Combating modern slavery 2020/21

2020/2021 Statement – Combating Modern Slavery

Introduction 

‘Modern Slavery’ is the phrase used to describe the crimes of human trafficking, slavery and slavery-like practices such as servitude, forced labour, forced or servile marriage, the sale and exploitation of children, and debt bondage. A common thread runs through all of these offences: they involve one person depriving another person of their liberty, in order to exploit them for personal or commercial gain.

It is a sad truth, that the impact of the Covid-19 pandemic on the progress of the eradication of modern slavery has been momentous. Manufacturing across the globe was drawn to a halt, resulting in cancelled orders and disruption to supply, workers being placed at risk of losing their livelihoods, and restrictions on movement of both workers and visitors limiting the efforts of anti-slavery organisations.

“As with previous economic crises, the sharp increase in unemployment rates brought about by the COVID-19 pandemic is likely to increase trafficking in persons, particularly from countries experiencing the fastest and most persistent drops in employment. Job seekers from these countries are likely to be more willing to take high risks in the hope of improving their opportunities.” –  UNODC, Global Report on Trafficking in Persons 2020 

Finding a reliable way to measure the full magnitude of modern slavery is universally acknowledged as a complex and challenging issue; with no one source being able to identify a single number. The varied nature and forms in which Modern Slavery can be defined are vast, and the level of sophistication of the systems which have been developed to ensure that those who encourage or facilitate these horrific crimes remain undetected is sadly increasing.

 

38% of detected modern slavery victims were trafficked for forced labour

-UNODC, Global Report on Trafficking in Persons 2020  

 

Whilst some forms of Modern Slavery are overt, there are also much more subtle forms of coercion and control. Situations where a victim’s vulnerability or lack of choice has been abused; where there is a hold over family back home through debt; or where the threat of deportation deprives them of any real freedom and choice.

This, our sixth Modern Slavery Statement, has been published in accordance with the UK Modern Slavery Act (2015). Section 54 of the MSA requires every organisation with a global annual turnover of £36 million or more, which carries out business (or part of a business) in the UK, to produce a slavery and human trafficking statement for each financial year. Lush’s financial year runs from July to the end of June. 

Since our last statement, on June 15 2021, a UK Modern Slavery (Amendment) Bill was proposed in the House of Lords. The Bill proposes additional disclosure and substantive compliance requirements and would establish penalties for non-compliance with selected aspects of the Act. 

Lush welcomes this amendment, which was the UK Government’s response to both a public consultation launched in July 2019 and an Independent Review commissioned by the Home Office in 2018 to assess the effectiveness of the Act. The public consultation had sought views from businesses, public bodies, investors, and civil society on a range of options to strengthen the Act’s transparency requirements.

The Government accepted several of the recommendations of the Independent Review and committed to making key changes to the Act, including the following:

• Mandating the specific reporting topics that statements must cover
• Requiring statements be published on a new Government-run modern slavery statement registry. (It currently is voluntary to post statements on the registry, however posting is encouraged, and the Lush statement can already be found here)
• Setting a single reporting deadline for statements
• Introducing financial penalties for subject commercial organisations that fail to meet their obligations under the Act’s transparency provision

In addition to the UK Modern Slavery Act, and its amendments, similar legislation has been introduced in other parts of the world. These include the California Transparency in Supply Chains Act (2010), French Duty of Vigilance Law (2017) and Australian Modern Slavery Bill (2018). 

As we have manufacturing operations within Australia and California we have written dedicated statements on tackling Modern Slavery within these markets.

Many countries in which we operate do not yet have legislation in place, but are either debating or have already reached agreements on mandatory human rights regulations. These include Germany (Human Rights Supply Chain Duty of Care Act), Canada (Bill S-216, an Act to enact the Modern Slavery Act and to amend the Customs Tariff) & the EU, who have published “Guidance on due diligence to help EU companies to address the risk of forced labour in their operations and supply chains.”

As a global, progressive business we always seek to go above and beyond the legislation within the countries that we operate, and are striving for global alignment. 

This statement details what Lush is doing to combat the risks of modern slavery and human trafficking within our own business and our supply networks. The statement also provides an update on the activities and commitments detailed in our previous (fifth) Modern Slavery Statement and the steps taken during our financial year July 2020 – June 2021. 

Also included is an update on some of the actions Lush have taken between July 2021 – November 2021 as some of our programmes were delayed due to the ongoing impact of the Covid-19 pandemic. Finally, it outlines Lush’s commitments towards mitigating the risk of modern slavery in our supply networks and business going forward. 

 

Our business – Organisational Structure

Lush is a UK cosmetics brand, with its head office in Poole and an additional office in London. Lush was started in 1995 by a close-knit team who have continued to work together for over 40 years. The first Lush shop opened at 29 High St, Poole in April 1995, with products being made in a small space above the shop. Lush places emphasis on the benefits of using the finest quality fresh, natural ingredients in our products for their nutritious effects on the body and mind. We strive to ensure our products reach our customers in the freshest condition, when they are most potent and effective – it’s at the heart of our philosophy. We use ingredients such as fruits and vegetables, herbs, flowers, butters and essential oils – organic wherever possible – and with minimal synthetic preservatives. All products are vegetarian, and the majority are vegan too. 

Lush’s global expansion, whilst rapid, has been carefully controlled. More than 25 years on, Lush has over 100 stores in the UK, 900+ shops worldwide and is present in 47 countries, with manufacturing operations in 6 countries (UK, North America, Germany, Croatia, Japan & Australia), employing around 14,000 people during peak production. We also have Lush Spas in select locations across the UK, France, Korea, Japan and Spain. We invent, manufacture and retail our own range of unique products so that we can be confident that our beliefs and ethics are carried through at all stages. 

We are very proud to offer a range of fresh, handmade cosmetic products which are all manufactured in house and sold through our retail shops, digital channels and collaborative partners.

Lush prides itself on its innovation and creativity, and therefore the number of products we produce is constantly evolving. An average of over 900 product lines (this includes size variations) were made at our UK manufacturing sites during 2020/21 per month. This includes all year round products and seasonal ones. 

The Lush business is run in accordance with a set of founding ethical principles written by our founders at the very beginning of Lush’s life, commonly known as our ‘We Believe Statement’. These principles underpin all that we do and run through every vein of our business.

Lush further sets out its core values or principles in the Lush Ethical Charter. 

As mentioned in last years report (FY 19/20), we have adopted the Stronger Together Framework for actioning our response to modern slavery, and you can see our progress against this below.

 

Our Business & Our Supply Networks

Lush products are for sale in our shops, on our website and through our carefully selected 3rd party partners. They are invented in-house and manufactured by our own factories. The Creative buying team manages the supply networks of our product and raw material suppliers who are selected based on ethical, sustainable and commercial criteria, and are supported by the integrated ethical compliance team.

Product supply networks are complex, involving a number of different processes; and Lush’s supply networks are no exception. Although we try wherever possible to buy as direct to source as we can, most supply networks are made up of several tiers stretching over numerous countries. We source around 1400 materials from more than 80 countries globally, with an annual buying spend of £45.8m (Lush UK).  

We have many supply networks that contribute to the operation of our business and as the Lush business continues to grow in size, so do our supply networks. For example, our raw materials are sourced from a global network of over 600 suppliers who help to support our global manufacturing operations. This number continues to evolve as we discover new materials, meet new suppliers and source materials to meet the growing business needs.

We are committed to sourcing and developing top quality, ethical materials for our products through a resilient global network and we also grow materials ourselves via agricultural projects and direct partnerships around the world. From the early days of buying we learned from the adulteration of our essential oils, that it is vital to gain an understanding of each material, from who is involved in its supply to the local impacts of its production in order to ensure top quality ingredients with no exploitation at any stage.  

As a business, we realised that we could have both a positive and negative impact through our business operations. Due to this, we have aspired to maximise the benefit of our actions, relying on positive and open relationships with our suppliers and producers to find a path to a truly ethical and sustainable business that will last into the future.

Our vision is that each and every ingredient we purchase is contributing to a positive future. We are already building a web of like-minded pioneers who wish to become part of the answer to the problems we all see every day. Through the ingredients we buy and through the people we meet and partner with, we are finding that some of these answers come through reciprocal trade. That means finding ways in which we can grow, produce, manufacture and ship our goods that are truly sustainable. In fact we have ceased to aim for just sustainable, but wish to reach beyond that to regenerative – making sure that our purchases put back more into the soil, to the community and the natural world than they take out, and at the same time provide profit and a viable business for all of us. We want to leave the world lusher than we found it. 

 

The Impacts of Covid 19 on Modern Slavery

The rapid spread of COVID-19 in 2020 prompted shutdowns of industries around the world, and, while most consumers were in lockdown, lower demand for certain products, and inability to access these, significantly reduced the need for production of some products. 

As a maker of soap products, Lush manufacturing was classed as an important industry, but sadly our retail outlets were not. Therefore whilst our stores were closed, we focused our efforts on serving our customers via our digital channels. 

Without the ability to visit our sites, we had to think of ways that we could connect with our supply network without physically being there. One of these methods was to utilise our existing software Supply Shift, to make contact with our suppliers and to understand the impact on the ground. We go into detail around how we used this information to support our supply network during this difficult time in the “Act” section of this report. In summary, this information request was sent to over 300 of our suppliers, and we received 162 responses.

Another notable impact that Covid had was on the fluctuation, both the decrease and excessive increase, in demand for particular products. As Lush uses many natural ingredients such as seeds, beans and butters that are also sources of food, we were fortunate that despite our need for materials decreasing, the majority of our suppliers (with 63.6% of the suppliers who responded to our Covid 19 Impact survey) stated they were able to maintain their business levels, or increase them through other channels. 

One commodity that faced extreme stresses on it’s supply network was nitrile gloves. Since the start of the pandemic, demand for medical gloves has rapidly increased and over 1.8 billion gloves have been provided for use in health and social care in England. The excessive need for PPE raised many concerns around the conditions in which these gloves were made. 

Allegations linked to poor working conditions and also bonded labour have been made public by several notable bodies; highlighting the restriction of movement and cramped conditions that contributed to extensive outbreaks of Covid 19 within multiple facilities. The reports also outline restrictions on movement, isolation, abusive working conditions, and excessive overtime.

We decided that as a user of this type of glove in our manufacturing facilities, we must address the allegations with our own supplier regarding the working conditions at their  facility. Following our investigation, we have decided to move our business to an alternative provider as no evidence could be presented to Lush to show that adequate efforts were being made to prevent forced labour. This has also led to ongoing workshops around how we can provide better guidance to our other team members  around the business on what information they should assess before partnering with a new supplier.

 

Our Commitment – Policies and Processes

We have several policies in place that help us to enforce the standards set to mitigate the risk of Modern Slavery and also encourage disclosure of any such practices within our business and throughout our supply networks. These policies are reviewed, communicated to and acknowledged by new and existing suppliers and also communicated to all Lush business partners. As a minimum requirement we ask all of our suppliers to acknowledge and comply to the following policies / documents (in addition to our strict Non Animal Testing Policy and declaration): 

Our Anti-Slavery & Human Trafficking Policy

This policy, updated in June 2021, clearly defines Lush’s position on Modern Slavery and sets the minimum standards that we expect all of our suppliers to comply with to ensure the fair treatment and well-being of all workers within our supply network. 

This policy applies to everyone working for us or on our behalf in any capacity, including employees, directors, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, suppliers, third-party representatives and business partners. Anyone who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Our Modern Slavery Remediation Policy

In FY 20/21, we published publicly our Modern Slavery Remediation Policy. Lush recognises the responsibility that we share with our suppliers to provide remedy to victims of slavery. Successful remediation is not easy to achieve and requires a victim-led, consultative and multi-stakeholder approach. 

The Lush remediation policy is drawn from best practice guidance on remediation and builds on the requirements of International Labour Organisation Conventions, Protocols, Recommendations and Instruments such as the Declaration on Fundamental Principles and Rights at Work and the Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy, the UN Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, and the United Nations Guiding Principles on Business and Human Rights. The policy is intended to provide a practical framework for us as a businesses to apply remedy, should we encounter victims of slavery in our business or in our supply chains. 

Our People Care, Earth Care and Fair Share Buying Policy

These buying policies consist of legal requirements, non-negotiable standards and progressive standards. Within Section ‘4.0 Legal Obligations’ of this policy we make supplier aware of the following: 

4.1 Suppliers must adhere to all relevant legal obligations and all relevant Lush policies. These policies include our ‘Anti-Slavery & Human Trafficking’, ‘Anti bribery and corruption policy’, amongst others, which can be found here: Anti bribery and corruption – We Are Lush

4.2 Suppliers must have systems in place to review and adhere to their legal obligations under regulations such as The UK Modern Slavery Act (or any other legislation designed to combat modern slavery and offences relating to trafficking and slavery), The Human Rights Act, The Nagoya Protocol, tax and environmental laws and where relevant and 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 also included the ‘employer pays’ principle in our policy document last financial year (2019/2020). 

The People Care, Earth Care and Fair Share Buying Policy helps us to ensure that our supply networks match our core values. 

Our Whistleblowing Policy

We have been working on developing a new Global Whistleblowing Policy which was shared with all Lush employees this year. 

The policy enables employees and anyone else to report any illegal or unethical malpractice that might be witnessed within our business or supply networks while remaining anonymous and protected by law against any mistreatment for reporting your concerns.

By encouraging a Whistleblowing culture, we can continue to promote transparency and empower our staff and those in our supply networks to help monitor and maintain our high ethical standards in every corner of the Lush business.  

This is a global policy that must be adhered to by all Lush businesses and made available to all Lush employees. 

Our central whistleblowing email address ‘[email protected]’ is monitored by our Lush UK People Experience Team and whistleblowing cases will be investigated and resolved in the shortest time possible. 

Breaches to these policies are not taken lightly. Where there is opportunity to influence change we will work hard with our suppliers to do so, but we will not hesitate to cease trade with any organisation where breaches of our policies are severe. 

 

Assess – Understanding the Risks

The risk of modern slavery lies everywhere; in all tiers of a companies supply network and within their own operations. For Lush, one of the sources identified as being high risk was mica, which is why we have moved away from sourcing natural mica and consequently made the decision to go completely natural mica-free as of January 2018. 

We utilise a variety of tools within the business to help us understand our supply chain risks.

Buying Policy Survey

This year (2019/20), we have further strengthened our internal processes in order to be able to monitor and address modern slavery risk as best as we can. In addition to rolling out the most updated version of The Lush People Care, Earth Care and Fair Share Policy to the UK and key suppliers in the Global markets, we issued an interactive questionnaire to dive deeper into our suppliers practises. 

The People Care survey, which, like the Buying Policy, is based on the Ethical Trading Initiative Base Code and International Labour Organisation’s Fundamental Conventions, was sent out to all suppliers in September 2020.  It defines the minimum standards we require our suppliers to adhere to. The policy includes a prohibition of forced, bonded or involuntary labour and also covers these areas: 

• Employment freely chosen 
• Freedom of association and the right to collective bargaining
• Safe & hygienic working conditions 
• Child labour 
• Legal minimum wages and legally mandated benefits 
• Working hours 
• Discrimination 
• Regular employment 
• Harsh or inhumane treatment 
• Home working & subcontracting 
• Use of Genetically Modified Organisms 
• Environment and biodiversity 
• Chemical management practices 
• Animal Welfare in Agriculture 
• Soil Health 
• Highly Hazardous Pesticides 
• Forestry Management 
• Fair Share 
• Legal Obligations 

The survey was scheduled to be sent out much earlier in the year but due to the Covid-19 outbreak we had to change our approach. We did not feel it was right to request lots of information from suppliers at a time where many businesses were forced to operate at a limited capacity and in some cases, close completely.

Mined Materials

Further to our decision to stop using Mica, this year we have further analysed our portfolio of raw materials to assess the modern slavery risks for other high risk mined materials. Lush uses several mined materials within its products, such as Kaolin, Calamine and Talc. These products are integral to our formulas, and we decided to act in order to further transparency and understanding within these supply networks. 

After forming a working group with all interested stakeholders & suppliers, we conducted a pilot transparency mapping exercise to further understand the complexities of sourcing this material, and the conditions at the mining source. We are currently in the process of putting together an internal policy on purchasing practices around mined materials, developing a process of identifying risk in different countries and comparing practices for different mined materials. We hope that this policy will be made publicly available in FY 21/22.

Palm Oil

Our focus on the palm industry began in 2006 when we realised what destructive environmental practices are involved, but we also now regard it as a high slavery risk. “Non-governmental organisations (NGOs) and unions report that even plantations that have been certified as ‘sustainable’ often show signs of child labour and forced labour” (Greenpeace, Final Countdown Report, 2018). Lush is still in the process of identifying and eradicating the last remnants of palm from our supply networks. Last year we reduced the % weight of palm derived materials used in manufacturing from 9.6% to 7.9%, and the full details around our reduction of palm oil derivatives can be found in our 2020 palm report.

Supplier Management Software & Risk Indices

In May 2019 the business decided to introduce the use of a supplier management software solution that helps to automate ethical sourcing practices across global supply networks. Within the software, it has the ability to support:

• supply networks mapping
• supplier benchmarking
• risk analysis
• reporting
• gaining more transparency 

It’s a tool that has supported the Lush buying team to visualise the supply networks and allows for more responsible and productive decisions to be made. 

The use of this software helps us to raise standards and enforcement measures throughout our supply networks, encourage disclosure, enable us to review policies & get acknowledgment of our policies from suppliers annually, benchmarking suppliers & tracking progress over time, help us decide where to utilise the help of third party auditing and set development targets for suppliers who might not meet our buying policy standards yet. 

Further to the above, we have also continued our relationship with a global research house and data analytics organisation that helps with data modelling, risk analysis & forecasting at country and industry level. This enables Lush to have access to 10+ years of data spanning 200 risk indices across 198 countries.

Since publishing our last modern slavery statement we have successfully implemented these systems and used them to send out the Covid-19 Survey (Apr 2020) & People Care, Earth Care and Fair Share supplier assessments (Sept 2020).

We received 123 responses to our People Care, Earth Care and Fair Share policy (which covered over 64% of the FY 20/21 spend) that helped us to provide appropriate assistance, training and support to suppliers.

Where possible, we work directly with suppliers and producers, but even without complex supply networks, we know that long distance relationships take work. This is why, under normal circumstances, we conduct regular visits to our overseas (and UK) suppliers to see their operations. Due to the global pandemic this has not been possible to the same extent as previous years, but as soon as travel restrictions ease, our buyers will take the information gathered from our online survey along to these visits, as it forms a good basis for an internal audit. 

 

Act – Taking Action 

Covid-19 Impact Assessment

Covid-19 has had a profound impact on the world but it has also created more challenges for people. It has increased vulnerability to slavery, worsened discrimination, increased risks for migrant workers and disrupted anti-slavery efforts. Human Rights protections have been lower for example when we look at India, where a number of labour laws have been relaxed in response to the pandemic. 

The impact on the supply networks was exacerbated further by the restrictions placed on the movement of people, and therefore migrant workers, and also the lack of ability from NGO’s and Retailers to maintain their presence within manufacturing sites. Workers, and especially migrant workers, may have personal and professional circumstances which do not allow them to socially distance, work at home or take a day off without pay, making them especially vulnerable. 

As a business, we wanted to understand the deep impact that Covid had on our supply chains, and if there was anything that we could do to help alleviate some of the pressure. We devised an Impact Assessment around Covid-19 which was issued to over 300 UK primary and lower tier suppliers, of which 162 responded.

The topics covered within the questionnaire covered Supplier dependency, Operational impact, Employee welfare and Covid response. From the responses that we received (43%) we were able to highlight suppliers that were in need of assistance more than others.

We worked to understand suppliers that were more vulnerable, and in some instances improved our payment terms or paid partially in advance. We also offered practical support where it was needed, funding PPE (mask & sanitation stations) and provided preventative training for women’s collectives growing some of our ingredients. We also provided emergency support for some of our suppliers in India, totalling around £24K)

Training and Raising Awareness

Internal Training

Around 14,000 people work for Lush globally (9,186 Lush Group Employees, not including Partners) – even more around peak times like Christmas when we recruit seasonal staff. We want all employees to have an active and engaged understanding of the risks of modern slavery to our business. We started our training programme in 2018, and since then have expanded this to a wide variety of departments and colleagues across the Lush global business.

We have organised sessions for individual teams and hosted a virtual session on modern slavery, which was recorded to maximise accessibility. With this experience, our staff are more likely to identify possible warning signs and raise issues if a supplier looks like they might be slipping below our expected standards.

This reporting year, we have hosted sessions for People Team (7th June), Recruitment (17th August), Procurement (8th September) and our Raw Materials and Packaging buying team. The Modern Slavery training has taken the same approach as our Respect at Work training programme with Managers being trained as a priority and passing messages to their teams.

To date (November 2021) we have trained the majority of Managers in Manufacturing (49), Support (113) and Retail (74) UK.

Talking about Modern Slavery

Communicating and keeping Modern Slavery at the forefront of people’s minds is key to making sure that we are constantly doing everything we can to try and eradicate this horrendous practise. We do this through a variety of channels which are accessible internally, to our supply network and publicly too.

• Our Anti-slavery and Human Trafficking policy and Modern Slavery statements are published on our website where staff, suppliers, customers and anyone with an interest can read about the risks to our business and the steps we are taking to combat modern slavery.
• We also have also created an internal document called the Modern Slavery Handbook (action taken after FY 20/21), which provides resources and materials created by Lush, as well as information provided by external organisations which campaign to eradicate modern slavery on a global scale. This was distributed in a follow up email to anyone who completed the online training. The document is comprehensive and covers topics such as: What is Modern Slavery, Our Obligations & Policies, Spotting the Signs, Reporting and Incident, and several external resources.
• The importance of eradicating modern slavery, and the importance of raising awareness of this key issue was also included in the “Upholding of our Ethics” section in our employee magazine, Lush Insider in June 2020.

 

Further to the above documents and policies, we have also explored more interactive options for supplier training and successfully hosted two virtual supplier conferences with the title of ‘ A collaborative approach to tackling modern slavery’ on the 5th November 2020. 

These two one hour sessions were co hosted alongside Stronger Together and broached the following topics:

• Where Lush stands from a policy point of view
• An overview of what Modern Slavery is – what is the problem globally, in the UK and in different sectors
• The UK Government’s & International Response – a businesses’ responsibility to tackle modern slavery
• Who are the victims, how are they exploited and where?
• Next steps and further resources

A total of around 110 suppliers were able to join the live sessions and a recording was shared with everyone who was unable to attend. 

In addition to training we have also participated in public discussions around modern slavery.

The Lush board of directors have overall responsibility for ensuring Lush’s compliance with the Modern Slavery Act and that all those under our control comply with it. Management at all levels are responsible for ensuring those reporting to them understand the issue of modern slavery and comply with this policy.

Lush also has a whistleblowing email address ‘[email protected]’ which is published on the Lush website. This is also communicated to all Lush UK employees via their electronic payslips, to all Lush employees via the global roll out of the whistleblowing policy and to all suppliers via the Lush People Care, Earth Care and Fair Share policy and several other means, to raise awareness. 

Operational Performance Assessment

Lush has previously used the Stronger Together Organisational Performance Assessment to self-assess how well we tackle modern slavery and hidden labour exploitation as a business (action taken during FY 19/20). The assessment was delivered by a trained and approved business and human rights expert consultant and provided independent verification of our company’s progress in tackling modern slavery. 

The OPA has been developed to support companies to evaluate their progress in tackling modern slavery and to inform their next steps to improve the scope and effectiveness of their programmes. The OPA analyses gaps, reports on strengths and provides detailed recommendations and action plans to support a business to make further organisational improvement. 

The framework covers six steps: 

• Commit – Make a public commitment to tackle modern slavery 
• Assess – Understand modern slavery risks in your business and supply networks 
• Act – Take action to deal with identified risks 
• Remedy – Provide a solution for victims of slavery 
• Monitor – Monitor progress 
• Communicate – Tell people what you have done 

We have used the output of this assessment to form a framework for this report, but also to guide us with a list of areas we wish to strengthen. We have another assessment planned for the coming year, (FY 21/22) and hope that we can conduct this on a global scale across all manufacturing operations.

 

Remedy – Provide a solution for victims of slavery 

We have two main channels through which we would receive potential violations or incidents for concern; via the whistleblowing hotline, or during our own investigations of our supply network.

As part of our aforementioned remediation policy, we have identified a structure for dealing with these incidents. The Lush process for responding to violations will be to:

• Conduct an initial assessment of the allegations to ensure that there is sufficient information to understand the exploitation discovered and remedy it.
• Ascertain if a supplier or labour provider is implicated.
• Report the allegations to relevant authorities.
• Capture evidence about the violations, using an independent third party if necessary. 
• Gather information from those affected.
• Take immediate steps to correct the situation for the worker, which will need to be tailored to their individual circumstances. This could include provision such as housing support, legal assistance, medical care or psychological support. 
• Compensate the victim or restore their situation to before their ordeal took place, including for those found to be a victim of modern slavery within the Lush network, internal colleagues or supply chain. This could be in the form of:
• Where possible, contribute to programmes and projects aimed at providing victim support.
• Work with local authorities and competent local organisations to provide assistance (on the express consent of the victim).
• Review progress over a suitable time period and verify that progress with local authorities and local organisations.
• Document remedial steps taken (see Remediation Reporting Tool).
• Build learnings into remediation procedures and operational procedures to prevent re-occurrence.

In FY 20/21 we had a total of 5 number of instances that required investigation, received either directly to our customer care teams, in store, or via the whistleblowing hotline.

Whilst the low numbers of reports is in some ways reassuring, we cannot be complacent and have identified that the awareness and accessibility of the Whistleblowing hotline is something that we wish to refine in FY 21/22.

Monitor – Monitoring Our Progress 

We use key performance indicators to measure how effective we’ve been in combating slavery and human trafficking in our business and supply networks.

In September 2020, we launched the first set of surveys in our supplier engagement platform Supplyshift, this platform allows suppliers to review and agree to our People Care, Earth Care and Fair Share Buying Policy and self-assess their organisation against the criteria covered within the policy.  

There were 247 suppliers who were invited to contribute, with 123 providing responses to our supplier survey. These responses accounted for 64% of raw material and packaging spend. (Lush UK, £45.8 million FY 20/21)

These are the Quantitative & Qualitative indicators that we highlighted that we wished to measure in last year’s report. Here are the first figures for FY20/21 calculated from these responses:

 

KPI	Result FY20/21	Additional Comments
Number of high-risk suppliers based on assessment responses	13.82%	Calculated using aggregated scoring from our People Care Assessment
Percentage of suppliers who have a high risk modern slavery rating based on assessment responses	10.57%	Calculated using aggregated scoring from our People Care Assessment
Percentage of suppliers who have had a third-party ethical/social audit	22.76%	Calculated from the number of suppliers who responded “Yes” to the question
Percentage of audits raising non-conformances related to modern slavery	0%
Percentage of modern slavery non-conformances closed within the timeframe stipulated	100%	No non-conformances were raised.
Percentage of suppliers that have a grievance mechanism in place	81.3%	Calculated from the number of suppliers who responded “Yes” to the question: “Do you have a process in place for workers to report a grievance regarding labour conditions?”
Number of suppliers who are aware of modern slavery and taking steps to manage modern slavery risks	85.37%	Calculated from the number of suppliers who responded “Yes” to the question: “Has your company implemented a policy, code of conduct or standards to assure that your operations are free from forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons?”
Number of suppliers that have made a commitment to tackle modern slavery, for example through a code of conduct or CSR report?	46.34%	Calculated from the number of suppliers who responded “Yes” to the question: Does your company conduct internal risk assessments/audits of your operations and activities to identify, prioritize, and mitigate the potential risks of forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery, or trafficking of persons?
What percentage of our tier 1 engages with labour providers	17.89%	Calculated from the number of suppliers who responded “Yes” to the question “Are workers obtained through the use of third party labor recruiters and/ or labor brokers?”
Level of engagement of high priority suppliers	68%	Calculated on the top 50 suppliers by spend in FY 20/21

 

We also had a number of KPIs that were focused more on our other internal actions such as training and development internally. More details around these can be found throughout the report, however the below provides an overarching summary.

Percentage of suppliers trained in preventing/identifying modern slavery	19.68%	Calculated from the number of suppliers from last years spend data vs attendees to webinar
Number of projects and collaborations established to prevent and address risks in our supply networks	3	We have 3 active projects covered in the Act section of this statement including two working groups (Mined Materials, Paper) and a partnership with Stronger together.
Stakeholder feedback on efficacy of forced labour strategy	N/A	This KPI is to be addressed in FY 21/22 as we wish to partner it with the next supplier assessment.

 

Communicate – Talking About Modern Slavery

It’s been said that Lush is like a campaigning organisation fronted by a soap shop. We are active and vocal about the issues that we care about, and use our shop windows and website as a way to highlight them. 

Lush generally don’t enter awards for our ethical practises or campaigning because we are not doing work in these areas for marketing purposes  or acclaim.  Where we have received awards this has been because we have been nominated by others. 

 

Supporting Human Rights Charities

At Lush, we like to look after those who look after others, and we are committed to supporting small, grassroots groups and other non-profit Human Rights organisations.

Globally we have made 389 donations to Human Rights groups from our Charity Pot Sales in FY2021 (including groups supporting migrants, refugees and groups tackling slavery and human trafficking) – £1.8 million were donated in total to these groups. In the UK alone we have made 128 of these donations totalling £384K. 

Breakdown of donations by cause 

Via other funds (Product Campaigns) during FY 20/21 we have donated £169k to Human Rights groups of which £20k went to groups working with refugees and asylum seekers. 

A full list of the charities we have supported can be found on our website at: https://uk.lush.com/article/donations-human-rights-groups

We encourage Charity Pot applications from all Human Rights organisations through our website.  Please see our Charity Pot Guidelines for more information: https://www.lush.com/uk/en/a/charity-pot-funding-guidelines “

 

Requirements

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 30/06/2021. It has been issued on behalf of the Lush Group, approved by the Lush board of directors on the 20th December 2021 and covers all UK Lush Entities including Lush Ltd, Lush Retail Ltd, Lush Manufacturing Ltd and Lush Cosmetics Ltd.

Signed: Hilary Jones, Ethics Director

Date: 20th December 2021

 

Finding help in the UK & Further Afield

If you or someone you know is being or has been exploited or you are unsure if someone is in need of help, assistance and advice is available:

• for life-threatening emergencies, call 999, or for non-emergencies, call 101 for the police
• Modern Slavery Helpline can be called on 08000 121 700 or contacted via an online form
• Victim Support can be called on 0808 16 89 111 or contacted via an online form
• Crimestoppers can be called on 0800 555 111 or contacted via an online form
• Migrant Help can be called on 0808 8010 503
• The Salvation Army have a 24/7 confidential referral helpline, which can be called on 0800 808 3733