2016 Statement - Combating Modern Slavery

The term ‘Modern Slavery’ is used to denote human trafficking, forced labour and slavery-like practices such as debt bondage and the sale or exploitation of children. The common feature with these crimes is they involve one person
depriving another person of their liberty in order to exploit them for personal or commercial gain.


The horrendous practices of modern slavery and human trafficking are occurring, largely hidden, across many parts of our world, including in the UK. The Lush Group are committed to helping end these practices in any way that we can. People are at the heart of everything that we do and we will only ever work with those that share the same, strong values as us. To combat the risks of modern slavery and human trafficking in every area of our business, we have taken (and continue to take) steps that we are proud to share with you in this statement. We are also committed to raising the bar higher, and monitoring our suppliers in order to ensure that they consistently meet our high standards.

Our Structure

The Lush Group is a global manufacturer and retailer of cosmetics. The Lush brand operates in 49 countries, with more than 20,000 employees worldwide.

Our Business

Lush covers the sourcing of ingredients including growing, manufacturing cosmetic products and the selling of our products through both our retail outlets and Digital sales online.

Our supply chains

Our supply chains are sizeable and feature suppliers from countries all over the world, including:

  • UK
  • France
  • USA
  • Italy
  • Spain
  • Turkey
  • Tunisia
  • Morocco
  • Egypt
  • India
  • Indonesia
  • China
  • Brazil
  • Uganda


Acting with integrity and upholding strong ethics is fundamental to every aspect of what we do. Our Anti-Slavery Policy is therefore embedded in all of our supply chain works, and breaches to this policy are not taken lightly. If we are not able to work with suppliers to influence them on matters that are of concern, we will end our relationship with them.

Due diligence processes for Slavery and human trafficking 

To effectively combat modern slavery and human trafficking, we have a variety of measures in place to monitor our supply chain and educate the people working with us. These are:

● A detailed buying questionnaire is used to vet each supplier we work with and ensure that they respect their employees’ rights.

● Where possible, we work directly with suppliers and producers, visiting their fields and processing plants, and fostering long-term relationships. This has multiple benefits: one of which is that we can guarantee that we’re happy with the working environment.

● We employ the assistance of third parties to carry out independent inspections when dealing with high risk materials to ensure the highest levels of due diligence – like cocoa – where we rely not just on our own checks, but use only certified cocoa (Fair Trade certified), which means the supply chains are audited by a certification body.

● Whistleblowers: The anonymity of anyone raising concerns or bringing to our attention practices that do not comply with our policy is protected. Anyone with information or a concern can bring this to our attention by emailing [email protected] so that we can investigate and take action.


To make certain that those in our supply chain share our ethics, we are recruiting for a compliance officer to work closely with our buying team. Our compliance officer will make absolutely sure that our suppliers believe in and practice the fair treatment of their staff. They will investigate and manages the risk of modern slavery in our supply chain and ensure that certain standards are met in line with our Anti-Slavery Policy.


We need Lush staff, particularly our buyers, to have an active and engaged understanding of the risks of modern slavery and human trafficking. Members of our buying team are therefore up-skilled via the Ethical Buying Initiative course so they can identify possible warning signs and raise concern if a supplier looks to be slipping below the standards we expect. We are rolling out a training programme across our business, aiming to educate staff on the risks of modern slavery and human trafficking. This will incorporate targeted, in-depth training for employees specifically involved with supply chain management.


Key performance indicators measure how effective we have been in combating slavery and human trafficking in our business and supply chains. At the moment our primary KPI is Training for all buyers and people involved in other relevant parts of the business. We are hoping to build on these over the next year when we have appointed a Compliance Officer to oversee and manage the MSA.

Where we’re heading

Following a review of the measures we have taken this year to combat the risks of modern slavery and human trafficking in our supply chains, we now intend to take the following further steps:

● Appoint a dedicated Compliance Officer to oversee the MSA.

● Undertake an annual review of our Buying Questionnaire to highlight any risks in our supply chain

● Alongside our annual review of our Buying Questionnaire, we will issue a set of ethical standards specific to the MSA, which will be signed as a declaration of commitment from our suppliers.

There will always be more work to be done, so we will continue to review, evolve, and strive to do more.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 30/06/2016.