INTRODUCTION
The LUMENE Group of companies, hereinafter referred to as the “LUMENE Group” in this Partner Code of Conduct, refers to the companies controlled by Lumene Holdings Oy (Business ID 2377938-7), including Lumene Oy (Business ID 2377940-8) and its subsidiaries Cutrin Oy (Business ID 2443709-8) and Lumene North America LLC (registration number 20-4349663). This code of conduct is applicable to all suppliers, service providers, partners and other third partieswith whom we co-operate and have a business relationship (individually a “Partner” and collectively, “Partners”).
The LUMENE Group comprises two internationally recognised brands, LUMENE and CUTRIN. LUMENE is a holistic beauty and well-being company focused on high performance skincare and face make-up products, while CUTRIN is a Nordic professional hair care brand tailored to meet the specific hair and scalp needs of Nordic men and women.
The LUMENE Group prides itself on its uncompromising expertise, research, and product development capabilities, which combine the latest technology with potent local arctic ingredients, sourced sustainably and preferably from the side-streams of local industry. We manufacture approximately 85 % of our products in Finland and employ 350 people across multiple geographies.
The beauty philosophy of the LUMENE Group is rooted in Nordic culture and values and has a close relationship with pure and diverse Nordic nature. Our aim is to commit and contribute to a sustainable future for beauty, with a fully comprehensive approach towards circular economy and with climate actions focusing on reduction of greenhouse gas emissions and promotion of biodiversity.
The LUMENE Group is committed to conducting its activities in accordance with all applicable laws, regulations, best practices and principles set out in international conventions in particular with regard to ethics and business integrity, labour and social responsibility, and protection of the environment. Therefore, the LUMENE Group expects its Partners to act accordingly and be committed to this Partner Code of Conduct and the principles set out in the United Nation’s Global Compact and in relevant international conventions such as the Unites Nation Declaration of Human Rights and the Conventions of International Labour Organisation, as well and to ensure that their own partners also do the same when conducting business with the LUMENE Group.
The LUMENE Group believes that cooperation is the cornerstone of positive change. We select our Partners carefully and engage in collaborative and open communication with them. We also expect our Partners to comply with the sustainable operating principles relating to ethical, social, and environmental aspects set out in this Partner Code of Conduct, thereby ensuring responsible procurement, and enabling the LUMENE Group to work towards achieving its sustainability objectives, and ultimately towards a circular economy.
ETHICS
General Requirements
The LUMENE Group requires its Partners to be committed to ethical conduct, in full compliance with all applicable laws, regulations and international treaties, and respect for human rights according to internationally recognized standards. Should a requirement of this Partner Code of Conduct be in contradiction with the applicable laws, Partners are expected to comply with the laws.
Confidentiality
Partners are expected to take all necessary measures to safeguard and make only appropriate use of confidential information they receive in the course of their actions with the LUMENE Group. Any use of such confidential information for purposes other than for which it was provided is prohibited.
Protection of Intellectual Property Rights
Partners shall comply with all applicable laws and international treaties on intellectual property and to refrain from infringing intellectual property rights of the LUMENE Group or a third party.
Business ethics
The LUMENE Group requires its Partners to commit to the highest standards of ethical business conduct. All forms of corruption, bribery, money laundering, and unlawful restrictive trade practices are strictly prohibited, and the partners are expected to make every effort to prevent, detect and discipline the same. Partners must also respect all applicable international trade restrictions and economic and trade sanctions.
Animal Welfare
The LUMENE Group does not tolerate animal testing of or in its products, including animal testing of the raw materials used in its products, but requires its Partners to use scientifically valid alternatives acceptable to regulators instead.
LABOUR AND HUMAN RIGHTS
The LUMENE Group believes that a diverse community is more creative and empowered and therefore, equality and diversity are an important part of the work community at the LUMENE Group. No decisions by the LUMENE Group are affected by anyone’s background, such as age, gender, or disability, or by belonging to a different language, cultural or other population group. The LUMENE Group expects its Partners also to commit to strengthening the diversity of their culture and maintaining an inclusive environment. In addition, Partners shall commit themselves to uphold the human rights of employees. Employees must be treated with dignity and respect at all times. Partners are expected to support and respect internationally declared human rights and to treat its employees fairly, equally and with dignity.
Freedom of association
In accordance with applicable laws and regulations, Partners shall respect employees’ right to form or join trade unions as well as the right to collective bargaining and action.
Prevention of Forced labour and Human trafficking
Modern slavery in all forms of forced, bonded, or involuntary prison labour or labour linked to any form of punishment is not permitted. Employees shall not be forced to hand over valuables, passport, work permits or identification papers to his/her employer. Partners of the LUMENE Group shall not use or benefit from any kind of forced labour or human trafficking.
Prevention of Child labour
The LUMENE Group does not accept child labour under any circumstances or contract with Partners using child labour. Every child is to be protected from economic exploitation and from carrying out work that can be considered dangerous, to have a negative effect on the child’s education or harmful to the child’s health or development. The term ‘child labour’ refers to work carried out by a child who is under 15 years of age, or under 14 years of age in those countries specified in Article 2.4 of ILO Convention 138. A young person less than 18 years shall not be given admission to work which might jeopardize his or her health, safety or morals.
Working hours
Working hours must comply with national legislation and agreements. Employees must be provided with adequate rest periods and breaks. Any reasonable overtime must be recorded and adequately compensated.
Wages
Wages, benefits and overtime compensation must always comply with applicable laws, regulations and agreements corresponding to the local market standards. Any deduction from wages as a disciplinary measure is prohibited.
Discrimination and oppression
The LUMENE Group does not tolerate discrimination, threats, bullying, oppression or harassment in any form, and supports equal opportunities for all employees.
ENVIRONMENT
Sustainability
The LUMENE Group requires its Partners to comply with applicable laws, regulations and the principles set out in the UN Global Compact concerning the environment. Partners are expected to proactively work towards reducing all negative environmental impacts, including but not limited to emissions into the air, soil and waterways, and to make more efficient use of resources.
Palm oil, palm kernel oil and their derivatives
All our palm oil suppliers must be members of the RSPO (Roundtable on Sustainable Palm Oil) and source their raw material from producers who are also members of the RSPO. Partners must report the quality of palm oil, palm kernel oil or their derivatives used (Mass Balance or others) in raw materials supplied to the LUMENE Group.
Soya Oil and its derivatives
Partners must report to the LUMENE Group the proportion of soya oil and/or its derivatives used in raw materials supplied to the LUMENE Group that is certified as sustainable (organic or Identity Preserved (IP)).
Environmental Permits and Reporting
Partners shall make sure that they obtain, keep current, and follow the reporting guidelines of all the required environmental permits and registrations. Partners shall ensure that their key employees are aware of and trained in product safety practices.
HEALTH AND SAFETY
Partners shall commit to ensuring safe working conditions and a healthy and clean working environment for their employees. Partners shall always comply with the minimum standards according to applicable laws and regulations regarding the working environment. All necessary actions to avoid accidents and work-related injuries must be taken.
DATA PROTECTION AND PRIVACY
The LUMENE Group requires its Partners to comply with all applicable laws, regulations and best practices in the processing and protecting of personal data, including to only collect which is necessary for the purposes of processing, to ensure the accuracy of the personal data and to protect the data from unauthorised access. Any processing of personal data must be conducted in a way that it does not jeopardise the privacy of individuals any more than necessary.
MANAGEMENT SYSTEMS
Partners are expected to have the risk management, documentation and measurement systems in place to facilitate compliance with all applicable laws and the promotion of continuous improvement with respect to the expectations set forth in this Partner Code of Conduct.
COMPLIANCE WITH THIS PARTNER CODE OF CONDUCT
The LUMENE Group requires that all its Partners read and comply with this LUMENE Group Partner Code of Conduct and take all reasonable efforts to communicate the requirements of this Partner Code of Conduct to its employees and such partners that conduct business with the LUMENE Group. Enforcement of this Partner Code of Conduct is important to the LUMENE Group’s business, and it is the responsibility of Partners to ensure that this Partner Code of Conduct is implemented. Partners shall provide upon request information and documentation supporting compliance with this Partner Code of Conduct. The LUMENE Group reserves the right to make inspections to ensure that this Partner Code of Conduct is being enforced. These inspections may be performed by an independent third party and may be unannounced.
In case a Partner fails to comply with the terms of this Partner Code of Conduct and the remedial actions to make good such breaches to the LUMENE Group’s satisfaction within an agreed time period, the LUMENE Group may terminate its business relationship with the Partner.
The LUMENE Group invites its Partners which become aware of wrongdoings or illegal activities affecting people, society, the environment, or the LUMENE Group, including any non-compliance with this Partner Code of Conduct or applicable laws, to raise concern anonymously or openly by using the reporting channel of the LUMENE Group, more information of which is available on www.lumenegroup.com.
