If you’re going to make bold claims about your ethics, you’d better be prepared to prove them. What’s more, having an eye from outside the business can shed light on practices that need to be improved. Many audits are now becoming legal requirements.
Keeping our Non-Animal Testing promise
One of our oldest and most honoured values is our fight against animal testing. To help make sure we uphold this principle, we have a team of non-animal testing coordinators (NATs) in the UK, Croatia, North America and Japan, who work side by side with our buyers, to ensure all our global suppliers are compliant. We also commission an annual audit, conducted by the Ethical Consumer Research Association to ensure we are implementing our Non Animal Testing Policy effectively and rigorously to avoid any animal testing as much as we possibly can. You can get to know our Non-Animal Testing Policy, and our relationship with Ethical Consumer, in the Animal Testing principle in this report.
Our first audit was conducted by Ethical Consumer in July 2013 and has followed yearly since then. It has evolved, as the business has evolved, over the years and now covers all our global manufacturing bases. Our NAT Coordinators — those who have been charged with protecting our Animal Testing policy — meet with Ethical Consumer at the start of this process to introduce the yearly audit and discuss the plans for it for the year.
The one-on-one audit commences by removing any suppliers that have been audited in the past three years and those that, for the year, we have spent less than £46,710 with. The remaining suppliers are then given a number and a random number generator is used to select the suppliers that will be audited. Ethical Consumer will take the chosen suppliers through our Non Animal Testing policy and declaration in depth (either virtually or in person). Once this is complete, they will determine whether the supplier’s compliance status that was assigned by the NAT Coordinators needs to change, or can stay the same.
We also meet as a group after completion of the audit to discuss the results, go through the compliance percentages, and highlight the non compliant suppliers. In addition to this, Ethical Consumer provides us with recommendations on what to work on, as well as what we can do to improve for our next annual audit. A recommendation could include resourcing an ingredient away from a non compliant supplier to a new one, though this is sometimes harder than it seems. Each NAT coordinator will receive their own individual audit report pack for the manufacturing country they cover, and we receive a Global Summary Report that includes all countries.
Our 2024 audit came out with the following compliance rates:
- Global Compliance Rate: 90% of 733 Suppliers
- UK Compliance Rate: 93% of 332 Suppliers
- Croatia Compliance Rate: 98% of 48 Suppliers
- North America Compliance Rate: 91% of 180 Suppliers
- Japan Compliance Rate: 86% of 42 Suppliers
- Australia Compliance Rate: 76% of 75 Suppliers
Each supplier is assigned a compliance status which determines actions that need to be taken by our buyers when the review is complete. The categories that determine the compliance status for each supplier is broken down as follows:
| Category | Definition | Action |
| Compliant | Supplier is fully compliant with the NAT policy. | Compliant – No Action Required |
| Reach Registered, no animal testing in SIEF after June 2007 | Supplier has confirmed that the material has been REACH registered, but no animal testing was required after June 2007 for completion of the registration dossier. | Compliant – No Action Required |
| Reach Registered, animal testing in SIEF after June 2007 | Supplier has confirmed they had to conduct/commission animal testing after June 2007 for REACH purposes, or have had to pay towards the costs of animal tests as part of a REACH registration. | Compliant – No Action Required |
| Partially completed declaration / Old Declaration / Company NAT statement received | The supplier has acknowledged receipt of the declaration, but they have not yet sent the completed declarations. The supplier has not confirmed that they won’t be able to complete the NAT. | Discuss with the supplier and try to source the declaration. If a supplier is Blue for two consecutive years, they will be added to the resourcing list. |
| No Response | We have not received any form of acknowledgement/response from the supplier. | Resource if no contact can be established by anyone |
| Second Tier Testing | Animal testing confirmed to the Distributor by their manufacturer or the manufacturer is a company Lush chooses not to buy from. | Resource Affected Materials. The distributor remains ‘Pink’ for the non-compliant ingredients being supplied. If Lush or the supplier resources, the distributor can become green. |
| Non-compliance – for reasons other than animal testing. | Distributor has confirmed that they will not be able to receive a completed manufacturer declaration from their supplier: Non-Compliant for “paperwork reasons”, animal testing not confirmed but can’t be ruled out. | Resource |
| Testing | Animal Testing in the first tier (for other reasons than REACH) / animal derivatives used in the production process / contained in the final product. | Resource – Highest Priority |
Environmental & Financial Practices Auditing
For years, we have been calculating our carbon emissions in order to figure out where we can actually make a difference. We are now required, under the Taskforce on Climate Related Financial Disclosures (TCFD) framework, to disclose on how we are contributing to climate change — which helps us to understand how climate change is going to affect our bottom line and what we can do about it. The TCFD provides a proper and consistent structure for businesses to publish their numbers in their financial statements
Our Group financial statements are fully audited by a reputable and qualified audit firm which includes consideration of our TCFD disclosures and Group wide internal controls. Our Group financial statements were signed on 27th March 2024. Every year we publish our audited accounts, which can be found here, for more information on our financial and environmental performance.
Ethical Practices Auditing
Auditing for our ethical practices is most concentrated in our buying and supply network efforts. As you will find out in our Fair Dealings With Suppliers principle, Lush has always given preference to transparency of our supply network, over certification of our suppliers. We work in collaboration with our suppliers and other partners to get better visibility across these networks and help, where we can, remediate on any issues we find. Our buying and support teams utilise a piece of software called Authenticate to register our suppliers and start mapping out their networks, back to the first source. We register our first tier suppliers (those who we are directly involved in) who then register their suppliers and so on and so forth until we have reached the source of where that material was created or grown.
We are also legally mandated to provide a statement on our actions against Modern Slavery by the UK Modern Slavery Act (2015). We have similar requirements in other markets such as California, France, Australia, Germany, Canada, the European Union, Norway, Switzerland and Japan. In recent years we’ve increased our capacity for social audits and strengthened our modern slavery training.
In FY2024, we conducted our yearly salient human rights risk assessment of all our ingredients and packaging suppliers, taking into account the sourcing countries and prevalent risks associated, looking at commodities as well as our spend and the risk to the business. This assessment shows, in line with previous assessments, that materials that are mined or those 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 prioritise which suppliers and countries to concentrate on and prioritise for a visit. While the salient human rights risk assessment is conducted internally, we enlist the help of independent third parties. They not only help us identify more serious issues in our supply chains, but support us in maintaining impartiality whilst creating unique and strategic plans for remediation and supply chain transformation where it is needed.
In total we have carried out 47 supplier visits since July 2023 and also three human rights impact assessments of high risk supply chains in Egypt, the Dominican Republic and India. For these three assessments we enlisted the help of independent third parties.To read more about these third parties, their findings and the actions we have taken to combat instances of modern slavery found in our supply network, please have a look at our most recent Modern Slavery Statement.
Other Auditing
Some other external auditing that takes place at Lush are those performed by the Soil Association and FLOCERT Fairtrade. We have one organic certified product, the Therapy¿ Massage Bar, which is audited by the Soil Association every year. We have to provide the Soil Association with all of our documents relating to the purchasing and transporting of organic materials, and show them how the product is manufactured, so they can ensure that there is clear separation from our non-organic production and hence no cross contamination. This includes everything from the storage of ingredients, the equipment used to mix up the product and the cleaning products used to wipe down between batches. We must keep detailed cleaning and training records in the areas where Therapy¿ massage bars are made to show that we are upholding Soil Association standards of organic manufacture.
As well as being organic certified, we also trade in FLOCERT Fairtrade products. While we don’t use their trademark, in order to purchase and sell FLOCERT materials, your site must be certified. We are audited twice in a three year period, again to prove that our paperwork is correct and that there is separation of materials from non-FLOCERT materials. We also have to report all our purchases and sales of FLOCERT materials through the Fairtrace platform on a quarterly basis. For more information on our organic and fair trade materials, have a look at our Fair Dealings With Suppliers principle.
We perform some internal and external auditing for the Health and Safety of staff in our retail stores and manufacturing. Manufacturing is audited every two months using IAuditor software and our retail stores are audited every two years, either in person or virtually. These audits are undertaken by our dedicated Health & Safety teams, as well as some external audits for fire risk assessments, legionella etc.
The Bottom Line
External audits aren’t about making us look good – they’re about making sure we actually are good. When you invite scrutiny, you’d better be ready for what you might find. Sometimes that’s uncomfortable, but it’s the only way to keep improving.
Further reading →
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