We are committed to maintaining a responsible, ethical, and transparent business environment in which employees, contractors, suppliers, service providers, business partners, and other individuals connected with our activities can raise serious concerns without fear of retaliation. We recognize that timely reporting can help identify unlawful, unethical, unsafe, fraudulent, or otherwise inappropriate conduct before it causes further harm. Anyone who has a genuine and reasonable concern about serious wrongdoing connected with our business is encouraged to speak up and provide the information available to them.
This policy establishes a general process for submitting and reviewing concerns involving significant misconduct. Whistleblowing may include reporting conduct that appears to violate applicable laws, create serious risks to individuals or the environment, involve financial wrongdoing, misuse business resources, abuse a position of trust, or deliberately conceal improper activity. The purpose of this process is to provide an appropriate channel through which serious concerns can be brought to attention and evaluated in a fair and responsible manner.
A whistleblowing report is generally intended for matters involving substantial wrongdoing rather than routine workplace disagreements or ordinary customer service complaints. Personal disputes, performance concerns, interpersonal conflicts, workplace relationship issues, or individual employment grievances may be more appropriately handled through another available process. If a person is uncertain about the correct reporting channel, they may contact us for guidance so that the concern can be directed appropriately.
Matters that may be appropriate for reporting include suspected criminal behavior, fraud, bribery, corruption, theft, financial misconduct, improper accounting practices, serious breaches of legal requirements, significant environmental harm, forced or exploitative labor, serious health and safety risks, misuse of company property, conduct that may place customers or members of the public at substantial risk, and deliberate attempts to hide unlawful or unethical activity. Serious breaches of internal standards may also be reviewed when the circumstances justify further consideration.
A concern may relate to conduct that has already occurred, is currently occurring, or is reasonably expected to occur. A reporting person does not need to possess complete proof before raising a concern. However, reports should be made honestly and should be supported, where possible, by observations, records, communications, documents, dates, or other information that provides a reasonable basis for believing that a serious issue may exist.
The reporting process may be used by individuals who have a professional, commercial, or other legitimate connection with our operations. This may include current or former workers, temporary personnel, contractors, consultants, suppliers, professional advisers, service providers, and business partners. Individuals who become aware of serious conduct that may fall within the scope of this policy are encouraged to report the matter through the available communication channels.
Concerns may be submitted by email at lush@gmail.com or by telephone at 1-800-648-5415. Written correspondence may also be sent to 6244 CASTLEGATE DR W APT 9307, CASTLE ROCK CO 80108, US. When making a report, individuals should provide as much relevant information as reasonably possible. Useful information may include a description of the conduct, the people or organizations involved, relevant dates or locations, the circumstances that created the concern, and any documents or other material that may assist with an appropriate review.
Where legally and practically possible, a person may raise a concern without identifying themselves. We will take reasonable steps to protect the confidentiality of information received through the reporting process, subject to applicable law and the requirements of a proper investigation. Anonymous reporting may make an investigation more difficult because follow-up questions cannot always be directed to the reporting person. It may also limit the ability to obtain clarification or additional evidence. Nevertheless, a report will not be disregarded solely because the person providing it has chosen not to disclose their identity.
After receiving a report, the available information may be reviewed to determine whether further investigation or action is appropriate. Depending on the circumstances, this may involve reviewing records, examining relevant documents, speaking with individuals who may have information about the matter, assessing available evidence, or carrying out other reasonable inquiries. Each concern will be considered according to its particular facts, seriousness, scope, and potential impact.
Investigations will generally be conducted with appropriate care, objectivity, discretion, and respect for the individuals involved. The exact process may differ depending on the nature of the allegation and the information available. Where appropriate, additional information may be requested from the reporting individual. If contact details have been provided, we may communicate regarding the progress or general outcome of a review when disclosure is appropriate.
Confidentiality will be respected throughout the reporting process, although complete confidentiality cannot always be guaranteed. Information may need to be disclosed where required by law, necessary to conduct a fair investigation, needed to protect individuals or business operations, or otherwise permitted under applicable requirements. Certain investigative information, disciplinary decisions, personal details, or confidential business records may therefore not be available to the person who submitted the report.
We do not tolerate retaliation against individuals who raise genuine concerns honestly and in good faith or who assist with an investigation. Retaliation may include threats, intimidation, dismissal, discrimination, unfavorable treatment, inappropriate disciplinary measures, or other adverse conduct taken because a person made a legitimate disclosure or participated in the review of a concern. Anyone who believes they have experienced retaliation should report the matter promptly so that it can be assessed separately.
The reporting process should be used responsibly. Individuals are expected to provide information honestly and should not intentionally create false allegations, fabricate evidence, or knowingly provide misleading information. The purpose of this policy is to protect legitimate reporting and encourage responsible disclosure, not to provide a means for malicious accusations or personal retaliation. Deliberately abusing the reporting process may result in appropriate action where permitted by applicable law or contractual requirements.
Information collected during a whistleblowing review may include confidential or personal information. We will seek to handle such information only to the extent reasonably necessary for assessing, investigating, documenting, and resolving the concern. Access may be limited to individuals who have a legitimate need to participate in the process. Reasonable administrative and technical safeguards may be used to protect information against unauthorized access, misuse, alteration, or disclosure.
Records relating to reports may be retained for as long as reasonably necessary to complete an investigation, document actions taken, resolve the matter, satisfy legal or regulatory requirements, or protect legitimate business interests. When information is no longer required, it may be deleted, securely disposed of, anonymized, or otherwise handled in accordance with applicable retention requirements.
Individuals who choose to report anonymously should understand that anonymity may affect the ability to verify information or obtain additional evidence. Where a report contains sufficient information, we may still review the matter and determine whether further action is warranted. The absence of direct communication with the reporting person does not automatically prevent a concern from being considered.
Nothing in this policy prevents an individual from contacting an appropriate government authority, regulator, law enforcement agency, or other external organization where such reporting is permitted or required by applicable law. Local laws may provide specific protections, reporting procedures, confidentiality rights, or remedies for whistleblowers. Individuals should consider the rules applicable to their circumstances when deciding whether to make an external report.
Where a serious concern is substantiated, appropriate corrective measures may be considered based on the nature and severity of the matter. Such measures may include changes to business practices, additional controls, remedial action, further review, termination of inappropriate conduct, or other reasonable steps. Any action taken will depend on the facts, applicable obligations, contractual arrangements, and legal requirements.
We may periodically review this policy to ensure that the reporting process remains suitable for our operations and reflects changes in legal requirements, business practices, communication methods, and organizational needs. Amendments may be made when necessary to improve the effectiveness of the process or address developments in applicable law. Where mandatory legal requirements provide greater protections or impose different obligations, those requirements will take precedence.
Individuals who have questions about this policy, wish to discuss reporting options, or need to raise a concern may contact us at lush@gmail.com or 1-800-648-5415. Written correspondence may be sent to 6244 CASTLEGATE DR W APT 9307, CASTLE ROCK CO 80108, US.
We believe that responsible reporting contributes to a healthier and more accountable business environment. By providing a clear avenue for serious concerns, protecting good-faith reporters from retaliation, and reviewing reported matters with appropriate care, we seek to encourage transparency, integrity, and responsible conduct throughout our business relationships and operations.