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UK&I Gender Affirming Care policy

April 2025

LUSH is committed to creating a diverse, and inclusive working environment and supports
our trans, non-binary and gender diverse employees.

LUSH understands the role that gender transition can play in some peoples journeys to becoming their most authentic selves. This policy outlines the support available to LUSH.
At any point an employee can contact their manager or the People team in your business area if they have any questions regarding this policy.
Where applicable this policy should be read alongside other relevant policies and guidance
within LUSH, including;
Respect at Work Policy
Lush Resolution Policy
Disciplinary & Guidelines and Policy
UK GDPR Privacy Notice for Employees, Workers and Contractors
Glossary of terms
Manager’s guide
FAQ’s

  1. Our Aim
    At LUSH people are at the heart of what we do. We are committed to fostering an environment where all employees can be their authentic selves. Our transgender, non-binary and gender-diverse employees contribute valuable experience to the organisation and have a positive impact on LUSH’s organisational priorities and values. This policy provides clear guidance on work place support, including name and pronoun changes, transitioning leave and access to facilities.
  2. Scope
    This policy applies to all employees working at LUSH.
    The paid leave benefit outlined in Section 6a of this policy is available to permanent members of staff after 6 months of employment and having successfully completed their probationary period. However, employees requiring support before this period may use alternative available leave entitlements. In addition, where appropriate, employees may be eligible for additional unpaid leave or flexible working arrangements on a case-by-case basis.
  3. Legislation
    LUSH is committed to complying with all relevant UK&I employment legislation, including The Equality Act 2010, Employment Equality Act 1998, The Worker Protection (Amendment of Equality Act 2010) Act 2023, Data Protection Act 2018 & GDPR, The Gender Recognition Act 2004 and The Gender Recognition Act 2015.
    While the Equality Act 2010 primarily protects individuals undergoing ‘gender reassignment’, LUSH recognises that gender identity is broader than legal definitions. This policy extends workplace protections to all trans and non-binary employees, ensuring support regardless of whether they undergo medical transition or legal gender change.
    We will comply with data protection laws, including the General Data Protection Regulation (GDPR) and The Gender Recognition Act 2004 to protect the personal data of employees undergoing a transition. For further information, see changing personal information guidance here.
  4. Respect at work
    Everyone at LUSH has a responsibility to create and maintain a respectful and inclusive work environment. The expected behaviours and responsibilities of all employees are outlined in our Respect at work policy.
    Employees who are transitioning have the right to privacy and support throughout the process. While each individual’s experience and needs may differ, there are some key responsibilities that can help ensure a smooth transition for all parties and the workplace.
    For more information please see our policy FAQ’s.
    Managers/Leads play a key role in supporting employees who are transitioning, ensuring that the workplace remains inclusive and respectful, please see further guidance here.
  5. What is transitioning?
    Transitioning is a term used to describe the process and steps an individual takes in order to live in the gender they identify as. This may include medical treatments, legal changes, social adjustments, or a combination of these. There is no single way to transition, and it is essential to respect each individual’s journey.
    Many people falsely believe that in order to transition a person must undergo a medical intervention, such as hormone treatment or surgery, or gain a Gender Recognition Certificate (GRC). It should not be assumed that the goal of every individual’s transition is to change their physiology or legal gender. If a person chooses not to undergo any medical intervention or gain a GRC, they are still entitled to dignity and respect along their chosen path of transition, whatever that may consist of.
  6. Transitioning at work: Steps and Support
    It is a matter of personal choice as to who you contact for support, either your manager or the people team, but it is recommended that together you create and agree an individualised action plan to support your transition journey. LUSH will provide tailored support to ensure a smooth transition in the workplace, which includes but is not limited to:
    ● Inform the business: Our employees are encouraged, but not required to inform their managers or the People team if they are transitioning and would like workplace support.
    ● Changing Personal Information: LUSH will update any personal information records (e.g., name, gender, pronouns) on request to ensure accuracy and respect.
    For more information on the process to update personal information, please see here.
    ● Workplace Facilities: Most of our facilities at LUSH are gender neutral. However, where this is not the case employees should use whichever facilities they feel most comfortable using. Employees should not be asked and will not be expected to use disabled/accessible facilities as an alternative. However, you may do so if you prefer.
    ● Dress Code: At LUSH, we aim to keep our dress code flexible and inclusive, while making sure everyone’s safe, comfortable, and on-brand. Our employees should follow the dress code for their area of the business, but can of course do this according to their gender identity.
    ● Deadnaming & Misgendering: All employees are expected to use an employee’s correct name and pronouns. If misgendering occurs, it should be promptly corrected. Intentional misgendering or deadnaming will be treated seriously and investigated promptly in line with our Respect at Work Policy.
    ● Flexible working: Where appropriate, LUSH will consider requests for temporary flexible working arrangements to support employees transitioning as and when needed.
    ● Bullying and Discrimination: Any form of bullying, harassment or discrimination based on gender identity or expression will not be tolerated. We have a clear resolutions procedure in place, and any complaints will be treated seriously and investigated promptly in accordance with our Respect at Work policy and Resolutions policy.
    ● Health Assured: All employees at Lush are eligible for the Health Assured employee assistance programme. Health Assured offers independent, confidential support and guidance. You can find more information on Health Assured here.

    6a. Paid leave
    At LUSH we recognise that gender transition is a deeply personal journey.
    We offer up to 33 weeks (1 week = weekly contracted hours at your basic pay excluding bonus) paid leave over a period of 10 years. As mentioned in section 2, this is available to permanent members of staff after 6 months of employment, and having successfully completed their probationary period (alternative unpaid leave may be available for those who do not meet this criterion). This leave is separate to any sick leave and does not affect any sick pay entitlements.
    Providing dedicated transitioning leave ensures that LUSH employees have the time and support they need to access gender-affirming care.
    This may include medical procedures, appointments, legal changes or personal adjustments, without using any sick leave entitlements. If you are unsure whether something would be covered under Gender Affirming Care leave or another form of leave, please discuss this with your manager.
    In the case of any complications with any medical treatments (e.g. surgical interventions) resulting in limitations to work, the regular procedure of sick leave, associated policies and support should be followed.



  7. Creating a gender affirming care support plan
    A transition and support plan may include any or all of the points below. It provides an opportunity to discuss with the employee what they need to feel supported and included at work.
    ● A discussion with the employee to explore where they are in their transition journey and how they would like to be supported. This may include discussing how they feel comfortable presenting in a way that aligns with their gender identity and using a new name or pronouns.
    ● A list of employees who need to be advised of the transition in order to implement any requested workplace changes (People Team members, EBT, the transitioning employee’s manager, etc.) or as requested by the employee.
    ● A plan for when and how those employees should be informed of the transition and who will inform them.
    ● A list of the employee’s records that will need to be changed to reflect any changes to gender identity or name (if applicable), along with any documents that may need to be provided to process these changes and the expected dates of when this will take place.
    ● A discussion to understand the employees plans for transition-related leave. The employee may not be aware of the length of leave required initially, so the plan should be reviewed and updated as needed.
    ● Explore any temporary workplace adjustments or accommodations needed to support the employee during their transition journey. Please see the flexible working guidance for more permanent requests.
    ● Supporting employees wellbeing – Create a safe space for employees to share any concerns and discuss how the employee would like to be supported in their journey (Internal/External support resources: Health Assured and community network groups)
    ● Discuss if the employee would like to acknowledge or celebrate any milestones in their transitioning journey and how would they prefer to do this.
  8. Process to request gender affirming care leave
    Any requests for transitioning leave should be discussed with your manager in the first instance and/or the relevant People Team in your business area.
    By informing your manager and/or people team, we can support any workplace accommodations and help facilitate changes in a confidential and respectful way. If for any reason you do not feel comfortable discussing this with your manager, please contact a member of the people team who can support you in facilitating this conversation with your manager.
    Your manager will do their best to accommodate any leave requests, while also considering the needs of the team and the wider business. If a situation arises where it is not possible for your leave to be accommodated, your manager will discuss alternative options with you.
    Once discussed and agreed, you should submit your leave request in writing to your manager at least *8 weeks before the leave is due to begin. Your request should include the following details:
    • the amount of the leave (If applicable, this will be outlined together with the employee and
      their medical professional);
    • the probable duration of the leave they wish to take;
    • start date of the leave;
    • and when applicable how the leave is spread over the week;
    • Any accompanying suitable evidence (e.g a medical note or letter from a healthcare
      provider), if applicable
  9. *If the announcement of the leave is not possible within the time frame of minimum 8 weeks
    in advance; the employee must discuss the start date of the leave as soon as possible with
    their manager. We understand that every journey is unique and that leave may be required
    within shorter timeframes.Your manager will do their best to accommodate these requests
    while also considering the needs of the team and wider business.

    Depending on the reason for leave and the nature of your role, your manager and/or the
    People Team may discuss with you any temporary reasonable adjustments to facilitate a
    smooth return to work. Your manager will also discuss and agree with you on the appropriate
    frequency and method of check-ins/communication during your time away. This is to ensure
    ongoing support, help maintain connection and provide an opportunity to share any updates
    or important information if necessary.
    Once you have discussed your leave request with your manager and it has been approved,
    your manager will need to complete a form, which will be sent to payroll to action the
    request.
    All requests for leave will be handled confidentially and in line with any agreed transition plans (see section 7 and 9). In the case of any complications with any medical treatments (e.g. surgical interventions) resulting in limitations to work, the regular procedure of sick leave, associated policies and support should be followed.


  10. Confidentiality
    LUSH understands that some employees may prefer to keep details of their gender transition private. We respect each individual’s choice regarding privacy and will only disclose details as necessary to implement any requested changes or if the employee consents to share it. Employees who are transitioning are encouraged to share information with their manager and peers as much as they feel comfortable doing so. In order to carry out certain workplace adjustments, you may need to share relevant information with your manager so they can assist in facilitating the necessary support.
  11. Training and Education
    LUSH will provide training to employees as part of the employee experience.
  12. Breach of this policy
    We trust that leave will be used appropriately and in the spirit of the support it’s intended to
    provide. Misuse of leave may be considered a breach of policy and could be addressed
    through our usual disciplinary procedures, where necessary.
    Failure to comply with this policy without good reason, could result in disciplinary action
    being taken against employees (up to and including dismissal) and in the case of
    non-employees, termination of the relationship. This includes instances where complaints
    are found to be falsified or fake.
  13. Status of this policy
    This policy is not contractual, and we reserve the right to amend it at any time. We will
    monitor this policy periodically to ensure its effectiveness and it will be updated in
    accordance with relevant changes in the law. Updated versions will be made accessible.
  14. Useful Lush contacts/resources
    *UK&I People Services
    Retail people team: retail.peopleservices@lush.co.uk | 01202 006460
    Manufacturing People team: manu.peopleexperience@lush.co.uk
    Support people team: support.peopleservice
    UK&I Retailers: uk.retail@lush.co.uk
    Customer Care: wecare@lush.co.uk | 01202 930051
    Included@lush.co.uk
    Colleague Centre – Here you can find lots of resources to support your employee journey
    Community Networks hub
    Useful external contacts
    Health Assured: All employees at LUSH are eligible for the Health Assured employee assistance programme. Health Assured offers independent, confidential support and guidance. You can find more information on Health Assured here.
  15. Other useful policies
    ● Disciplinary Guidelines and Policy
    ● Whistleblowing Policy
    If you require any support accessing or interpreting these policies, please contact the People team.

    Published: April 2025 V1

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