that all our products are safe to use as intended.

We know that consumers trust us with their personal information, and we are committed to respecting their privacy and the security of their information.

OUR COMMUNITIES

The Estée Lauder Companies’ (ELC) founding values inspire our commitment to operate responsibly and motivate us to build a sustainable business based on uncompromising ethics, integrity, fairness, diversity and trust. In partnership with our suppliers, our retailers, our consumers and everyone we touch, we aspire to foster our heritage of respect for people and the environment and be a positive influence in every community we serve.

As a global company with a portfolio of well-known brands, we have many opportunities for meaningful engagement in citizenship causes that matter to our employees, consumers, communities and suppliers. We develop and implement strategies to reduce operational impacts for our company-owned production, distribution, and retail facilities. We have also set citizenship and sustainability goals in focus areas where we believe we have the opportunity to positively impact the environment and society. To read more about our commitment to citizenship and sustainability, please visit our website.

Nature & Human Rights

We consider environmental sustainability and respect for human rights to be interlinked. We recognize the relationship between the environmental impacts and its connection to human rights – such as the right to health and the right to water, sanitation, and hygiene (WASH) – and are therefore working to integrate human rights considerations into our environmental policies and programs.

To ensure the protection of local communities and the environment, we have developed a No Deforestation, No Peat, No Exploitation (NDPE) Policy, Timber and Palm Action Plan, and Water Stewardship Policy.

These policies enshrine our commitment to sourcing sustainably and outline our expectations for suppliers to uphold sustainable, rights-based sourcing principles, such as free and prior informed consent (FPIC) to ensure protection and promotion of the rights of indigenous peoples and vulnerable communities. We assess compliance with these responsible sourcing policies through supplier sustainability performance, increased transparency, and third-party certification. Learn more about our sourcing responsibly strategy here.

ENGAGING OUR STAKEHOLDERS

At ELC, we recognize the importance of engaging with employees, workers, and other rights-holders across our operations and value chain.

Access to Grievance and Remedy

We have grievance mechanisms in place for employees and others affected by our operations to report any concerns or potential violations of this policy. Employees have several avenues to raise questions or concerns about whether any behavior is consistent with the law, our Code of Conduct or Company policies, including reporting to managers and supervisors, Human Resources, and Global Ethics. If there are allegations of a violation, the matter will be reviewed, investigated, and remediated as appropriate. Employees and non-employees can report concerns through our Integrity Helpline and other resources.

We will not tolerate retaliation against anyone who in good faith raises questions or concerns about a potential violation of the law, our Code, or Company policies, or who assists in an investigation of a reported violation. Retaliation in any form is itself a serious violation of our Code and is strictly prohibited. Acts of retaliation or potential retaliation should be reported immediately. Anyone found to have retaliated against an individual will be subject to disciplinary action, up to and including termination of employment.

Employee Training

ELC provides a suite of internal training courses related to ethics, human rights, responsible sourcing, and social impact and sustainability. In addition to the Code training mentioned above, targeted employees in functions with proximity to our human rights due diligence program are required to take a modern slavery prevention training module.

GOVERNANCE AND OVERSIGHT

At ELC, our human rights policy and progress is overseen by our Chief Sustainability Officer; Executive Vice President, Chief People Officer; and Executive Vice President, Chief Value Chain Officer.

This policy has been reviewed and approved by our Chief Executive Officer. ELC intends to review and update this policy periodically to reflect changes in processes and procedures.

ADDITIONAL RESOURCES

For additional information, please refer to the following resources:

Employee Code of Conduct
Modern Slavery Enterprise Statement
Supplier Code of Conduct
Supplier Sustainability Guidelines
FY25 SI&S Report