2024/2025 Statement: Combating Modern Slavery

Modern slavery encompasses a range of severe human rights abuses, including human trafficking, forced and bonded labor, servitude, the sale and exploitation of children, and other forms of coercive control. At its core, modern slavery involves the exploitation of individuals through the deprivation of liberty for personal or commercial gain.

According to the 2023 Global Slavery Index, an estimated 50 million people are living in situations of modern slavery on any given day, including 28 million in forced labor and 12 million children engaged in exploitative work across industries such as agriculture, textiles, mining, and manufacturing. Women and children remain disproportionately affected, reflecting persistent global inequalities and systemic vulnerabilities in supply chains.

The scale of this issue is also deeply concerning in the countries where Lush operates and sources materials. For instance, the U.K. has an estimated 122,000 people living in conditions of modern slavery, while Japan’s figure is approximately 144,000. These numbers are far exceeded by sourcing regions such as India (11 million), China, Pakistan, Indonesia, and Türkiye, all of which are identified as high-prevalence countries.

While the exact extent of modern slavery is difficult to quantify, evidence indicates that it continues to rise globally. The International Labour Organization (ILO) and Walk Free Foundation report that the number of people in forced labor increased from 24.9 million in 2016 to 27.6 million in 2021 — equating to 3.5 victims for every 1,000 people worldwide.

Our Reporting Obligations and Commitment

This, our 10th Modern Slavery Statement, has been prepared and approved in accordance with the following legislation:

• U.K. Modern Slavery Act (2015) – Section 54 mandates annual disclosure for companies with a global turnover exceeding £36 million carrying on business in the U.K.. Annual disclosure is required for the financial year. Lush’s financial year runs from July to the end of June.
• Australian Modern Slavery Act (2018) – Requires annual modern slavery reporting by entities with consolidated annual revenue of at least $100 million AUD. Reporting is tied to the entity’s financial year.
• Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (2024) – Requires annual reporting to the Minister of Public Safety by May 31st each year.
• California Transparency in Supply Chains Act (2010) – Mandates annual disclosures (not tied to a company’s financial year) by large manufacturers and retailers regarding efforts to eliminate slavery and human trafficking in supply chains.

As a basis for this statement and to ensure it satisfies all the above, we prepare this statement using the guidance for responding to supply chain transparency requirements in the United Kingdom, Australia, and Canada published in July 2025.

Please note that this statement will be published by the applicable deadlines in all relevant jurisdictions it is designed to comply with (U.K. Modern Slavery Act 2015, Australia Modern Slavery Act 2018, Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act, and the California Transparency in Supply Chains Act (S.B. 657)).

A decade later, the U.K. Modern Slavery Act 2015 was pioneering when enacted, but its impact has been limited because it only mandates companies to publish statements, with no real enforcement mechanism for non-compliance.

Other jurisdictions have since moved ahead, raising the risk that the U.K. could become a “dumping ground” for goods produced under exploitative conditions.

For meaningful progress, the U.K. should adopt mandatory human rights and environmental due diligence (mHREDD) legislation, which would create a level playing field for responsible businesses, increase transparency and accountability, and better protect workers throughout supply chains.

There is also criticism of the government’s failure to improve prevention systems and statutory guidance, leaving victims without adequate support. There is an urgent need for comprehensive reforms to ensure that victims receive the support and protection they deserve.

With this in mind, Lush also recognizes and closely monitors broader international due diligence obligations and emerging regulations, including:

• French Duty of Vigilance Law (2017)
• German Supply Chain Due Diligence Act (2023)
• E.U. Corporate Sustainability Due Diligence Directive (CSDDD) (2024)
• E.U. Forced Labour Regulation (2024)
• Norwegian Transparency Act (2022)
• Swiss Ordinance on Due Diligence and Transparency in Supply Chains (2023)
• U.S. Uyghur Forced Labor Prevention Act (2021)
• Japanese Guidelines on Respecting Human Rights in Responsible Supply Chains (2022)
• New Zealand Modern Slavery Bill (2024)

Purpose and Scope of This Statement

This statement covers the period July 2024 to June 2025 and outlines:

• The steps Lush has taken to assess and address the risks of modern slavery and human trafficking within our operations and supply chains;
• Our progress in implementing due diligence and traceability systems globally;
• The outcomes of supplier assessments and remediation efforts; and
• Our commitments for the coming year.

Our Business - Organizational Structure

Lush originated in the U.K., with its head office in Poole. It was started in 1995 by a close-knit team who have worked together for over 40 years. The first Lush shop opened at 29 High St, Poole in April 1995, with products made in a small space above the shop. Lush places emphasis on the benefits of using the finest quality, fresh, natural ingredients in our products for their nutritious effects on the body and mind. We strive to ensure our products reach our customers in the freshest condition, when they are most potent and effective — it’s at the heart of our philosophy. We use ingredients such as fruits and vegetables, herbs, flowers, butters and essential oils (organic wherever possible) and with minimal synthetic preservatives. All products are vegetarian, and the majority are vegan, too.

Lush’s global expansion, while rapid, has been carefully controlled. After 30 years in business, Lush has over 105 stores in the U.K. and Ireland (at the end of FY25), 869 shops worldwide (including all Group and Partner shops) and is present in 53 countries, with full scale manufacturing operations in five countries: The U.K., Canada, Croatia, Japan and Australia, complemented by smaller manufacturing operations in other countries such as Hong Kong and Dubai and smaller "kitchen" style operations in many other territories. Lush employs around 13,343 people through the Lush Group (Lush Group Employees: Retail, Digital, Manufacturing and Support, not including Partners) — even more around peak times like Christmas when we recruit seasonal staff. We also operate 19 Lush Spas in select locations across the U.K., Spain, U.A.E., Canada, the U.S., Japan and Korea.

We are very proud to offer a range of fresh, handmade cosmetic products which are all invented and manufactured in-house. They are then sold through our retail shops, our digital channels and select third-party digital platforms. This ensures we can be confident that our beliefs and ethics are carried through at all stages.

Lush prides itself on its innovation and creativity, and therefore the number of products we produce is constantly evolving. We sold an average of 1,900 product lines globally within FY25. This includes all year-round products, collaborations and seasonal exclusives.

The Lush business is run in accordance with a set of founding ethical principles written by our founders at the very beginning of Lush’s life, commonly known as our “We Believe” statement. These principles underpin everything we do and run through every vein of our business.

Lush further sets out its core values or principles in the Lush Ethical Charter.

As mentioned in our 2019/2020 statement, we have adopted the Stronger Together Framework for actioning our response to modern slavery. You can see our progress against this below.

Our Business and Our Supply Networks

Lush products are for sale in our shops, on our website and through our carefully selected third party partners. They are invented in-house and manufactured by our own factories (apart from our Knot Wraps, candles, bags, books, records and lifestyle products which are all manufactured in carefully-selected external supplier factories). The Creative Buying team manages the supply networks of our product and raw material suppliers who are selected based on ethical, sustainability and commercial criteria, and are supported by the integrated Supply Chain Impact team.

Product supply networks are complex, involving a number of different processes; and Lush’s supply networks are no exception. Although we try wherever possible to buy as direct from source as we can, most supply networks are made up of several tiers stretching over numerous countries. We source our materials from close to 1493 suppliers (across our raw materials, packaging, sundries and indirect spend) from about 116 countries globally, with a combined global buying spend of £98.2m/$132.2m U.S.D.

We have many supply networks that contribute to the operation of our business and, as the Lush business continues to grow in size, so do our supply networks. This year we have updated our purchase figures to include all of our global spend, not just for our ingredients.

We continue mapping our supply network beyond Tier 1. The level of visibility we currently have (5172 Tier 2, 1301 Tier 3, 1033 Tier 4 suppliers) is highlighting that we still have work to do when it comes to mapping our supply chain and the percent of full traceability has now been added as a recurring KPI.

We are dedicated to sourcing and developing high-quality, ethical ingredients through a resilient global network, and growing our own materials through agricultural projects and direct partnerships worldwide. From our early experiences with adulterated essential oils, we learned how crucial it is to understand each material fully — from the people involved in its supply chain to the local impacts of its production — so we can ensure exceptional quality without exploitation at any stage. As a business, we realized that we could have both a positive and negative impact through our business operations. Due to this, we have aspired to maximize the benefit of our actions, relying on positive and open relationships with our suppliers and producers to find a path to a truly ethical and sustainable business that will last into the future.

Our vision is that every ingredient we buy is contributing to a positive future. We are already building a web of likeminded pioneers who wish to become part of the answer to the problems we all see every day. Through the ingredients we buy and through the people we meet and partner with, we are finding some of these answers come through reciprocal trade. That means finding ways in which we can grow, produce, manufacture and ship our goods that are truly sustainable. In fact we have ceased to aim for just sustainable, but wish to reach beyond that to be regenerative — aiming to make sure that our purchases put back more into the soil, the community and the natural world than they take out, and at the same time provide profit and a viable business for all of us. We want to leave the world lusher than we found it.

Within the business we have specific roles responsible for identifying, assessing, and responding to modern slavery risks (Social Impact Leads) and a governance structure with senior-level oversight (Director).

Our Commitment – Policies and Processes

We have several policies in place that help us to enforce the standards set to mitigate the risk of Modern Slavery and also encourage disclosure of any such practices within our business and throughout our supply networks. These policies are reviewed, communicated to and acknowledged by new and existing suppliers and also communicated to all Lush business partners. Suppliers are also reminded of our policies via every purchase order they accept.

As a minimum requirement, we ask all of our suppliers to acknowledge and comply with the following policies/documents (in addition to our strict Non-Animal Testing Policy and declaration):

Our Anti-Slavery and Human Trafficking Policy

This policy, last updated in June 2024, clearly defines Lush’s position on Modern Slavery and sets the minimum standards that we expect all our suppliers to follow to ensure the fair treatment and well-being of all workers within our supply network.

This policy applies to everyone working for us or on our behalf in any capacity, including employees, directors, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, suppliers, third-party representatives and business partners. Anyone who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

Our Modern Slavery Remediation Policy

In the 2020/2021 financial year, we publicly published our Modern Slavery Remediation Policy. Lush recognizes the responsibility that we have as a business, but also the responsibility we share with our suppliers, to provide remedy to victims of slavery. Successful remediation is not easy to achieve and requires a victim-led, consultative and multi-stakeholder approach.

The Lush remediation policy is drawn from best-practice guidance on remediation and builds on the requirements of International Labour Organization Conventions, Protocols, Recommendations and Instruments such as the Declaration on Fundamental Principles and Rights at Work and the Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy, the U.N. Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, and the United Nations Guiding Principles on Business and Human Rights. The policy is intended to provide a practical framework for us as a business to apply remedy should we encounter victims of slavery in our business or in our supply chains.

Our People Care, Earth Care and Fair Share Buying Policy

These buying policies, last updated in May 2025, are available in six languages and consist of legal requirements, non-negotiable standards and progressive standards expected by Lush. The People Care section covers topics such as recruitment practices (worker-paid recruitment fees, freedom of movement), freedom of association and collective bargaining, prohibition of compulsory overtime, prohibition of child labor (specific reference beyond general anti-slavery), and prohibiting confiscation of worker ID documents.

As noted in Section 4.0, “Legal Obligations,” of this policy, we require suppliers to adhere to the U.K. Modern Slavery Act (or any other global legislation designed to combat modern slavery and offences relating to trafficking and slavery), as well as all relevant Lush policies found here:

https://weare.lush.com/lush-life/our-policies

Suppliers will be notified of new policies through buyer communication, email or our supplier management system. Further, we require suppliers to have systems in place to support their approach to compliance with relevant legislation, and expect our suppliers to be:

• Aware of the risks of bribery and corruption, modern slavery, and other potential risks that may prevent compliance with relevant legal obligations.
• Committed to communicating awareness to employees and business partners.
• In compliance with all of the legal requirements and legislation for the country in which their business operates.

We also include the “employer pays” principle in our buying policy document. The People Care, Earth Care and Fair Share Buying Policy helps us to ensure that our supply networks match our core values.

Our Whistleblowing Policy

This policy, last updated in October 2024, enables employees and anyone else to report any illegal or unethical malpractice that might be witnessed within our business or supply networks while remaining anonymous. By encouraging a whistleblowing culture, we can continue to promote transparency and empower our staff and those in our supply networks to help monitor and maintain our high ethical standards in every corner of the Lush business. This is a global policy that must be adhered to by all Lush businesses and made available to all Lush employees.

In line with the requirements of the E.U. Whistleblowing Directive, we have fully implemented a new system during 2023/24 for whistleblowing that makes it easier for anyone within the business or in our supply network to raise concerns confidentially via multiple channels and in their preferred language.

We work with a confidential third-party global reporting service, AAB People (formerly SeeHearSpeakUp). AAB People specialize in implementing effective whistleblowing solutions for businesses in a safe, secure and supportive environment to encourage whistleblowers to speak up and be heard.

Available 24 hours a day, 365 days a year, AAB People provides an independent confidential hotline available in 217 languages and an online reporting tool to ensure that any malpractice concerns are brought to our attention in a secure and confidential manner. You can also contact AAB People anonymously if you would prefer.

To make a whistleblowing report, please visit the web portal or contact the hotline on 0800 026 0466.

Breaches of any of the above policies are not taken lightly. Where there is an opportunity to influence change, we will work hard with our suppliers to do so, but we will not hesitate to cease trade with any organization where breaches of our policies are severe.

Assess – Understanding the Risks

Assessments

The risk of modern slavery lies everywhere; in all tiers of a company's supply network and within their own operations. For Lush, one of the sources identified as being high risk was mica, which is why we have moved away from sourcing natural mica and consequently made the decision to go completely natural mica-free as of January 2018.

During 2024/25 we have again conducted our annual salient human rights risk assessment of all our ingredients and packaging suppliers, taking into account the sourcing countries and prevalent risks, commodities and our spend and risk to the business.

This assessment continues to show that materials that are mined or are coming from agricultural supply chains (especially fragrance materials) are at high risk in terms of human rights abuses. Carrying out this assessment allowed us to prioritize which suppliers and countries to concentrate on and prioritize for a visit. In total, we have carried out 58 supplier visits between July 2024 and June 2025, and conducted six human rights impact assessments of high-risk supply chains in Egypt, the Dominican Republic, Pakistan, and India. For these six assessments, we enlisted the help of independent third parties, and also engaged directly with workers on the ground, as well as with relevant NGOs and industry initiatives to gain a deeper understanding of local conditions and best practices.

For further information on the steps we have taken since carrying out the assessments, please refer to the “Act – Taking Action” section below.

Key risk identified – Child Labor in Agricultural Supply Chains

As mentioned above, our annual salient human rights risk assessment identified agricultural supply chains as high-risk for human rights abuses, particularly forced labor and child labor. Agricultural production relies heavily on laborers and seasonal migrants, especially during short harvest periods.

In line with the Definition of Child Labor established under the U.N. Convention on the Rights of the Child, we define a child as anyone under 18. Child labor refers to work that:

• Deprives children of childhood, potential, and dignity
• Harms physical and mental development
• Interferes with compulsory schooling
• Involves hazardous conditions (minimum age 18 for hazardous work)

According to the ILO, 60% of all child laborers aged 5-17 work in agriculture (farming, fishing, forestry, livestock). Most (67.5%) are unpaid family members, with an even higher percentage in agriculture.

Root Causes

• Poverty is the primary driver
• Limited access to quality education
• Inadequate agricultural technology
• Traditional attitudes toward children's work
• Lack of childcare alternatives (children brought to fields)
• Economic vulnerability of agricultural communities

Children of seasonal migrant workers face elevated risks including disrupted education, early school dropout, hazardous working conditions, and limited social development.

Not all children's participation in agriculture constitutes child labor. Age-appropriate, non-hazardous tasks that don't interfere with schooling can be part of normal rural development and intergenerational skill transfer.

We are collaborating with affected suppliers and independent human rights experts to address these issues on the ground. Please find a summary of our assessment findings below.

Egypt

Impactt, a consultancy that specializes in ethical trade and human rights, traveled together with the Lush team to carry out a social impact assessment of Lush’s jasmine supply chain in August 2023. We wanted to understand the human rights risks faced by workers in the supply network in more detail and gain a better understanding of how the formal supply chain channels function, and the relationships and dynamics between different actors. The assessments highlighted that despite Egypt having a well-established legal framework, iterative reforms to the law to address ratified international conventions, as well as diversified national policies relating to Child Labor practices, deep-rooted socio-cultural norms and, at times, household needs mean that many children are still engaged in agricultural activities.

Children support their families during the production and picking season, more so during the school holidays, but during term time as well. This goes against the national legislation and Lush’s People Care, Earth Care and Fair Share policy, especially as children are working during nighttime hours when jasmine is typically picked. This is known to be a common challenge across many agricultural sectors in Egypt.

While at the national level there are many initiatives being implemented to address this challenge — both by the government and by donors and NGOs — it is a very hard and complex challenge to address. One critical risk is, of course, non-compliance with the national legislation; however other risks include children being exposed to hazardous conditions and/or safety and security risks and their engagement in the labor market having a negative impact on their education.

In some instances, households and/or producers and pickers are becoming increasingly reliant on family members, including children, to support the harvest, especially during the peak. This is both due to the high costs of labor in parallel to the limited availability of workers willing to work for the income levels currently offered in the market.

During the 2025 financial year we have completed phase two of the child labor remediation program. Kick off of phase two was in June and concluded with a visit by Impactt in September 2025. More details of this work can be found in the “Act – Taking Action” section further below.

Dominican Republic

Cocoa is one of our key ingredients here at Lush. In order to minimize the risk of human rights abuses in the cocoa supply network, we work with suppliers who are taking active steps to mitigate these risks — we only buy fair trade and organic cocoa butter which adds a layer of protection, but in April 2024, we went a step further and conducted our own independent human rights assessment of one of our sourcing countries. This was followed up in April 2025 to gather even more insight into the workings at farm level.

This human rights risk assessment provided us with insight into the supply network in the Dominican Republic, the actors and processors involved, and any potential risks. Fortunately, no child labor or forced labor was discovered during this assessment but we are working with the supplier to address the other identified concerns.

India

For our peppermint supply chain in India we worked closely with human rights and Environmental, Social, and Governance (ESG) experts from the Re-Assurance Network. The objective of the assessment here was for Lush to gain greater transparency into its peppermint supply chain in Uttar Pradesh, to understand how it is structured and the associated human rights risks from supplier down to farm level. The assessments of two of our peppermint suppliers were completed during June and July 2024. During June 2025, we completed the Human Rights Impact Assessment with our third and final peppermint supplier in the region. The assessments highlighted many common themes along the supply chain:

 • Opaque supply chain with little traceability • Absence of management systems for procurement and employment • Farmers and farm workers effective debt bondage — with farmers and workers taking advances. Farmers must pay interest or sell their crop at a reduced rate creating a cycle of poverty that needs to be broken. • Use of child labor (only evidenced outside of school hours) • Unsafe working and poor living conditions — lack of health and safety management and access to potable drinking water not ensured or toilets provided • Pay below legal minimum wage and inconsistent earning for farmers and workers — female workers paid less than men, no agreed minimum value, price dictated by buyers (distillation units and peppermint oil producers) • No experience of labor resource and human rights management

Further to the above the assessment also highlighted several external contributing factors:

 • The market is subject to external influences beyond its control, which can substantially affect the extent and severity of the repercussions on workers and farmers. • Legality of children working on family farms and benefits of additional income • Caste system • Low literacy levels among farmers and workers make written agreements challenging • Water and sanitation infrastructure not in place • Climate change impacts and water sensitivity exacerbated by a water-intensive crop

Bulgaria

Having established the rose oil industry as a high risk one for human rights abuses, we have continued our work to understand the complexities of all our current rose supply networks. During May 2025, we again visited our supplier of rose water in Bulgaria and this year in addition also our supplier of rose oil. Our visit in 2024 highlighted the following concerns:

• Child labor — children, especially from the Roma community being involved in the rose harvest

• Working conditions — insufficient access to drinking water and toilets

• Contracts — lack of official documentation, contracts for pickers, even though these are enforced by the Bulgarian Government, contracts do not seem controlled and do not reflect the true employment relationship. Due to the lack of paperwork and official contracts we are unable to confidentially verify fair pay for all pickers.

• Discrimination/segregation of Roma community

Pakistan

Our rose absolute supply chain in Pakistan came up high on our Salient Human and Environmental Risks Assessment which is why we carried out a human rights risk assessment in March 2025. The assessment of the farms and processing units of our joint venture found no evidence or indicators of child labor, forced labor, discrimination, or modern slavery. The assessor found no concerns regarding restriction of movement, violence, intimidation or threats, retention of identity documents, or debt bondage. The assessment covered the production facility of our joint venture and 20 farms. Some of the areas of improvement identified were lack of contracts between supply chain actors, wages paid, records keeping, incorrect overtime payments, health and safety protocols at the production site and at farm level.

Palm Oil

When we look at our historic reporting, FY25 palm derivative use is down 16.9% from FY22 data, but up 8% on FY24. As we report on our use by volume, this increase should be viewed in the context of a year where we saw sales growth, and changes to the product sales mix. When we look at our portfolio of ingredients that would generally be palm-based, we now have a split of 52.08% palm-free alternatives vs 47.97% palm derived materials. A full review of the suppliers that supply us with 80% of our palm derived volumes confirmed that they are not able to offer certified options to provide increased traceability and transparency of their feedstocks. Roundtable on Sustainable Palm Oil (RSPO) segregated and Identity Protected versions are not currently available (the certification options that would offer the highest level of transparency). The announcement of the E.U. Deforestation Regulation has seen many of our suppliers focusing on becoming EUDR ready. Under the new regulation, suppliers placing selected products on the E.U. market will have a legal obligation to prove that there has been no deforestation since 2020 across their palm supply chains. We are hoping the new EUDR legislation will enable us to gain further transparency from the manufacturers of our palm derivative ingredients, regarding their supply chains. We continue to expand our palm due diligence tracker to enable us to gather publicly available ESG data relating to our palm derivative suppliers. The full details around our palm oil derivatives can be found in our 2025 Palm Report.

Improving Traceability

Lush champions traceability within its supply network, and it is an important part of every material that we buy here at Lush. We are fortunate to have many long-lasting relationships with our suppliers, from whom we are able to buy directly. 

When we started formally monitoring our traceability levels back in 2022, we had around 700 suppliers in our supplier management system to enable us to focus on the highest spend materials. As we have developed our strategy, we understand that modern slavery exists in all supply networks, and therefore needed to ensure that all of our materials were included — not just raw ingredients.

We now have over 1400 suppliers registered in the system for all our materials and are working on improving transparency across all supply networks. Key performance indicators (KPIs) relating to traceability have been added to the “Monitoring” section of this statement.

Act - Taking Action

Steps Lush has taken since completing the above mentioned human rights risk assessments

Egypt - Jasmine

To build on the work from previous years, Impactt conducted a three-day follow-up visit in September 2025 as part of Phase 2 of the child labor remediation program. The initial diagnostic work, conducted by Impactt in 2023, had revealed several challenges in our suppliers’ own operations, including child labor risks, quality and traceability issues, market volatility, lack of grievance channels, and concerns over working conditions. 

In 2024, Lush and Impactt began working with our supplier to manage child labor risks in the company's smallholder supply chain and develop solutions. The objective was to understand the root causes and impacts, and to build solutions through stakeholder consultation. The purpose of the work carried out this year and the visit in September is to assess the implementation of previous recommendations, validate reported progress, and provide practical recommendations for continuous improvement. While few issues are fully closed, the progress noted against the majority of assessment topics is substantial and will make a meaningful difference in the lives of workers and smallholders.

Significant progress has been made in improving labor practices, worker welfare, and supply chain management. Within its own operations, our supplier has fully resolved key issues by implementing age verification, appointing a worker representative, eliminating the need for workers to work overtime but also ensuring employees understand how compensation for overtime is calculated correctly. Partially resolved actions include signing formal contracts for all permanent staff, establishing an accessible grievance mechanism, improving health and safety measures, and providing essential facilities such as toilets, drinking water, and personal protective equipment (PPE). In the supply chain, child labor prevention is being successfully enforced with a significant reduction in children found, health services and education access expanded, and worker awareness strengthened. Monitoring takes place to ensure the risk of child labor continues to reduce. Ongoing improvements focus on fairer pricing to close living income gaps, women’s empowerment and youth initiatives, enhanced training and monitoring on human rights and safety, PPE distribution, and the extension of grievance mechanisms and ethical commitments across the supply chain.

India - Peppermint

There are several steps we need to take in order to help to break the poverty cycle in which peppermint farmers are currently locked, so we are closely working with our suppliers of peppermint on:

• Traceability — Knowing the chain, understanding the routes and visibility of payments and agreements.
• Consistent and improved yield — Improving the value of each harvest to provide higher incomes for farmers and workers.
• Reciprocity — Establishing commercial relationships that provide benefits to all parties through the supply chain.

To improve traceability and transparency we will continue to work with our suppliers to prioritize recordkeeping of crop source for the first season and then look to identify core farmers and identify cooperative collectors and farmer producers organizations. To improve yield we will review current agricultural practices and improve the support and guidance currently offered. To make the system fairer we will work with our suppliers to maintain records of payments and earnings. We will continue to work to understand commercial arrangements such as margins and payment schedules with each supply route and work towards a minimum guaranteed price for the crop.

We are keen to collaborate with other stakeholders on the issues identified in this supply chain.

Bulgaria, Pakistan, Türkiye - Rose water and rose oil

Following our findings in our Bulgarian rose water supply chain in 2024 we are working closely with our supplier on strengthening the Human Rights Due Diligence processes. A list of immediate actions to be taken was shared with our supplier. The actions that could be addressed immediately and verified virtually have been actioned. The remaining non conformities were followed up on during an in person visit in May 2025. One change that took place in our rose water supply chain is that we are now buying rose water exclusively made from roses picked on our suppliers own farms rather than the much bigger network of external farms. This makes remediation and implementation of corrective action much easier.

We have further assessed the Bulgarian supply chain during the 2025 harvest season and also visited our supplier of Bulgarian rose oil. The assessment identified several labor and human rights risks within farm operations. Instances of children being brought to the farm highlight an ongoing risk of child labor, underscoring the need for robust prevention measures, such as vehicle checks before field entry and clear procedures for managing such cases. Recruitment and payment structures also pose concerns. Supervisors and drivers currently receive a percentage of workers’ earnings, which may cause unfair deductions or potential exploitation. Furthermore, pickers are typically paid in cash via intermediaries, creating limited wage transparency and accountability. A lack of consistent communication regarding pay rates per kilogram further contributes to confusion among workers and potential pay discrepancies. Clear display of rates at farms or weighing stations, direct payment to workers, and transparent clarification that drivers are already compensated separately would strengthen fair pay practices and reduce the risk of exploitation. 

Other actions that need to be taken are: 

• Strengthen child labor prevention
• Formalize agreements with supervisors and drivers
• Improve wage transparency
• Communicate pay rates clearly
• Promote awareness and accountability.   

To complete the picture of our rose supply chains we have also conducted a human rights impact assessment in Pakistan. The assessment of the farms and processing units found no evidence or indicators of child labor, forced labor, discrimination, or modern slavery. The assessor found no concerns regarding restriction of movement, violence, intimidation or threats, retention of identity documents, or debt bondage. The assessment covered the production facility of our joint venture and 20 farms. Some of the areas of improvement identified were lack of contracts between supply chain actors, wages paid, records keeping, incorrect overtime payments, health and safety protocols at the production site and at farm level. We are working on remediating the issues identified.  

In addition to the above Lush also continues to participate in a joint project, “Harvesting the Future”, to promote and improve working and living conditions of seasonal agricultural workers in Türkiye. For further information please see the Fair Labor Association website.  

Training and Raising Awareness 

Internal Training 

At Lush, we are committed to ensuring that all employees have an active and engaged understanding of the risks of modern slavery. Our modern slavery training program began in 2018 and has since been expanded across a wide range of departments and regions across our global business. 

Training has been delivered through a combination of team-specific sessions and virtual workshops, with recordings made available to maximize accessibility. This approach equips staff to recognize potential warning signs and take appropriate action if a supplier appears to fall below our expected standards.   

In recent years, we have provided additional training to support teams, global colleagues, and buying teams to strengthen understanding of modern slavery risks within their areas of work. 

We have also hosted Social Auditing sessions for our buying colleagues and wider support teams to develop skills in Social Systems Auditing. 

These sessions covered: 

• Understanding the range of social and ethical issues that organizations and auditors may face, including conventions, codes of conduct, and industry initiatives. 
• Planning, conducting, reporting, and following up on social system audits in line with ISO 19011. 
• Interpreting SA 8000 requirements during audits. 

These sessions were delivered in both our U.K. and North America offices, with global colleagues participating.  

Additionally, our buying teams have undertaken digital training to enhance their awareness of risks within their own supply networks. This has included topics such as Effective Due Diligence for Addressing Child Labor Risks in the U.S., which remains an area of ongoing monitoring. Looking ahead, in 2025 we developed a new in-house Modern Slavery Awareness Training, which will be rolled out to all Lush colleagues globally in 2026. 

Talking about Modern Slavery  

Communicating and keeping Modern Slavery at the forefront of people’s minds is key to making sure that we are constantly doing everything we can to try and eradicate this horrendous practice. We do this through a variety of channels which are accessible internally, to our supply network and publicly, too. 

Our Anti-slavery and Human Trafficking policy and Modern Slavery statements are published on our website where staff, suppliers, customers and anyone with an interest can read about the risks to our business and the steps we are taking to combat modern slavery.  

We also have also created an internal document called the Modern Slavery Handbook (last updated in November 2024), which provides resources and materials created by Lush, and information provided by external organizations which campaign to eradicate modern slavery on a global scale. This is available internally, and is distributed in a follow up email to anyone who completes our online training. The document is comprehensive and covers topics such as: What is Modern Slavery, Our Obligations and Policies, Spotting the Signs, Reporting and Incident, and several external resources. It is also shared as part of our immersion sessions for new employees.  

Lush has long prioritized raising awareness of modern slavery and embedding ethical practices across our business and supply chains. 

Previous initiatives include highlighting the issue in our employee magazine, Lush Insider, and developing internal referral procedures to support colleagues or customers who may be affected. 

To engage suppliers, we have explored interactive training approaches, including virtual supplier conferences co-hosted with Stronger Together, which provided guidance on identifying risks, understanding global and U.K. responses, and Lush’s policy expectations. Recordings of these sessions were made widely accessible to suppliers unable to attend. 

Beyond training, Lush has actively participated in public discussions on modern slavery, demonstrating our ongoing commitment to collaboration and sector-wide learning. 

These historical initiatives form the foundation of our current approach and continue to inform how we raise awareness, train staff and suppliers, and address modern slavery risks across our operations. 

Operational Performance Assessment 

Lush has previously used the Stronger Together Organisational Performance Assessment to self-assess how well we tackle modern slavery and hidden labor exploitation as a business (action taken during FY 19/20). The assessment was delivered by a trained and approved business and human rights expert consultant and provided independent verification of our company’s progress in tackling modern slavery.  

The OPA has been developed to support companies to evaluate their progress in tackling modern slavery and to inform their next steps to improve the scope and effectiveness of their programs. The OPA analyses gaps, reports on strengths and provides detailed recommendations and action plans to support a business to make further organizational improvement.  

 The framework covers six steps:  

• Commit — Make a public commitment to tackle modern slavery  
• Assess — Understand modern slavery risks in your business and supply networks  
• Act — Take action to deal with identified risks  
• Remedy — Provide a solution for victims of slavery  
• Monitor — Monitor progress  
• Communicate — Tell people what you have done  

We have used the output of this assessment to form a framework for this report, but also to guide us with a list of areas we wish to strengthen. We had another assessment planned for  FY 23/24 but this has been postponed. When we carry out the next OPA we plan to extend the assessment across all of the Lush manufacturing operations. 

Remedy - Provide a solution for victims of slavery  

We have two main channels through which we would receive potential violations or incidents for concern; via the whistleblowing hotline (https://fileaconcern.org/lush), or during our own investigations of our supply network. 

As part of our aforementioned remediation policy, we have identified a structure for dealing with these incidents. 

The Lush process for responding to violations will be to: 

• Conduct an initial assessment of the allegations to ensure that there is sufficient information to understand the exploitation discovered and remedy it. 
• Ascertain if a supplier or labor provider is implicated. 
• Report the allegations to relevant authorities. 
• Capture evidence about the violations, using an independent third party if necessary.  
• Gather information from those affected. 
• Take immediate steps to correct the situation for the worker, which will need to be tailored to their individual circumstances. This could include provision such as housing support, legal assistance, medical care or psychological support.  
• Compensate the victim or restore their situation to before their ordeal took place, including for those found to be a victim of modern slavery within the Lush network, internal colleagues or supply chain. 

This could be in the form of: 

• Reimbursement of recruitment fees or illegal deposits 
• Compensation for lost wages or illegal wage deductions  
• Assistance with repatriation, if desired.  
• Where possible, contribute to programs and projects aimed at providing victim support. 
• Work with local authorities and competent local organizations to provide assistance (on the express consent of the victim). 
• Review progress over a suitable time period and verify that progress with local authorities and local organizations. 
• Document remedial steps taken (see Remediation Reporting Tool). 
• Build learnings into remediation procedures and operational procedures to prevent re-occurrence.  

In line with the E.U. Whistleblowing Directive, we have fully implemented a comprehensive whistleblowing system. It provides confidential, multi-channel reporting for anyone within the business or our supply network and enables us to direct concerns to the appropriate stakeholders, ensuring they are handled efficiently and effectively.  

Between July 2024 and June 2025 we have received 16 reports through our whistleblowing channels and none of them related to modern slavery concerns.  

Compared to last year the numbers of reports received have gone up which is a reassuring sign that the system is working and being used. 

We are now working on rolling the system out further globally and within our supply networks.  

Monitor - Monitoring Our Progress  

{NOTE: BAR CHART GOES HERE}

Moving from U.K. reporting to a Global structure has allowed us to monitor our supply network much more comprehensively. This year (FY2025), we have also added all indirect suppliers to our supplier management system. This has resulted in a drop off in the percent of materials that are fully traceable, but allows us to monitor the progress more holistically going forward. 

While we continue to track and report on our high-risk suppliers and any non-conformances found internally, the unpredictable combination of political, social, and economic risks, combined with shifts in our global spend profile, results in a constantly evolving risk landscape. This fluidity accentuates the need for a continuous and dynamic risk management system, moving beyond a reliance on fixed, snapshot figures, so that we can understand the improvements over time.  

In light of these, we have updated our KPIs so that they are reflective of our entire supply network — our new set of KPIs, which we will report on every year are below:

KPI

Result FY23/24

Result FY24/25

Number of suppliers included in scope

1223

1493

Since last year, we have included all our spend in our reporting, not just ingredients, which has resulted in a large increase in the number of suppliers.

% of suppliers engaged (registered) with our supplier traceability system

84.10%

80.72%

Figures taken from our supplier management system.

% of Global FY25 Spend mapped past Tier 1

Not Available

30.39%

Figures taken from our supplier management system of those who have mapped to Tier 2 or beyond and compared to total yearly spend.

% of Global FY25 Spend mapped to Source / Farm Level

Not Available

13.88%

Figures taken from our supplier management system of those who have mapped to farm or end of chain and compared to total yearly spend.

% of suppliers identified as high risk that have been involved in assessment / remediation projects / Lush Visits

Not Available

22%

This is made up of third-party human rights assessments, follow-up projects, and Lush buyer

Communicate - Communicating and Highlighting Modern Slavery 

It’s been said that Lush is like a campaigning organization fronted by a soap shop. We are active and vocal about the issues that we care about, and use our shop windows and website as a way to highlight them.  

Historically, we have hosted campaigns in partnership with After Exploitation, calling on Part five of the Nationality and Borders Bill to be scrapped. 

Each of Lush’s 101 storefronts across the U.K. carried the slogan: “Don’t let the Government rip up support for modern slavery survivors”, alongside a QR code and URL, so that customers could quickly and easily take part in the Scrap Part 5 action. 

As in previous years, we marked Anti-slavery Day in October 2025 by raising awareness of modern slavery and its prevalence via presentations in our U.K. offices and manufacturing sites. As part of our company-wide ongoing commitment towards eradicating modern slavery and forced labor, we encouraged everyone to read the shared information to:

1. Understand/remind themselves of what modern slavery is 
2. Learn about recent modern slavery cases 
3. Know how to spot the signs  
4. Familiarize themselves with what to do if a case of modern slavery is suspected  

Further to this we also shared an animation that was created by Stronger Together in partnership with Migrant Help, to support businesses in raising awareness of the signs of labor exploitation throughout their operations and supply chains. 

Supporting Human Rights Charities  

At Lush, we like to look after those who look after others. We are committed to supporting small, grassroots groups and other non-profit human rights organizations.

Globally we made 345 donations to Human Rights groups from our Charity Pot sales in FY2025 (including groups tackling slavery and human trafficking) — £1.5 million was donated in total to these groups. In the U.K. alone we have made 101 of these donations totalling £182K. In North America, we have made donations valuing $1,873,441.91 CAD. 

Via other funds (Product Campaigns) during FY 24/25 we have donated £1.5 million to Human Rights groups. 

Requirements  

The Lush board of directors have overall responsibility for ensuring Lush's compliance with the Modern Slavery Act and that all those under our control comply with it. Management at all levels are responsible for ensuring those reporting to them understand the issue of modern slavery and comply with this policy. 

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 30/06/2026. It has been issued on behalf of the Lush Group, approved by the Lush board of directors and covers all U.K. Lush entities including Lush Ltd, Lush Retail Ltd, Lush Manufacturing Ltd and Lush Cosmetics Ltd. 

Signed by:  

Date:  

I have the authority to bind Lush Ltd 

Finding Help in Canada and Beyond 

If you or someone you know is being or has been exploited, or if you are unsure if someone is in need of help, assistance and advice is available:  

For life-threatening emergencies: Call 911 for the police. 

Canadian Human Trafficking Hotline: Call 1-833-900-1010 or contact them via their online form. The helpline is available 24/7, offers services in over 200 languages, and can be used to report a tip, access support, or gather information. 

Victim Services (Provincial/Territorial): Most provinces offer dedicated support. You can find your local branch via the Policy Centre for Victim Issues (PCVI). 

Crime Stoppers: To report anonymously, call 1-800-222-TIPS (8477) or submit a tip online via canadiancrimestoppers.org. 

Migrant Worker Support (Temporary Foreign Worker Program): If you are a migrant worker being mistreated or exploited, call the Service 

Canada tip line at 1-866-602-9448. 

The Salvation Army (Canada and Bermuda): They provide specialized support for survivors of human trafficking. Contact their national headquarters or local branches for confidential assistance. 

Canadian Red Cross: Call 1-800-418-1111 for general support and information on humanitarian assistance. 

Identifying Labor Exploitation: To support businesses in raising awareness, use the Public Safety Canada toolkit to help spot signs of forced labor throughout operations and supply chains. 

If you suspect someone is a victim of human trafficking, forced labor, or worker exploitation, report it immediately: 

The Police: Call 911 for emergencies or your local police non-emergency line. 

Crime Stoppers: 1-800-222-8477 

Canadian Human Trafficking Hotline: 1-833-900-1010 

RCMP Human Trafficking National Coordination Centre: 1-833-900-1010 (Integrated with the national hotline)  

Employment and Social Development Canada (ESDC): Report employer abuse directly to the government at 1-866-602-9448. 

Rowena Bird

May 28th, 2026