Lush is committed to promoting a culture where people feel comfortable talking about their concerns, including highlighting instances they think might be illegal or unethical malpractice. We want to make sure the workplace is a positive place to be for all those working for Lush and in our supply chains. If you have reason to believe that malpractice is taking place, we want to hear about it and encourage you to raise this in accordance with this policy.
What is Whistleblowing?
Whistleblowing is the name given to the act of reporting certain types of wrongdoing related to a business, government department, an official in public office, etc. A person is said to ‘blow the whistle’ when they share (secret or new) information about an activity that could be seen as illegal.
When someone discloses certain types of malpractice there is protection in place to ensure they and any other persons affected by a report or disclosure are not treated unfairly or do not lose their job because they ‘blow the whistle’.
Examples of malpractice can be found under ‘What is malpractice’ below.
Whistleblowing is different from raising a personal grievance (bullying, harassment, discrimination) and is not covered by this policy. If you are a Lush employee and have a concern about the way you are being treated at work, we encourage you to either contact a member of your local support team or contact the UK People team directly at people.services@lush.co.uk / 01202 006 460.
If you would like to report a personal grievance, but wish to remain anonymous, please ensure you make this clear to the People Services team and consider that by remaining anonymous, this could make it more difficult to investigate the situation and may limit what action we are able to take.
If you are an employee of the Lush Group and have concerns that there has been a breach to The Lush Ethical Charter, this should be reported directly to the EBT Trustees at ebt@lush.co.uk.
What is malpractice?
Malpractice covers things such as criminal activity, breach of legal obligations, environmental damage, acts of bribery, tax evasion, unlawful cash procedures, theft of company money or property, modern slavery, risk to health and safety, endangering staff or members of the public or any attempt by anyone to conceal these things.
Malpractice at Lush also includes any activity which would result in non-compliance with our legal and ethical policies including the Ethical Buying Policy, Non-animal testing policy and anti-bribery policy for example. A full list of these policies can be found here.
If malpractice is discovered to have taken place, those responsible within the company will be subject to disciplinary procedures and appropriate actions will be taken.
Who does this policy apply to?
This policy applies equally to all employees of Lush around the world in every location, every contract type, role or position, whether you are new to Lush or have worked in the business for a long time. This policy also applies to anyone who has had any type of business relationship with Lush such as agency workers, volunteers, business partners, contractors, suppliers and their employees. This policy must be shared with every Lush employee in every global market.
The purpose of this policy
The purpose of this policy is to provide a mechanism for reporting, investigating and remedying instances of malpractice in the workplace which applies to our business and those in our supply chains. You can raise concerns at any time about an incident that happened in the past, is happening now, or you believe will happen in the future.
Protection and support for Whistleblowers
It is understandable that whistleblowers are sometimes worried about possible repercussions. As a company, we are committed to providing a safe place for our staff and everyone associated with Lush to speak up. We will ensure the protection of all whistleblowers who raise genuine concerns about any instances of malpractice as defined in this policy, even if such concerns result in no findings of malpractice. Many countries also have local laws that protect you when disclosing certain types of malpractice in the workplace.
Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, please report this to us immediately through the See Hear Speak Up web portal.
You must not threaten or retaliate against whistleblowers in any way. If any Lush employee is found to be involved in any such behaviour, you may be subject to disciplinary or legal action.
In the UK, Whistleblowers are protected by The Public Interest Disclosure Act 1998, if reporting the following acts of wrongdoing in the public interest. Under this legislation, you are protected to ensure you are not treated unfairly or do not lose your job because you ‘blow the whistle’.
How to raise a malpractice concern
We work with a confidential, third party global reporting service, SeeHearSpeakUp. SeeHearSpeakUp specialise in implementing effective whistleblowing solutions to businesses in a safe, secure and supportive environment to encourage whistleblowers to speak up and be heard.
Available 24-hours a day, 365 days a year, SeeHearSpeakUp provides an independent confidential hotline available in 217 languages and an online reporting tool to ensure that any malpractice concerns are brought to our attention in a secure and confidential manner. You can also contact SeeHearSpeakUp anonymously if you would prefer.
To make a whistleblowing report, please visit the web portal or contact the hotline on 0800 026 0466.
Whilst we would strongly advise that you raise malpractice concerns directly through this service, there are external authorities in each market who can also provide you with advice. Please visit your country’s government website for more information.
What happens next
After receiving your disclosure, we will confirm receipt within seven days. Once the detail of your disclosure has been reviewed, you will receive confirmation of whether the malpractice you have reported qualifies as a protected whistleblowing disclosure as defined by this policy.
We will then work with the relevant teams to conduct an investigation into the claims and communicate with you throughout the process.
The investigation may include interviews with yourself and anyone who is suspected of being involved in the malpractice. You are welcome to bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation. If you have requested to remain anonymous, this will be maintained throughout this process.
We will aim to update you on the progress of the investigation within the first month, and within 3 months at the latest. We may not be able to share all details with you due to confidentiality reasons, but will be able to update you on the status of the investigation and any agreed remediation plans.
Confidentiality
We hope that staff will feel able to voice whistleblowing concerns openly under this policy and will treat all disclosures in a confidential and sensitive manner.
If you have requested to remain anonymous, we will take all reasonable steps to ensure this is the case. If it is necessary for anyone investigating your concern to know your identity or if this would support the outcome of the investigation, we will discuss this with you first.
We will only disclose your identity without your consent if we are legally obligated to (e.g. criminal proceedings, fine proceedings, or judicial decision).
Protecting your data
As part of the whistleblowing process, we may be required to record your personal data, and we will therefore request your consent in order to proceed. We will only collect data that is relevant to the process (for example: name, shop, department or country, topic of disclosure, outcome) and it will only be held until the report has been fully investigated and resolved. After this time the information will be anonymised. It is important to note that Lush’s ability to fully investigate any claims might be limited if you choose to remain anonymous or decide not to give your consent for Lush to collect your personal data.
All personal data is minimised and held securely, while access is restricted to only those individuals who are directly involved in the whistleblowing process. For further information on how Lush handle your personal data please refer to the Lush Privacy Notice on the Lush website and the local Data Protection Regulations.
Consequences of breaches to this policy and false reporting
Failure to comply with this policy without good reason could result in formal action being taken against employees and in the case of non-employees, termination of the relationship/contract/agreement.
If after investigation, we conclude that a false allegation has been made maliciously or with a view to personal gain, you may be subject to formal action. In this case, it may not be possible to protect your identity from disclosure with relevant parties or authorities.
Status of this policy
This policy does not form part of the Lush contract of employment, and we reserve the right to amend it at any time. Updated versions will be made accessible to all employees and external parties on our website and internal Lush platforms.
*When a local law or legislation applies that may conflict with this policy, the higher standard will apply.
See Hear Speak Up Whistleblowing Phone Lines
APAC HELPLINE TELEPHONE NUMBERS
• Australia – 1 800 621 390
• Hong Kong – 01234 567890
• Japan – 0066331 32761
• Macau – 00800 9687 4357
• Malaysia – 1800 815 895
• New Zealand – 0800 446 198
• Philippines – 1800 1110 2032
• Singapore – 800 120 5513
• Korea – 00798 14 203 5427
• Taiwan – 0080 113 6354
• Thailand – 001 800 1100 3300
EMEA HELPLINE TELEPHONE NUMBERS
• Austria – 0800 006 652
• Albania – 00 44 121 629 0395
• Bahrain – 00 44 121 629 0395
• Belgium – 0800 74189
• Bosnia & Herz – 0800 83062
• Bulgaria – 800 83062
• Croatia – 0800 988 945
• Czech Republic – 800 023 118
• Estonia – 8000 100 718
• Finland – 990 800 9687 4357
• France – 0800 918 045
• Germany – 0800 000 8875
• Qatar – 00800 100 674
• Saudi Arabia – 00 44 121 629 0395
• Serbia – 0800 300 192
• Slovenia – 0800 83185
• South Africa – 0800 990 094
• Sweden – 0 200 883 702
• Greece – 800 848 1360
• Hungary – 06800 18894
• Ireland – 1 800 901 631
• Italy – 800 867 580
• Kuwait – 00 44 121 629 0393
• Lebanon – 0044 1224 379303
• Luxembourg – 800 21 031
• Macedonia – 0800 8 05 02
• Netherlands – 0800 022 2398
• Norway – 800 62 804
• Oman – 00 44 121 629 0395
• Poland – 00800 121 1495
• Portugal – 00800 9687 4357
• Switzerland – 0800 830 236
• Spain – 800 600 953
• UAE – 8000 178 171
• UK – 0800 026 0466
• Ukraine – +44 1224 080955
AMERICAS HELPLINE TELEPHONE NUMBERS
• Canada – 1 866 606 5211
• Chile – 1 2300 205 765
• Mexico – 800 681 1823
• USA – 1877 492 6399
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