Anti-Slavery & Human Trafficking Policy
What is Modern Slavery?
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as human trafficking, slavery, servitude, forced labour, forced or servile marriage, the sale and exploitation of children and debt bondage, all of which have one thing in common - the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
We care about the welfare of everyone in our supply chain and operate a zero-tolerance approach to modern slavery.
We ask everyone to :
- Be open and honest with us
- Take ownership of any problems
- Work with us to tackle problems
We are committed to ensuring transparency throughout our business and our approach is to tackle modern slavery by implementing effective systems to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
Who does this policy apply to?
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. This policy does not form part of any employee's contract of employment and we may amend it at any time.
Responsibility for this policy
The Lush board of directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. Our Ethical Compliance Manager 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.
Setting the Standard for the Care of People in our Supply Chains
We set our standards high and expect our suppliers to hold their own suppliers to the same standards.
The standards detailed in Annex 1 ‘Setting the Standard for the Care of People in our Supply Chains’ constitute minimum and not maximum standards and should not be used to prevent anyone from exceeding these standards. You are expected to comply with national and other applicable law and, where the provisions of law and this Policy address the same subject, to apply that provision which affords the greater protection. By failing to meet these standards, you will be in breach of this policy.
Compliance with the policy
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
If you believe or suspect an instance of non-compliance with this policy has occurred, or may occur in the future or if you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, you must report your concerns to [email protected] in accordance with our Whistleblowing Policy as soon as possible.
All disclosures made in line with our Whistleblowing Policy will be protected. The Public Interest Disclosure Act 1998, as amended, prevents you from suffering detrimental treatment for ‘Whistleblowing’.
If you believe that you have suffered any detrimental treatment as a result of raising such concerns, you should inform our People Experience team on [email protected]. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found within our Grievance Policy on Lush Labs.
Communication and awareness of this policy
Raising awareness of this policy, and the risk our business faces from modern slavery in our supply chains should form part of the induction process for all individuals who work for us, and training should be provided as necessary.
Compliance with this policy must be confirmed by all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of this policy
Any employee 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 organisations working on our behalf if they breach this policy.