Human Rights Policy

we celebrate the unique beauty, voice and value of every eye, lip and face.

e.l.f. Beauty, Inc. (“e.l.f.” or the “Company”) proudly supports human rights and individual expression and freedom. As such, we ensure our employees have their rights respected, regardless of age, gender, ethnicity, or sexual orientation. e.l.f. Beauty also expects its suppliers and partners to observe these principles when providing products and services to the Company. This policy is endorsed and overseen by our Board of Directors and senior management team.

e.l.f. Beauty stands with every eye, lip, face and paw with a deep commitment to inclusive, accessible, cruelty-free beauty.
we take a clear stance on human rights.

Human Rights Principles

At e.l.f. Beauty, we are committed to the following Human Rights principles:

  • Recognizing human rights in all parts of the world and opposing discrimination based on race, ethnicity, color, gender, pregnancy, sexual orientation, gender identity, age, religion, creed, national origin, disability, legally protected leave or veteran status, political opinion, and other categories protected by applicable law.
  • Ensuring our partners and suppliers adhere to the Company’s Code of Business Conduct and Ethics, this Human Rights policy and any other best practices related to human and labor rights.
  • Banning the practice of recruiting children and exploiting child labor, as well as ceasing partnership with any third party involved in such practices.
  • Prohibiting any form of physical or mental abuse of employees such as disciplinary punishment, as well as prohibiting the use of all forms of forced labor, including forced prison labor, indentured labor, bonded labor, or slave labor and the human trafficking associated with such abuses.
  • Supporting human rights practices as outlined by the United Nations Universal Declaration of Human Rights and the International Labor Organization (ILO) Core Labor Standards.
  • Subscribing to the UN Global Compact and principles regarding labor practices, human rights, the environment and anti-corruption.

Human Rights Strategies

e.l.f. Beauty has identified aspects of our business that require special attention to human rights standards. The Company set guidelines in those areas that should be followed by our employees, partners, and suppliers in order to adhere to human rights best practices across all operations and monitor potential threats and risks to those rights. The following policies and actions represent e.l.f. Beauty’s current strategy on human rights:

  • Code of Business Conduct and Ethics: All of our employees are expected to be familiar with the Company’s Code of Business Conduct and Ethics, ensuring they will conduct themselves in an honest and ethical manner, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. Our employees should be aware that the Company is obligated to comply with all applicable laws, rules, and regulations. It is the employees’ personal responsibility to adhere to the standards and restrictions of such rules. Similarly, our partners and suppliers are obligated to observe our Code of Business Conduct and Ethics.
  • Forced and Child Labor: None of e.l.f. Beauty’s operations allow the use forced labor and we are committed to cease involvement with any party that allows such practice. Also, we will not, under any circumstance, hire, engage professionally or knowingly employ anyone younger than sixteen (16) years of age. Read more about our Labor Management Policy here.
  • Employee Compensation: At e.l.f. Beauty, we take a “one team” approach to compensation. Every employee receives a base salary, is bonus eligible under the same bonus target tied to the financial performance of the Company, and receives an equity award. We believe this approach – which applies across all employee levels and geographies – is unique in the beauty industry and contributes to our success in hiring and retaining top talent and driving business results. We support the full development of the professional and personal goals of our employees and believe their compensation, to the greatest extent possible, should be sufficient to cover at least their basic needs, in compliance with relevant legislation and legally mandated work hours and overtime compensation. The same principles should be followed by all our suppliers and third parties engaged with e.l.f. Beauty.
  • Diversity, Equity & Inclusion: We are deeply committed to diversity, equity and inclusion. We believe in a world where everyone can own their beauty, without compromise. We are committed to creating a culture internally – and in the world around us – where all individuals are encouraged to express their truest selves, are empowered to succeed, and where we do the right thing for people, the planet and animals. Our organization is committed to providing equal opportunity for all employees at all levels regardless of race, color, religion, sex, national origin, citizenship, ethnicity, age, disability, marital status, veteran status, sexual orientation, gender identity or any other characteristic protected by law in the terms or conditions of employment. This includes but is not limited to recruitment, hiring, promotion, transfer, compensation, training, demotion, or layoff. Read more about our Diversity, Equity & Inclusion Policy here.

Monitoring, Auditing & Verification

e.l.f. Beauty maintains the following procedures to monitor and seek external verification in our own locations and our suppliers’ facilities regarding workplace conditions and human rights practices:

  • Supplier Policy Statement: We require that all third-party suppliers in China (where substantially all of our products are sourced and manufactured) annually sign our Supplier Policy Statement that confirms compliance, among other things, with maintaining a safe and healthy workplace environment, prohibiting the use of child or forced labor, prohibiting discrimination and observing principles of human rights in the workplace.
  • Periodic On-Site Audits: We periodically conduct on-site visits to our third-party suppliers in China to assess, among other things, compliance with our Supplier Policy Statement.
  • Third Party Certifications: Many of our Tier 1 third-party suppliers are certified by independent third parties, which require periodic surveillance audits in order to maintain certification. Please see additional detail in the table on the following page.
  • Ongoing Supplier Assessments: We are also in the process of launching the EcoVadis program, a third-party certification to evaluate and monitor the sustainability performance of our supply chain partners. EcoVadis 360° ESG assessments are used to assess the environmental and social performance of our suppliers based on supplier documents related to four key areas: Enviornment, Labor and Human Rights, Ethics, and Sustainable Procurement.
CertificationDescription% of Tier-1 Supplier Facilities certified(1)
ISO 9001:2015An internationally recognized standard for Quality Management Systems (QMS) Certified by independent third parties Certification is maintained through a program of annual surveillance audits, as well as recertification audits every three years93%
ISO 14001:2015An internationally recognized standard for environmental management systems (EMS) Certified by independent third parties Certification is maintained through a program of annual surveillance audits, as well as recertification audits every three years41%
SA8000An internationally recognized social certification standard that encourages organizations to develop, maintain and apply socially acceptable practices in the workplace Certified by independent third parties Certification is maintained through a series of required surveillance audits in the 3-year certification cycle, as well as recertification audits every three28%
SEDEX(2)A non-profit organization for businesses committed to continuous improvement of the ethical performance of their supply chains Certified by independent third parties Certification is maintained through a series of required surveillance audits in the 3-year certification cycle, as well as recertification audits every three years19%
  1. As of March 2021.
  2. The Supplier Ethical Data Exchange.

Risk Assessment

In addition to periodic on-site visits to our third-party suppliers in China (where substantially all of our product is sourced and manufactured), e.l.f. Beauty requires all third-party suppliers in China annually sign a Supplier Policy Statement that confirms compliance, among other things, with maintaining a safe and healthy workplace environment, prohibiting the use of child or forced labor, prohibiting discrimination and observing principles of human rights in the workplace. Risk factors considered in the selection of our suppliers where we conduct in person facility audits and the frequency thereof include geographic risks, industry-associated risks, and the volume of business we do with said supplier. We have not, to date, assessed a supplier as high risk in the area of human rights. To the extent we were to do so in the future, we would either terminate our relationship with said supplier or work on a remediation plan, which may include a third-party audit.

Reporting, Accountability & Enforcement

The Company promotes ethical behavior and encourages covered parties to talk to managers and other appropriate personnel when in doubt about the best course of action in a particular situation. e.l.f. Beauty ensures no adverse action will be taken against any employee, former employee, agent or third party for complaining about, reporting, participating in or assisting in the investigation of a suspected violation of the Company’s Code of Business Conduct and Ethics, Company policy or applicable law.

We created the following channels for employees and external parties to obtain guidance, ask questions and report any alleged violation of the Company’s Code of Business Conduct and Ethics or applicable laws/policies:

  • Telephone Hotline: Any person may call 1-844-240-0005 (from the United States) or 10-811, then 800-603-2869 (from Shanghai, China) to report an incident. The phone call will be received by an independent third-party service provider specifically engaged to identify improper activity.
  • Internet: Any e.l.f. Beauty employee may go to www.lighthouse-services.com/elfcosmetics to report an incident. The link opens an Incident Form text box in which an employee may submit an incident report. The Incident Forms are managed by an independent third-party service provider specifically engaged to identify improper activity. Employee anonymity will be protected.

Remediation

e.l.f. Beauty will conduct a thorough investigation on every suspected violation of our guidelines or applicable law within our facilities and operations. The Executive Team member of the department where the alleged violation occurred shall ensure that a prompt and thorough investigation is conducted, with notification to Human Resources and Legal as appropriate.

Training

All of our salaried employees are required to review and sign our Code of Business Conduct and Ethics. Certain e.l.f. Beauty employees will be required to become familiar with this Human Rights policy and polices related to labor practices and protection of the environment.

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