What do I do if I think there's been a breach to the Ethical Charter?
We all play a role in ensuring our values are protected through the Ethical Charter. Our EBT Trustees have a role as guardians of the ethics to ensure that the company remains compliant with our commitments in the CW Ethical Charter.
If you or someone in your team think that CW is ever in breach of the Ethical Charter it is your responsibility to report this immediately to the Trustees directly at ebt@lush.co.uk.
What happens after I report a potential breach?
There is a process in place that would trigger an immediate investigation by the Trustees and depending on the outcome of the investigation, there are a series of next steps to be followed to ensure a transparent and thorough investigation and remediation plan. This may include:
➜ Providing the anonymised reported breach
➜ Considering any previously reported breaches of a similar nature
➜ Oobtaining any additional and relevant contextual information from other departments
How long will it take to make a decision about a reported breach?
We're unable to provide an estimate as to how long it will take to make these decisions. It relies on a number of factors including how quickly information can be gathered, when the Trustees are able to regroup for discussion and if any further investigation is required.
The EBT team will keep you informed about your reported breach whenever possible.
What happens if the Trustees can't decide unanimously?
If the Trustees can't unanimously decide on if there is a breach of the Ethical Charter, they can form the Ethical Charter Committee.
When do the Ethical Charter Committee convene?
If any Cosmetic Warriors Employee in any country where Cosmetic Warriors operates raises a concern that any of the core values or principles in this Ethical Charter are not being adhered to by Cosmetic Warriors, (unless they reasonably consider that concern to be unfounded or sufficiently minimal that it does not amount to a breach of the Charter), the EBT Trustees shall convene a committee (the Ethical Charter Committee) to decide whether or not the actions, proposed actions or inactions which are the subject of that concern amount to a legitimate risk of a breach of the Ethical Charter.
Who makes up the Ethical Charter Committee?
5 Cosmetic Warriors employees, selected at random.
The committee will be chaired by an EBT Trustee who will not have a vote.
The EBT Trustees will as far as possible provide the Committee members with all the information on the relevant Cosmetic Warriors activities in relation to the core value brought into question which they will reasonably require to make that decision.
The Committee will then decide by a simple majority vote whether or not Cosmetic Warriors is operating within the spirit of the Ethical Charter:
if the Committee decides that the company is operating within the spirit of the Ethical Charter, then no further action will be taken; but
if the Committee decides that the relevant company is carrying on its activities in such a way that it amounts, or is likely to amount, to a breach of the Ethical Charter the EBT Trustees will inform the Board of Directors of Cosmetic Warriors Limited (or any other company which may be the parent company of the Lush Group at the relevant time) (the Board) of the breach or likely breach and the Board will, as far as reasonably practicable, take the views of the Committee into account when deciding what action to take in response to the breach or likely breach.
If at any time the Ethical Charter Committee is convened, the EBT Trustees will notify all the Employees then on the payroll of Cosmetic Warriors at that time of the concern it was convened to consider and the decision made by the Committee.
Find out more
If you believe we are in breach of the Lush Ethical Charter in any area of the business, you can contact our EBT Trustees via the EBT Team at this email address.
See if any of your business questions, concerns or ideas have been answers already