As senior vice president and chief ethics officer of L’Oréal Group since 2007, Emmanuel Lulin, LLM ’89, has contributed to establishing the group’s industry leadership in business ethics. Earlier this year, the Covalence EthicalQuote Reputation Index placed L’Oréal first among more than 6,600 international companies for its ethical reputation, and this year also marked L’Oréal’s 11th recognition by Ethisphere as one of the world’s most ethical companies. Based in Paris, L’Oréal is the world’s largest personal care company, with 2019 revenues of more than 33 billion dollars and more than 88,000 employees.
“I might not always have known it, but I feel that this is the kind of job I was destined to hold, and I am fortunate to hold it at a company that is 100 percent committed to being ethical in all that it does, and to fostering ethical behavior in any context where L’Oréal exists,” he said.
When he was just a teenager, Lulin worked with the Nazi hunters Serge and Beate Klarsfeld to seek justice for Holocaust victims. Going into several countries to dig out information, his work contributed to exposing atrocities and their perpetrators and to the discovery of the Auschwitz Album, which is virtually the only known pictorial evidence of the extermination process inside the German concentration camp. “You could say that that experience put me on an expressway to maturity,” he remarked.
After earning law degrees in France, where he had grown up, he came directly to the Law School to pursue his LLM degree. “I went to Chicago partly because of the Law and Economics program,” he recounted. “I thought it would be valuable for that perspective to be more widely understood and practiced in Europe. And I also went because I knew the Law School would push me and challenge me—which it did, in many important ways.”
Ten years with a top-tier firm followed his graduation, and then he decided that he wanted to work inside a company, where he would have a more direct say in what happened and be responsible for lasting results. He joined L’Oréal as its general counsel for human resources in 1999 and led the creation of the office of the chief ethics officer in 2007.
“Any company can have policies and regulations about ethics,” he said. “Most of them are window dressing. It’s behavior that matters—it’s whether or not everyone walks the talk.” His measures to make that happen have been bold. For example, each year the company holds an Ethics Day, during which employees can submit questions to CEO Jean-Paul Agon. Last year, more than 60,000 employees participated and more than 7,000 questions were submitted. Employees electronically rank the questions and Agon personally answers the highest vote getters throughout the day. The company sends a letter to every employee each year disclosing how many cases of sexual harassment, bullying, and discrimination have been substantiated, in whole or in part, and disclosing what corrective measures have been taken.
Lulin has personally visited L’Oréal subsidiaries in more than 65 countries. “Nothing beats personal contact to show that we are serious about everyone living our values,” he said. The company’s ethical principles have been distilled to four—integrity, respect, courage, and transparency—and to drive them home, Lulin led the publication of a book of quotes, maxims, and proverbs contributed by employees from around the word that encapsulate the company’s ethics.
“Being ethical is not just the right thing to do, it’s also good for business,” he said. “It creates trust, and trust is an extremely valuable thing in today’s fractured world. We need the trust of our employees, our customers, our suppliers, our shareholders, and any other person or entity we interact with. Ethics is one of the best long-term investments.” Committed to spreading that idea, over the past five years he has presented classes in ethics at more than 100 organizations and been interviewed or featured more than 100 times in business publications worldwide.
“All lawyers know that there are things that are lawful but awful, and we know that in these fast-moving times the law is not always the most reliable guide for proper action,” Lulin said. “I have the immense privilege of thinking about ethics every day, and of helping colleagues to recognize and do what is right and sincere. It’s my life’s journey, and I couldn’t be happier than to be on that journey.”