IMPORTANT INFORMATION
All data as at 31 December 2025, unless specified otherwise. This document is issued for information purposes only. It does not constitute the provision of financial, investment or other professional advice. We strongly recommend you seek independent professional advice prior to investing. The value of investments and the income derived from them may fall as well as rise. Investors may not get back the amount originally invested and may lose money. Any forward-looking statements are based on CCLA’s current opinions, expectations and projections. CCLA undertakes no obligations to update or revise these. Actual results could differ materially from those anticipated. All names, logos and brands shown in this document are the property of their respective owners and do not imply endorsement. These have been used for the purposes of this document only. CCLA Investment Management Limited (registered in England & Wales, No. 2183088, at One Angel Lane, London EC4R 3AB) is part of the Jupiter Group, and is authorised and regulated by the Financial Conduct Authority.
Foreword
What is Good Investment?
Our responsible investment approach
2025 a year in action
Stewardship and engagement
Appendix 1: 2025 engagement record
Appendix 2: Shareholder proposals
Appendix 3: Investors supporting CCLA engagement
Appendix 4: Governance and our portfolios
Appendix 5: Climate pledge and portfolio carbon footprint
Appendix 6: Memberships and initiatives
Appendix 7: Industry recognition
Appendix 8: Standards, frameworks and initiatives
2026 Better World
Stewardship outcomes for the year 2025
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result
Better Work
Engagement case studies
Engagement case studies
Our engagement aims to improve the conditions of workers across themes ranging from fair pay to upholding the human rights set out in the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. With an estimated 50 million people trapped in modern slavery worldwide, we recognise that such exploitation is likely embedded within the supply chains of virtually all businesses, even when the risks are not immediately visible. For this reason, modern slavery is a strong focus of our work.
Case study:
Engaging with Amazon on the right to freedom of association and collective bargaining
Amazon is a multinational technology company engaged in e-commerce, cloud computing, online advertising, digital streaming and artificial intelligence. With more than 1.5 million employees worldwide, it is the second largest private employer globally.
Reason for engagement
Journalists, unions and civil society organisations have raised concerns about working conditions, health and safety, and the ability of Amazon workers in fulfilment and delivery to form, join and collectively bargain via unions. Freedom of association is one of the ILO Core Labour Standards. It plays a central role in ensuring workers are treated fairly by allowing them to form and join unions, engage in collective bargaining, and defend their rights at work.
What we did
We have been engaging Amazon about our concerns on workers’ rights for many years. In 2023–24 and 2024–25 we filed shareholder proposals calling for the company to commission an independent report on the degree to which its practices align with international human rights standards and its policies on freedom of association and collective bargaining. In June 2024, we wrote a public letter, supported by 47 global investors, to highlight concerns raised by GMB Union regarding its efforts to organise Amazon workers in Coventry.
In March 2025, Amazon moved to ‘no-action’ the latest shareholder proposal, so as to remove it from the ballot at the annual general meeting. The company argued that the proposal, under new rules, constituted ‘ordinary business’ and was therefore beyond the purview of investors (see box below). We interpreted this as a move to block a resolution that had previously secured significant investor support.
In June, we organised a roundtable for investors and wealth managers in the UK to discuss labour rights at Amazon. The roundtable included contributions from GMB Union members who had been attempting to organise workers in Coventry.
Outcomes
In October 2025, executives from Amazon came to CCLA’s London offices for a meeting and also invited us on a tour of the company’s Dartford fulfilment centre (LCY3).
Amazon flew a tour guide in from Seattle to meet with a group of London-based investors for the tour. During the tour, we were told that LCY3 is equivalent to seven football pitches in size, employs 2,500 workers on-site, and packs on average six million packages per week. This number significantly increases during busy periods.
We saw investments that Amazon had made in automation and robotisation. Large areas of the distribution centre are now fully automated, such that the main role of human packers is to pick up items from containers, scan them and insert them into folders on robot stacks. Amazon was keen to emphasise that it had introduced investments in automation to increase safety as well as efficiency. Representatives also explained the mechanisms they have to engage employees, employee safety committees and European-style works councils.
Following the tour, Amazon representatives came to CCLA’s offices to discuss the issues of collective bargaining and labour standards. They wished to discuss our concerns and gauge how they could address them. The representatives appeared ready to listen but made no commitments; they took note of what we said but maintained their position that Amazon respects workers’ rights to freely associate and collectively bargain. This was only a first step, but the company’s willingness to send representatives in person to discuss these issues is a positive development. We will continue to engage with Amazon on collective bargaining and are encouraging the company to publish ongoing data on its engagement with worker representative organisations.
Case study:
Engaging with Coca-Cola Co on forced labour and human rights abuses in the Indian sugar supply chain
Coca-Cola Co is the world’s largest beverage enterprise, headquartered in Georgia, United States. It offers a diverse portfolio of soft drinks, juices, teas and waters, selling into more than 200 countries worldwide. This engagement focuses on Coca-Cola Co but also includes Nestlé and Unilever, both of which are also significant buyers of Indian sugar.
Reason for engagement
In 2024, a series of articles in The New York Times uncovered exploitative abuse, forced labour and coerced hysterectomies in the Maharashtra sugar cane industry. Migrant sugar cutters – labourers who travel to sugar-producing regions to harvest sugarcane – are recruited by gangmasters known as mukadam, who serve as intermediaries between sugar mills, farms and labourers. Through debt traps and informal contracts, these workers are pushed into debt bondage and forced labour, while reports have revealed brutal working conditions and exploitative, sometimes violent, practices aimed at boosting productivity on sugar farms.
What we did
CCLA is a member of the Interfaith Center on Corporate Responsibility’s Equitable Global Supply Chains group. The group picked up on the issue and joined an international group of investors engaging major sugar buyers from the Maharashtra region, including Coca-Cola Co, Mondelēz International, Nestlé, PepsiCo and Unilever. As a direct investor in Coca-Cola Co, we took the lead in engaging the company, along with Mercy Investment Services. We have been asking Coca-Cola Co to demonstrate leadership in tackling this deep-rooted and complex human rights issue and ensure there are effective social dialogue mechanisms with workers.
Outcomes
Coca-Cola Co has engaged constructively and launched several initiatives in India with a view to creating a more responsible sugar cane industry. These include:
- Sustainable and Ethical Engagement in Decent Sugarcane (SEEDS): Coca-Cola Co and its implementation partner, Solidaridad, are working with three mills in Coca-Cola Co’s direct supply chain to raise awareness and create better working conditions for mill workers and cane cutters.
- Coalition for Responsible Sugar Cane Industry (CRSI): this newly formed multi-stakeholder initiative is working to address the issues at a system-wide level. CRSI has gained the support of and is working with the Indian Sugar Mills Association, the apex sugar industry body in India. CRSI also has the support of Hershey Company, PepsiCo and Unilever.
- Partnering with the International Organisation for Migration, which is tasked with providing pre‑departure rights training for migrant workers in India.
- Supporting the ILO’s child labour work in the neighbouring state of Karnataka.
Case study:
Engaging with InterContinental Hotels Group on modern slavery and the Living Wage
InterContinental Hotels Group (IHG) is a British multinational hospitality company headquartered in the UK, operating more than 6,800 hotels in over 100 countries worldwide. Its portfolio includes brands such as InterContinental, Holiday Inn and Crowne Plaza.
Reason for engagement
The hospitality industry is a sector with a high risk of modern slavery. It is typically a low pay sector, highly reliant on migrant workers in roles such as security, cleaning and catering. It is also associated with human trafficking for sexual exploitation.
What we did
We first engaged IHG on this theme more than a decade ago, specifically concerning the risk of child sex trafficking in the run-up to the London Olympics. In recent years, we have also engaged with the firm on its approach to paying the Living Wage.
IHG is one of the companies assessed and ranked annually in the CCLA Modern Slavery UK Benchmark; we have been benchmarking its approach to modern slavery and forced labour since 2023. We have had several discussions with IHG’s human rights team about what the company could do to improve and have found this to be a thoughtful and engaged company with a sophisticated understanding of human rights risks.
Outcomes
We were delighted when, in 2025, IHG reached performance tier 1 in the CCLA Modern Slavery UK Benchmark, considered ‘leading on human rights innovation’. In its human rights disclosures published in 2025 IHG:
- improved the information it provided on human rights due diligence processes, including details on audit prioritisation and protocols
- provided detail on processes to strengthen monitoring and evaluation of the implementation of responsible labour requirements, piloting a new self-assessment process and conducting on-site assessments at selected hotels in the United Arab Emirates, Kuwait and Saudi Arabia
- discussed how several hotels had shared that outsourced workers’ passports had been held by a third-party labour provider and how IHG had worked to ensure workers could access these essential documents
- published new guidelines for hotels on how to investigate and remediate worker-paid recruitment fees and costs
- explained how it had partnered with civil society organisations to raise awareness of trafficking for sexual exploitation around the Paris Olympics and the Super Bowl in Las Vegas.
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Case study:
Engaging with Sage Group on modern slavery
Sage Group is a British multinational enterprise software company specialising in accounting, payroll, HR and business management solutions for small and medium-sized businesses worldwide. It serves customers in more than 20 countries.
Reason for engagement
Sage Group is one of the companies assessed and ranked annually in the CCLA Modern Slavery UK Benchmark. The company was ranked as tier 4 (‘failing to meet basic expectations’) in 2024.
What we did
Following the publication of the benchmark, we wrote to all tier 4 companies in our portfolio, including Sage Group. We have subsequently met representatives of the company on several occasions to discuss its approach to modern slavery.
Outcomes
Sage Group embraced the challenge and has invested in internal human rights expertise to review its approach and procedures. In its subsequent modern slavery statement, Sage Group disclosed that it had:
- improved its human rights due diligence processes, including its risk assessment processes
- joined Slave-Free Alliance, a non-profit social enterprise dedicated to helping organisations combat modern slavery; this three-year membership will provide Sage with expert guidance on identifying both potential and actual risks of modern slavery across its operations and supply chain
- introduced a human rights saliency assessment to identify and prioritise the most salient human rights risks across its value chain
- started to develop a human rights risk register to integrate into its enterprise risk management system.
Case study:
Engaging with Berkeley Group Holdings and the construction industry on modern slavery
Berkeley Group Holdings is a British property developer and housebuilder specialising in residential-led and mixed-use developments across London, Birmingham and the South of England. The company operates under brands such as Berkeley, St George, St James, St Joseph, St Edward and St William.
Reason for engagement
The construction sector is considered at high risk of modern slavery. A combination of low-wage, low-skilled jobs, endemic subcontracting and labour shortages increase the risk factors. Furthermore, many of the materials used in construction (e.g. bricks, stone, timber and glass as well as renewables) are associated with elevated supply chain risks.
What we did
For the past two years, CCLA, in partnership with the UK Cabinet Office, LGT Wealth Management and the Supply Chain Sustainability School, has been convening C-suite and senior managers from the construction sector alongside investors, civil servants, government officials and civil society to discuss the risks of modern slavery in the UK construction sector.
The most recent roundtable was held in October 2025 and featured keynote speeches from Jess Phillips, Minister for Safeguarding and Violence Against Women and Girls, and Sam Ulyatt, chief executive of Crown Commercial Services. Representatives from Berkeley Group Holdings attended both roundtables.
Outcomes
Berkeley Group Holdings is one of the companies assessed and ranked annually in the CCLA Modern Slavery UK Benchmark. Having been ranked in tier 3 (‘meeting basic expectations’) in 2024, in 2025 it improved sufficiently to move up to tier 2 (‘evolving good practice’). This was a result of improved disclosures around due diligence, supply chain mapping and the company’s approach to risk management. Specifically:
- improved disclosures on human rights due diligence processes, including more details on how the company assesses and manages risk
- reporting on the salient modern slavery risks around the recruitment of contractors and in the company’s materials supply chain
- greater detail on the categorisation, mapping and disclosure of the company’s supply chain
- improved disclosures on the on-site induction of workers and awareness campaigns disseminated across all Berkeley sites, in Albanian, English, Polish and Romanian
- improved disclosures on the effectiveness of the company’s actions and its future plans.
Case study:
Engaging with Microsoft on modern slavery
Microsoft is a multinational technology company that develops, licenses and sells computer software, consumer electronics, personal computers and cloud services. Its best-known products include the Windows operating system, Microsoft 365, the Azure cloud platform, Xbox gaming consoles, LinkedIn and Surface devices.
Reason for engagement
As a company that develops hardware as well as software, Microsoft has extensive supply chains that reach into high-risk geographies for forced labour in Asia. In addition, its technology is reliant on rare earth minerals, which are often mined in conflict-afflicted regions in Africa.
What we did
We commenced engagement with the company in 2025 to understand and evaluate its approach to modern slavery and forced labour. Microsoft engaged constructively and was placed in performance tier 2 (‘evolving good practice’) in the pilot benchmark.
Outcomes
Since engagement commenced, Microsoft has enhanced its modern slavery disclosures and provided more granular detail on its supply chain. It has also incorporated site-level analysis into its modern slavery risk assessments. In its supply chain integrity statement for fiscal year 2024 (published in 2025):
- The company disclosed improved details about its supply chain. The statement indicates that the company sourced from over 19,000 directly contracted suppliers located in 108 countries in 2024. A map illustrating these countries is included.
- It also disclosed that its cloud hardware division integrates on-site analysis into broader risk assessment processes: ‘assessment findings and remediations … are all inputs to a quarterly risk assessment cycle, out of which new and emerging risks are identified, rated, and actioned’.
- It furthermore demonstrated that modern slavery indicators were found in its supply chain during the reporting period, specifically 13 instances of ‘prohibited recruitment fees’. The statement provides brief detail on the remedial action taken in response to these findings. It confirms that Microsoft requires suppliers to repay such fees and that in fiscal year 2024, suppliers took immediate action to repay a total of $66,939 to 2,216 employees.
Investor Initiative on Human Rights Data
The Investor Initiative on Human Rights Data (II-HRD) is a collaborative initiative where institutional investors work together to improve the data available on human rights. This can help investors to more easily incorporate human rights data into their investment and stewardship decision-making.
This year, as part of the II-HRD collaboration, we have engaged with proxy voting advisory service ISS and environmental, social and governance (ESG) data provider Sustainalytics on their approach to human rights data. As clients and users of their data, we pressed them to increase the scope of companies under analysis. We also asked them to ensure their methodologies were transparent and aligned with the UN Guiding Principles on Business and Human Rights and the requirements of the EU Corporate Sustainability Due Diligence Directive.
In addition, we fed into the September 2025 publication of the II-HRD’s ‘Guidance for ESG data providers on assessing company non-compliance with, and breaches of, international human rights norms’.
Case study:
Engaging with the UK government on seasonal workers
The Department for Environment, Food and Rural Affairs (Defra) is the ministry responsible for the Seasonal Worker visa scheme. The Seasonal Worker Scheme Taskforce is a multi-stakeholder initiative set up in 2022 by the supermarket retailers and Defra following controversies and alleged modern slavery in UK seasonal agriculture.
Reason for engagement
In 2022, following news stories about the exploitation of seasonal agricultural workers coming from Indonesia, Nepal and Central Asian republics to pick fruit and vegetables in the UK, CCLA drafted a public statement calling for (among other things) UK supermarkets to implement the Employer Pays Principle in UK agriculture. This is a human rights concept that asserts that migrant workers should not be charged recruitment fees in order to secure a job. The statement was co-signed by 10 global investors.
What we did
Subsequently, CCLA met the Ministers of State for Food Security and Rural Affairs for the Conservative and Labour governments to raise our concerns, with our latest meeting held in March 2025 with Daniel Zeichner. We have been invited to participate in the Seasonal Worker Scheme Taskforce as the sole investor voice and took part in a working group undertaking a Defra‑supported feasibility study on implementing the Employer Pays Principle.
Outcomes
The feasibility study was published in September 2025. CCLA’s Dame Sara Thornton was interviewed for the BBC’s File on 4 Investigates programme about our work to protect the UK’s migrant seasonal workers from exploitation and our engagement with supermarkets and policymakers to implement the Employer Pays Principle.
Supermarkets and the government continue to consider their response in the context of the rising cost of living and a policy environment that is hostile to migrants. As Dame Sara said on File on 4 Investigates, ‘Supermarkets have been part of the Seasonal Worker Scheme Taskforce for years. Several of the supermarkets in the UK have made public commitments to the Employer Pays Principle but we are now at a key inflection moment. This is a key test of their commitment.’
Case study:
Engaging with the UK Home Office on modern slavery policy
The UK Home Office Forced Labour Forum is a multi-stakeholder group of civil servants, businesses and civil society organisations convened by the Home Office to discuss modern slavery policy. In 2024 and 2025 the group met several times to discuss an update of the transparency in supply chains statutory guidance.
Reason for engagement
In our public policy advocacy, we have been pushing for a new modern slavery Bill and a proportionate, risk-based, mandatory human rights due diligence law. The old transparency in supply chains guidance for businesses looking to comply with the UK Modern Slavery Act 2015 was widely viewed as insufficient and dated.
In the absence of stretching guidance, the CCLA Modern Slavery Benchmark has had a wide appeal. Many corporates use the framework to gauge the maturity of their processes. We wanted our experiences and elements of our benchmark to be integrated into the new statutory guidance.
What we did
In a series of meetings with the Home Office over several months, we showcased the CCLA Modern Slavery UK Benchmark and emphasised our view that businesses should be encouraged to find – and to report on – instances of modern slavery in supply chains.
Modern slavery is likely to exist in the supply chain of almost every company. We therefore believe that, rather than indicating an absence of modern slavery, failing to ‘find it’ demonstrates that a company’s human rights due diligence processes are inadequate. This is a theme that has been reflected in the public addresses of the Minister for Safeguarding and Violence Against Women and Girls (including modern slavery), Jess Phillips.†
Outcomes
In March 2025, coinciding with the 10-year anniversary of the Modern Slavery Act, the Home Office published its updated statutory guidance. We were pleased to see that the new guidance draws on CCLA’s Modern Slavery Benchmark framework and that our benchmark is linked to and positively referenced in the guidance. The statutory guidance states: ‘A useful resource to support organisations developing KPIs [key performance indicators] in the above areas is the CCLA Modern Slavery Benchmark. The CCLA Benchmark includes several metrics under each of the above areas, and organisations could use these to develop suitable KPIs for their business.’
We expect that the guidance will be the first port of call for all companies in the scope of, and working to comply with, the Modern Slavery Act. We are delighted that our benchmark has received such acclaim.
Engaging in a changing political environment
The changing political climate in the United States has influenced investor stewardship, particularly on environmental, social and governance (ESG) issues. In recent years, some policymakers and regulators have questioned whether shareholder engagement on such themes might be politically motivated. In response, certain US states (e.g. Florida and Texas) have introduced measures restricting or scrutinising ESG-related investment practices, framing them as politically motivated rather than an act of fiduciary duty. This has created a highly polarised environment, making coordinated stewardship strategies more difficult for investors, especially those operating globally.
At the same time, the US Securities and Exchange Commission (SEC) has reinterpreted aspects of Rule 14a8, which governs the terms under which investors can place proposals on a company’s proxy ballot. In the updated guidance, companies that receive a shareholder proposal may request permission from the SEC’s staff to exclude it from their proxy materials. The company must submit a ‘no-action request’ to the SEC, arguing that the proposal fails to meet certain requirements (e.g. it is too vague, relates to ordinary business operations, duplicates another proposal or violates procedural rules). For investors in US-listed companies, exercising stewardship now requires greater persistence and strategic coordination, as proposals that once reached the ballot may now be blocked (or ‘no-actioned’) earlier in the process.
* Berkeley Group Holdings, communication to CCLA, 5 September 2025.
† See, for instance, Jess Phillips (2025), ‘Foreword’, in UK Home Office, ‘Transparency in supply chains: a practical guide’