Anti bribery and corruption policy

We take all Anti-Bribery and Corruption laws very seriously and are committed to investigating any incidents that may arise and promptly taking the most appropriate action required.

Who must comply?

Every employee and individual working on our behalf in any capacity is responsible for complying with this policy and conducting business honestly and with complete professional integrity.

This includes all partners, employees, suppliers, NGOs or other organisations funded by or commercially involved in our ‘Sustainable Lush Fund’ scheme.  Our Anti-Bribery and corruption policy is available to view on Lush Labs and on our website under ‘Our Policies’.

What is Bribery?

A Bribe is defined as giving someone a financial or other advantage, to encourage that person to perform functions or actions improperly which could be illegal or unethical, or to reward that person for having already done so.

Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit and includes offering, accepting or seeking a bribe.

Specifically, you must not:

• Offer any form of bribe
• Receive any form of bribe
• Bribe any Government Official in any country

Gifts and Hospitality

Lush recognises that giving or receiving gifts or hospitality can be a part of building and maintaining business relationships. Our policy does not prohibit the giving or accepting of reasonable and proportionate hospitality as long as they have a legitimate purpose. Promotional gifts of low value may also be given to or accepted from existing customers, suppliers and business partners.

Gifts or hospitality will not be appropriate if it is unduly lavish, extravagant, or could be seen as an inducement. Gifts must not include cash or cash equivalent, or be given in secret. Gifts must be given in the name of Lush and not in the name of any individual.

Record-Keeping

Details of hospitality and gifts given or received, over a value of £250 should be reported to your line manager and a written record should be kept.  This record demonstrates that we have ‘adequate procedures’ in place to prevent bribery.

Raising Concerns

If you are offered a bribe, or are asked to make one, or if you suspect that bribery has or may occur, you must notify your manager or send details of your concerns to: blowthewhistle@lush.co.uk as soon as possible. If you refuse to accept or offer a bribe or you report a concern, we understand that you may feel worried about doing so. We will make sure that anyone who raises concerns in good faith, is fully supported by Lush.