Objective and Purpose

Our commitment to doing business in an ethical way is central to how we operate; being agents of change, we try to use our economic activity in the best way possible to improve practices where needed and want to lead by example. We care about the welfare of humans and animals in our supply chain and the environmental footprint we leave behind. At Lush, we recognise that a large part of our success has been due to the establishment of direct and close working relationships with our suppliers. Our aim is for everyone in our supply chain (all direct and indirect suppliers of raw materials and packaging products and their subcontractors) to share and adhere to these policies. We use these policies as a framework for conducting our business. All new suppliers will need to complete and return this policy document prior to Lush purchasing any goods. 

Here is a checklist of all documents/links sent to suppliers with a breakdown of our expectations:

• Non-Animal Testing Policy & Declaration – Lush does not test on animals, do not use materials that contain animal derivatives that are unsuitable for vegetarians and only buy raw materials from companies that are not involved in the use of, or commission the use of, animals for testing and have no plans to do so in the future. Whilst we recognise the unavoidable exception of the European and UK REACH legislation (Registration, Evaluation, Authorisation & Restriction of Chemicals) we believe that animal testing is not acceptable. We recognise that customer safety is of importance but that this cannot be assured using animals. This policy and declaration is sent out annually as part of the Lush Non-Animal Testing review. Suppliers, new and existing, acknowledge the receipt of the policy and complete the declaration. The Non-Animal Testing declaration also contains a document that gives advice on New Approach Methodologies (NAMs). We are supporting the uptake of NAMs to end the reliance on traditional animal toxicity tests.
• People Care, Earth Care & Fair Share Buying Policies – These buying policies consist of non-negotiable standards, legal requirements and progressive standards (please see further information below). Suppliers, new and existing, acknowledge the receipt of the policy by signing the policy document. This is sent out to suppliers to be renewed regularly. New suppliers will only be fully authorised as a Lush supplier upon receipt of the completed and signed policy document. 
• Buying Vision – The purpose of this document is to provide motivational and inspirational examples of positive changes relating to our supply chain. We welcome stories from our suppliers to be included in this document. The Vision document is sent out together with the People Care, Earth Care & Fair Share Buying Policy. 
• Online Supplier Survey – 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. We are aiming to send out a survey to all suppliers every other year and to send shorter surveys investigating specific topics to a selection of suppliers annually. We require all of our direct suppliers to complete this.
• Third party auditing of our suppliers’ records and procedures may also be carried out. This may be done as a random spot check or used where further validation of the declaration is needed.

Non-Negotiable Standards

These standards consist of legal obligations and/or standards we consider minimum standards that everyone needs to adhere to. These standards are marked with the following symbol: ⚫

Please note – we understand that there can be very unique circumstances. If for any reason adhering to any of the standards outlined in this document could have any social or environmentally detrimental effect on you as a supplier or anyone in your supply chain please get in touch with us.

Progressive Standards & Supporting Change

These standards are still important to us, however, we understand that suppliers may need time/require support to reach these standards. We accept that we cannot solve all problems overnight, so if these standards are not met, we work with our suppliers to set benchmarks, to move in the right direction and to achieve mutually acceptable solutions in an agreed time frame. We believe in working with suppliers and want to support change. These standards are marked with the following symbol:  ◯

Commitment from suppliers

We ask all of our suppliers to:

• Be open and honest with us

• Take ownership of any concerns

• Work collaboratively with Lush so that we can help support to tackle any issues

• Be responsible for ensuring that all suppliers used for the production of goods sold to us are aware of the policies set out in this document 

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. 

We would love to hear from suppliers that exceed any of the standards set out in this policy and invite you to share any work that you do to tackle any of the issues covered within this document with us.

This policy applies to a suppliers operations as follows: 

• Distributors – their entire operations + the manufacturer(s) of the material sold to Lush (as per below requirement for manufacturers)
• Manufacturers – where Lush buys directly from a manufacturer, the policy applies to the manufacturers entire operations, including suppliers, subcontractors and homeworkers.

1.1 Employment is freely chosen ⚫

1.1.1 There is no forced, bonded or involuntary prison labour.

1.1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

1.1.3 Lush strictly prohibits human trafficking in all its and our suppliers’ operations.

1.2 Freedom of association and the right to collective bargaining are respected ⚫

1.2.1 All workers have the right to join or form trade unions of their own choosing and to bargain collectively.

1.2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.

1.2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.

1.2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

1.3 Working conditions are safe and hygienic ⚫

1.3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

1.3.2 Workers shall receive regular and recorded health and safety training, in line with the appropriate risk assessment and such training shall be repeated for new or reassigned workers.

1.3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

1.3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

1.3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative, who is suitably qualified, and has the ability to effect change.

1.4 No child labour ⚫

1.4.1 No child should be employed or work if:

• They are younger than the legal minimum age for work in the country of manufacture or
• They are younger than 15 (or 14 in some developing countries)
• There is any risk to their mental and physical health
• It’s harmful to their safety or ability to have a childhood
• It’s interfering with or replacing the child’s education
• It’s forced and against their will

1.4.2 Children aged 13 to 15 years (or 12 to 14 years in some developing countries) may be employed in light work, if national laws or regulations permit.

1.4.3 No-one aged below 18 years should engage in any dangerous/hazardous work that might jeopardise their physical, mental or moral well-being because of its nature or the conditions under which it is carried out. 

1.4.4 Children and young persons under 18 shall not be employed at night or in hazardous conditions. 

1.4.5 Suppliers shall establish, document, maintain and effectively communicate to personnel and other interested parties, written policies and procedures for remediation of child labourers. Policies and procedures shall provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child (this includes the provision of adequate financial and other support).

1.4.6 The organisation shall not expose children or young workers to any situations – in or outside of the workplace – that are hazardous or unsafe to their physical and mental health and development.

Please note – we understand that there can be very unique circumstances. If for any reason adhering to 1.4 or any of the standards outlined in this document could have a detrimental effect on you as a supplier or anyone in your supply chain please get in touch with us. 

1.5 Legal minimum wages are paid and all workers employed shall be provided with all legally mandated benefits. ⚫

1.5.1 All workers shall be provided with written and understandable information about their employment conditions, or services to be conducted before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

1.5.2 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

1.5.3 Wages and benefits paid for a standard working week shall meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher.

◯ The progressive goal is for suppliers to pay a wage that both meets basic needs and provides some discretionary income.

1.5.4 Employer Pays Principle: No worker shall pay for a job – the costs of recruitment should be borne not by the worker but by the employer.

Repayment of Recruitment Fees: If it is discovered that workers have paid recruitment fees, the full cost of those fees should be reimbursed to the worker by the business partner who is responsible for the violation, including for any sub-agents in the recruitment supply chain where this was within the reasonable due diligence control of the business partner. 

1.6 Working hours are not excessive ⚫

1.6.1 Working hours must comply with national laws, collective agreements, and the provisions of 1.6.2 to 1.6.6 below, whichever affords the greater protection for workers. Sub-clauses 1.6.2 to 1.6.6 are based on international labour standards.

1.6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week unless the individual concerned has expressed the desire to.

1.6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace, or supplement regular employment.

1.6.4 The total hours worked in any seven-day period shall not exceed 60 hours, unless the individual concerned has expressed the desire to do so, or where covered by clause 1.6.5 below.   

1.6.5 Working hours may exceed 60 hours in any seven-day period only in exceptional circumstances where all of the following are met:

• this is allowed by national law;
• this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;
• appropriate safeguards are taken to protect the workers’ health and safety following suitable risk assessments; 
• additional breaks are provided if required, and
• the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies. Please note, seasonal fluctuations are not exceptional circumstances.

1.6.6 Workers shall be provided with at least one day off in every seven-day period or, where allowed by national law, two days off in every 14-day period. * International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced. 

1.7 No discrimination is practised ⚫

1.7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination, general day-to-day workplace practice or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation. 

1.8 Regular employment is provided ⚫

1.8.1 To every extent possible work performed must be on the basis of a recognised employment relationship established through national law and practice.

1.8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, subcontracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

1.8.3 There shall be no zero-hour contracts unless it is the preferred choice of the employee or where the country concerned has protected ‘casual employee’ legislation in place.

1.8.4 There should be equal balance between the employee’s employment conditions, rights, responsibilities and duties set out in the contract and the employer’s. 

1.9 No harsh or inhumane treatment is allowed ⚫

1.9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. The provisions of this code constitute minimum and not maximum standards, and this code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and, where the provisions of law and this standard address the same subject, to apply that provision which affords the greater protection.

1.10 Homeworking & Subcontracting ⚫

1.10.1 We accept the presence of homeworking and subcontracting within our supply chain where mutually agreed. We want to work with our suppliers to ensure good labour conditions in our supply chains. We ask our suppliers to communicate this policy to all homeworkers/subcontractors and to declare to Lush where homeworking/subcontracting occurs in supply chains.

2.1 Use of Genetically Modified Organisms (GMO) & Microorganisms (GMM) ⚫

2.1.1 Suppliers shall not use genetically modified organisms or microorganisms in the production of any material supplied to Lush. This includes paper and paper based products and transgenically modified trees and plants that have genes of other animals and plants inserted.

2.2 Environment and Biodiversity ⚫

2.2.1 The supplier’s operations shall not contribute to the destruction of natural habitats/areas of ‘conservation interest’ including primary forest, peatland, coastal habitats, water meadows, water reservoirs etc.

2.2.2 There is an implemented Environment plan/policy which takes into consideration avoiding actions that adversely affect biodiversity and natural habitats e.g. clearing native forests, fracking, draining reservoirs.

2.2.3 Suppliers shall not exceed legal pollution limits (air, soil, water) and all required permits are held.

2.2.4 If material supplied to Lush is listed under any CITES appendix, a sustainable extraction management plan is in place to ensure that the species is able to regenerate at the same pace as is being extracted.

2.2.5 Suppliers shall advise Lush if a material/product sold to Lush falls under CITES control. 

2.2.6 If the supplier imports the product from outside of the EU, or buys from a third party that does, then the supplier must provide Lush with a copy of the CITES import permit. 

2.3 Chemical Management Practices ⚫

2.3.1 There must be a detailed Health and Safety Risk Assessment and training provided for the handling of all chemicals to include:

• Protective wear and equipment
• Dangers of inhalation and contact with skin
• Detailed guidelines on mixing and spraying

2.3.2 All applications of chemicals are monitored and recorded.

2.3.3 The business must consider all impacts of all chemical management practices.

2.3.4 Protection measures must be in place where chemicals are handled and mixed to prevent potential spillage resulting in pollution of water streams and the local environment.

2.3.5 Chemicals must be stored safely and in line with the manufacturer’s instruction, such that the risk to the person and the environment is minimised.

2.4 Animal Welfare ⚫

Suppliers shall enforce the following animal welfare standards. This is applicable to any animal that is directly or indirectly involved with your operations. The below standards are intended to incorporate the five freedoms of animal welfare, along with any additional requirements.

2.4.1 Freedom from hunger and thirst – by providing ready access to fresh water and a diet to maintain full health and vigour.

2.4.2 Freedom from discomfort – by providing an appropriate environment including shelter and a comfortable resting area.

2.4.3 Freedom from pain, injury or disease – by prevention or rapid diagnosis and treatment.

2.4.4 Freedom to express normal behaviour – by providing sufficient space, freedom of movement, proper facilities and company of the animals’ own kind.

2.4.5 Freedom from fear and distress – by ensuring that the conditions and care provided avoid mental suffering.

2.4.6 Wherever possible, suppliers shall prohibit any form of animal hunting or culling to take place on the land which the product is grown/processed on. This includes animals such as badgers, rats etc which are sometimes considered ‘pests’.

2.4.7 Field operations shall be adjusted to avoid areas of habitat for animals e.g. ground nesting

2.4.8 In agricultural operations any chemicals or processes used should ensure that Bees and Pollinators are not harmed.

Please note – Even if you do not have animals on your premises, Lush is a vegetarian company and we have a preference that our suppliers do not engage, or produce products that contain animal derivatives. We do however understand and appreciate this is not always possible, but we kindly ask all suppliers to declare to Lush any animal derived products including, but not limited to; fur, exotic skins, foie gras, horn that they manufacture or sell, when submitting this policy.

2.5 Soil Health ◯

2.5.1 There shall be an implemented Soil Health Management plan which aims to conserve soil organic matter.

 2.6 Highly Hazardous Pesticides ◯

Lush promotes the use of natural techniques for pest control that are based on agroecological methods or the use of biological control agents. Lush encourages suppliers to phase out the use of chemical pesticides and requires suppliers to provide a phase out plan with a realistic timeline, should chemical pesticides be used. If the active ingredients in the pesticides being used qualify as Highly Hazardous (according to the PAN list) suppliers are required to provide a remediation plan in addition to a phase out plan. Please note that Lush conducts spot checks on our materials to monitor traces of prohibited pesticides for the safety of our customers. 

Here is a link to the list of pesticides Lush prohibits. 

http://pan-international.org/wp-content/uploads/PAN_HHP_List.pdf

2.6.1 None of the pesticides, fungicides and herbicides listed on the Lush Prohibited list shall be used in the production of the supplied material to Lush. Please note that this also includes the same products disguised under a different trade, scientific or common name.

2.7 Forestry Management ◯

2.7.1 If any material supplied to Lush requires further processing which uses forests as energy source (e.g. wood-fuelled distilling), the supplier must demonstrate the sustainability of those materials to Lush, assuring a net-zero deforestation scenario.

2.7.2 Operations shall not disrupt bird nesting (e.g. felling occurs outside of breeding times) or breeding periods of other key animals.

2.7.3 Suppliers must have a forestry management plan in place which is shared with the relevant buyer. This shall address the sustainability of the yields and the wider ecological roles of the utilised species in the local ecosystem.

2.7.4 Suppliers shall ensure that there are no hunting/shooting rights for sporting/entertainment purposes attached to the forest area.

2.7.5 If root stock is extracted [or trees are felled and will not re-grow through coppice] the supplier shall ensure that there is a [realistic] replanting plan in place.

2.7.6 Suppliers should ensure that extraction does not prohibit seed dispersal if set in a primary forest setting.

2.7.7 Any materials derived from tree tapping methods for resin shall provide a sustainable tapping management plan to be shared with the relevant buyer. Suppliers shall ensure that ongoing tapping does not contribute to declining tree health and endangering the tree population.2.7.8 Suppliers shall ensure that no Genetically Modified or Genetically Engineered Transgenic Trees are planted.

3.1 Suppliers accept responsibility for helping to gain transparency of the supply chains of ingredients supplied to Lush. 

3.2 The legal and customary rights and traditional practices of indigenous peoples and local communities shall be respected. 

3.2.1 Disputes over ownership or use of land and natural resources are addressed. Information is available on disputes in cultivation or collection sites, including over rights of use of land, tenure rights and rights on other natural resources, such as water. 

3.2.2 Any disputes identified in 3.2.1 shall be actively monitored and attempts at conflict resolution shall be supported where possible. 3.2.3 Existing disputes over ownership and/or land use and steps to resolve them shall  be documented by an impartial third party. E.g NGO or government authority.

4.1 Suppliers must adhere to all relevant Lush policies. These policies include our ‘Anti-Slavery & Human Trafficking’, ‘Anti bribery and corruption policy’, “Modern Slavery Remediation Policy,” amongst others, which can be 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.

4.2 The supplier must confirm that all necessary due diligence was undertaken and that they are compliant with the Nagoya Protocol where applicable. Suppliers will be asked to provide proof of this. 

4.3 Suppliers must have systems in place to review and adhere to their legal obligations under regulations including, but not limited to; The UK Modern Slavery Act (or any other global legislation designed to combat modern slavery and offences relating to trafficking and slavery), UK Bribery Act, The Human Rights Act, The Nagoya Protocol, tax and environmental laws and where relevant the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), to protect endangered plants and animals and to help regeneration of degraded environments. 

We expect you to be:

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

4.4 Any legal non-compliance must be reported to Lush immediately.

All malpractice concerns should be reported to: [email protected] 

For further information on whistleblowing please refer to our whistleblowing policy here: https://weare.lush.com/lush-life/our-policies/lush-whistleblowing-policy/

For any questions or comments regarding this document please contact: [email protected]