2018 Statement - Combating Modern Slavery
“Modern Slavery” is the phrase used to describe the crimes of human trafficking, slavery and slavery like practices such as servitude, forced labour, forced or servile marriage, the sale and exploitation of children, and debt bondage.
A common thread runs through all of these offences: they involve one person depriving another person of their liberty, in order to exploit them for personal or commercial gain.
Where things stand today
More than 40 million people around the world, including in the UK, are victims of modern slavery and this figure continues to grow as global migration reaches an all-time high. The Lush group take a zero-tolerance approach to modern slavery of any kind and are committed to helping end these practices in any way that we can. People are at the heart of everything we do and we care about the welfare of everyone in our supply chains.
To combat the risks of modern slavery and human trafficking in our own business and in our supply chains, we have taken (and continue to take) steps that we are proud to share with you in this statement.
This year, we have been focusing heavily on our raw material supply chains and have raised the bar on our standards and enforcement measures ensuring our suppliers are consistently up to the mark.
Lush is a UK cosmetics brand, originally founded in 1995, now trading with 933 retail stores in 49 countries employing over 18,000 employees.
We are very proud to offer a range of over 300 fresh, handmade, cosmetic products which are manufactured at our 7 manufacturing sites across the world and sold through our retail shops and digital channels.
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 all that we do and run through every vein of our business.
Our supply chains
We have many supply chains that contribute to the operation of our business and as the Lush business continues to grow in size, so do our supply chains.
For example, our raw material supply chains are made up of a network of approximately 330 suppliers all over the world. This number continues to evolve as we discover new materials and meet new suppliers.
We are committed to sourcing and developing top quality, ethical materials for our products through a resilient global network. We also grow materials ourselves via agricultural projects and direct partnerships around the world.
From the early days of buying, we learned the hard way that the adulteration of our essential oils was down to how we treated our suppliers and the relationships we formed.. As a business, we realised that we could have both a positive and negative impact through our business operations. Since then, we have aspired to maximise 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 each and every ingredient we purchase is helping contribute to a positive future.
We are already building a web of like minded pioneers who wish to become part of the answer to the problems we all see everyday. Through the ingredients we buy and through the people we meet and partner with, we are finding that 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. And not just sustainable but beyond that - regenerative. That they put back more into the soil, to the community and the natural world than they take and at the same time provide profit and a viable business for all of us.
Policies and Practices
We have several policies in place that help us to enforce the standards set to prevent the risk of Modern Slavery in our supply chains and also encourage disclosure of any such practices within our business and throughout our supply chains. These policies are reviewed, sent out and acknowledged by new and existing suppliers annually.
- Our Anti-Slavery & Human Trafficking Policy
This policy clearly defines Lush’s position on Modern Slavery and sets the minimum standards that we expect all of our suppliers to comply with, to ensure the fair treatment and well-being of all workers in our supply chains.
- Our People Care, Earth Care and Fair Share Buying Policy
These buying policies consist of non-negotiable standards, legal requirements and progressive standards. The policies help us to ensure that our supply chain matches our core values including the Anti-Slavery & Human Trafficking policy.
- Our Buying Policy Questionnaire
The purpose of this online survey is to open a dialogue and to gather information that will help Lush identify positive practices in our supply chains and focus on what support might be needed. This will be sent out annually for all direct suppliers to complete.
- Our Whistleblowing Policy
Encourages our employees and anyone in our supply chains to report concerns of illegal or unethical malpractice within our business or supply chains. The anonymity of whistleblowers and anyone raising concerns or bringing to our attention practices that do not comply with our policies is protected. Our central whistleblowing email address ‘[email protected]’ is monitored by our Compliance Officer and whistleblowing cases are investigated and resolved in the shortest time possible.
Breaches to these policies are not taken lightly. Where there is opportunity to influence change we will work hard with our suppliers to do so. The additional information from our policy questionnaire enables us to benchmark suppliers and practices to keep tracking progress against each of the areas covered by our buying policy.
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. Our Compliance Officer has day-to-day responsibility for implementing this policy, monitoring its use and dealing with any queries about 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 year, we have been working hard to develop a system that will enable us to work more efficiently to monitor and work with our raw material suppliers to ensure we are meeting the highest ethical standards possible throughout our supply chain.
This has seen the introduction of:
- Our People Care, Earth Care and Fair Share Buying Policy & Declaration
- A digital Policy Questionnaire which is linked to a data analysis software
- Improved Whistleblowing Policy
- Country and industry risk mapping
Where possible, we work directly with suppliers and producers, but long distance relationships take work which is why regular visits to our suppliers to see their operations are important to us. Just as important is meeting our suppliers here in the UK.
There are many ways that a company can ensure that their internal practices are transparent and honest – and one of the best ways is to allow oversight of these internal practices by outside agencies. There are several areas of our business where external bodies exist that can check and verify our work. Expert eyes from outside the company can give reassurance and confirmation to customers that we are doing the things we say in our written policies and give guidance to us for future developments and improvements.
We have an internal team that works hard to look after our policies. They make sure the policies are implemented in practice on a daily basis. The team is spread over all of Lush’s manufacturing countries (UK, North America, Brazil, Croatia, Germany, Japan and Australia) and work closely with our global buying teams. They look into all new suppliers to ensure everyone in our supply chain, that we source from and give our money to, is in line with our non-animal testing and other buying policies.
Training and Raising Awareness
A lot of people work for Lush. All of them need to have an active and engaged understanding of the risks of modern slavery to our business. This year, we have started to roll out training to key teams within the business to educate them on these risks and indicators of modern slavery. The closer they are to our supply chains, the more targeted and in-depth this training tends to be.
This year, our buying, property, and project management teams have all received training via the Ethical Trading Initiative and we aim to roll out this training to new areas of the business over the next year. With this experience, our staff are more likely to identify possible warning signs and raise issues if a supplier looks like they might be slipping below our expected standards.
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.
Effectiveness in combating slavery and human trafficking
We use key performance indicators to measure how effective we’ve been in combating slavery and human trafficking in our business and supply chains.
The KPI’s we will be using this year to measure our success are:
- Number of suppliers visited and audited by our Buying Team.
- Number of suppliers audited by a third party.
- Number of slavery reports received.
- Level and depth of Internal and External training
- Number of suppliers that completed our buying questionnaire.
- Number of development targets met by suppliers to help improve working conditions.
- Identifying high risk countries and industries for Modern Slavery.
Something to shout about - The move from Natural Mica
Lush first started buying materials containing natural mica back in 2012. We chose suppliers based on the guarantees that children were not working in production, and had audit reports to verify this. Our supplier at the time was working with a local NGO called BBA (Save the Childhood foundation), which works with whole villages to accomplish ‘child friendly villages.
Unfortunately, the pigment division of the company was old to another company. Lush Buyer, Gabbi explains: “We were told that the company could no longer offer the same external, third party auditing or verification. The new suppliers remained adamant that there was no child labour involved but because we no longer had verification of that fact by an independent company this raised a concern. It was then that we decided to switch all of our materials containing natural mica to a synthetic-based mica instead.”
In 2014, Lush started working to replace all ingredients containing natural mica with a synthetic mica based version.
When we were no longer able to guarantee transparency in the supply chain, we decided to make the change to synthetic mica.
Gabbi explains: “For us it was to do with the sourcing practises behind natural mica. It became clear that we couldn’t get the transparency that we wanted in our natural mica supply chains, so we decided synthetic mica was a better and more ethical option for us”
In 2016 natural mica was discovered in a range of mica pigments that we were told were synthetic. Gabbi explains: “This discovery was a real shock for us and highlighted the need for really tight controls. So it wasn’t just that it was our ethical preference not to use natural mica, it was absolutely something our suppliers had to fully commit to and confirm that they would not use natural mica in anything that they supplied us with.”
We are now happy to confidently say that as of the 1st January 2018, no natural mica has been used in the production of Lush products.
Supporting Human Rights Charities
At Lush, we like to look after those who look after others, and we are committed to supporting small, grassroots groups and other non-profit Human Rights organisations.
This financial year, in the UK alone, we have donated over £480,000 to Human Rights charities, including groups supporting anti-slavery practices such as human trafficking.
A full list of the charities we have supported can be found on our website at: https://uk.lush.com/article/donations-human-rights-groups
We encourage Charity Pot applications from all Human Rights organisations through our website. Please see our Charity Pot Guidelines for more information: https://uk.lush.com/article/charity-pot-funding-guidelines-0
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 30/06/2018. It has been issued on behalf of the Lush Group, approved by the Lush board of directors on the 24th of June 2018 and covers all UK Lush Entities including Lush Ltd, Lush Retail Ltd, Lush Manufacturing Ltd and Lush Cosmetics Ltd.
Signed by: Hilary Jones, Ethics Director
Date: 30th June 2018