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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.
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Better WORK

CCLA Modern Slavery Benchmark

Modern slavery is a serious abuse of human rights, encompassing several forms of exploitation, including forced labour, human trafficking, servitude and forced marriage. Eradicating modern slavery has been set as a target in the UN Sustainable Development Goals, and its achievement will require dedication, innovation and collaboration.
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Pamela Bentley
Current estimates indicate that 50 million individuals are trapped in modern slavery worldwide, with 28 million of these victims in forced labour. This figure is not static; it is actively growing. It is estimated that every year the UK imports $26 billion worth of products at risk of being linked to modern slavery. For the G20 this number increases to $468 billion.
Forced labour is a fundamental violation of human rights and a severe economic crime. It generates an estimated $236 billion in illicit profits annually. These are effectively wages taken from the vulnerable, remittances taken from migrants and lost tax revenue for countries.
The International Labour Organization calculates that a global one-off investment of $212 billion to eliminate forced labour would unlock $611 billion in demand-driven GDP growth.
In 2023, CCLA launched the first Modern Slavery UK Benchmark, assessing and ranking UK-listed companies annually on their approach to modern slavery.
Find it, Fix it, Prevent it investor coalition
In 2019, CCLA established Find it, Fix it, Prevent it, a collaborative investor initiative designed to tackle modern slavery. The initiative aims to harness the power of the investment industry to encourage companies to find, fix and prevent modern slavery in their value chains.
To this end, the Find it, Fix it, Prevent it initiative has four workstreams:
1
Corporate engagement: aiding companies in developing and implementing better processes for finding, fixing and preventing modern slavery
2
Public policy: promoting a meaningful regulatory environment through work with the government and policymakers
3
Developing better data: working with data providers, non-governmental organisations and academia to develop better data on the prevalence of modern slavery and corporate efforts to address it
4
Convening: offering thought leadership and engaging in wider advocacy to tackle the systemic causes of modern slavery.
At the end of 2025, Find it, Fix it, Prevent it had 58 investors in the programme, with collective assets under management and advisory of £13 trillion.
In 2025 we ran a pilot for the Modern Slavery Global Benchmark. The benchmark aims to:
Provide a framework for companies to follow
The benchmark represents an evaluation of the degree to which companies are active in the fight against modern slavery.
Create an objective assessment Assessments are undertaken annually and align with statutory requirements, government guidance, and international voluntary standards on business and human rights.
Support investor engagement The benchmark furnishes investors with the data they need to engage meaningfully with investee companies on their approach to modern slavery.
Contribute to thought leadership The benchmark provides a vehicle for learning and sharing good practice.
Enhance business competition The benchmark creates a mechanism to leverage business competition to drive improvement in practice.
The benchmark assesses the modern-slavery-related disclosures of the largest UK and global listed companies on the degree to which they:

Modern Slavery UK Benchmark in numbers

The benchmark is designed to support the engagement of the Find it, Fix it, Prevent it investor coalition. During the year, 58 investors, with a combined £13 trillion in assets under management, supported our engagement efforts on modern slavery.

Achievements to date

0
companies have improved their performance tier since the first assessment
0
investors supported CCLA’s engagement efforts
0
companies disclosed cases of modern slavery between 2023 and 2025

2025 UK benchmark

0
companies were assessed
0
companies engaged with us
0
companies disclosed finding modern slavery
0
companies mentioned the benchmark in their public reportingxiv
Reporting on finding cases of modern slavery
The benchmark encourages companies to disclose finding cases of modern slavery. This not only demonstrates a company’s commitment to transparency and accountability but also allows investors to assess the quality of the remedy provided.
The number of companies disclosing cases of modern slavery has increased year on year since the benchmark’s inception.

Modern Slavery UK Benchmark outcomes

The chart below shows the percentage point changes in score over the past three years for the 94 companies that have appeared in the UK benchmark since its inception in 2023. The companies’ 2025 performance tiers are indicated below.
Performance summary by tier ranking 2023–2025
This graphic shows how companies’ tier rankings changed between 2023 and 2025.
Pamela Bentley

Case study: Investec

Investec is an Anglo-South African international banking and wealth management group. Investec was the most improved company on the Modern Slavery UK Benchmark between 2023 and 2025 with a 55 percentage point increase in score. It has moved from tier 4 to tier 2, which means it now represents ‘evolving good practice’.
In its 2025 modern slavery statement, Investec lists the steps it has taken to improve its approach. It has:
  • established a working group to address modern slavery risks across its operations, supply chain and value chain
  • reviewed and updated contract templates for relevant third-party suppliers to strengthen clauses on human rights and modern slavery
  • partnered with the modern slavery charity Unseen UK to strengthen its response to modern slavery
  • collaborated with Unseen UK to risk assess 261 direct suppliers
  • developed a set of red flags to support facilities employees in identifying modern slavery risks during supplier audits
  • worked with Unseen UK to conduct a modern slavery gap analysis
  • developed a four-year internal roadmap intended to guide the company’s response to modern slavery.
From our dialogue with Investec, we know that the CCLA benchmark has played a role in spurring this work.
Dutch modern slavery index
In January 2025, CCLA presented the Modern Slavery Benchmark framework to the board of De Nieuwe Beurskoers, a Dutch network of faith-based investors. The board members were impressed by the rigour of the benchmarking process and appreciated that it aligns with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.
Discussions ensued about whether CCLA’s benchmark framework could be used to assess a selection of Dutch companies on their approach to modern slavery. In December 2025, we agreed a sub-licensing agreement for De Nieuwe Beurskoers to use CCLA’s framework to assess and engage with 10 Dutch-listed companies on their approach to modern slavery and forced labour. We look forward to reporting on the outcomes of this project in 2026.

Case study: International Consolidated Airlines Group (IAG)

IAG is the owner of the airlines Aer Lingus, British Airways, IAG Cargo, Iberia and Vueling. The scale, nature and footprint of the company’s business and supply chain present specific challenges and risks in relation to modern slavery and human trafficking.
Following the publication of the 2023 Modern Slavery UK Benchmark, we met key individuals at the company, who subsequently presented the findings of the benchmark to IAG’s board. A plan was put in place to drive improvement. Between 2023 and 2025, IAG’s score in the Modern Slavery UK Benchmark increased by 34 percentage points. This improvement was driven by:
  • a refreshed code of conduct setting out specific expectations for colleagues, suppliers and partners
  • a new board-approved Human Rights Policy and Ethics and Compliance Charter, underpinned by a three-year plan that includes specific initiatives related to human rights, modern slavery and human trafficking
  • an initiative to join and use Sedex and EcoVadis for supplier risk assessment processes
  • an industry assessment on salient human rights issues, led by the British Airways Holidays Sustainability Team in collaboration with Shift, an expert human rights partner (British Airways Holidays also conducted a review of its top five hotel partners to gain insight into their management of risk and controls)
  • an analysis of risks in the company’s food and catering supply chain, noting working practices associated with these products (such as growing, farming, harvesting, processing and transport)
  • a review of risks in the company’s uniform supply chain (IAG sources tens of thousands of new and replacement uniform items each year) that involved auditing 15 suppliers in Bangladesh, China, India, Indonesia, Morocco, Pakistan, Spain, Sri Lanka, the UK and Vietnam.
IAG has also played a key role as part of an international working group led by the International Civil Aviation Organization to produce updated guidelines for combating trafficking in the aviation industry. These guidelines were published in April 2025 and demonstrate growing awareness and collaboration across the travel and tourism industry.
Pamela Bentley
Launching the CCLA Modern Slavery Global Benchmark pilot
In 2025, we took our benchmark methodology global with the launch of the CCLA Modern Slavery Global Benchmark pilot. The pilot built on the success of the UK benchmark by applying its approach to the top 95 global companies that operate in the UK – companies such as Alphabet, Amazon, Apple, Microsoft, Nestlé and Saudi Aramco.
These global companies are in the investment portfolios of many institutional investors. They employ millions of people directly and will have many more in their supply chain. As such, they are exposed to modern slavery risks globally and can play a powerful role in eliminating modern slavery around the world.
A key question for the global benchmark was: to what extent do foreign-domiciled companies respect UK reporting requirements in both letter and spirit? A secondary question was: in a context where the European Union is significantly increasing the reporting and human rights due diligence requirements of large companies, how do companies domiciled in countries with less stringent requirements report on human rights due diligence?
Only three companies reached the top tier of the pilot benchmark. The majority of the companies were clustered in the bottom tiers, as illustrated in the chart below.
Performance Tier distribution
The global benchmark pilot showed some interesting trends:
  • Global companies on average scored lower than UK companies in the 2024 benchmark, suggesting the UK imports greater modern slavery risk through its open markets.
  • There was a significant disparity between the best-performing (Cisco Systems, Costco and Nestlé) and worst-performing companies (China Merchants Bank, Intuitive Surgical, Philip Morris International and Saudi Aramco). Four companies scored less than 10% overall, raising questions about minimum compliance.
  • A gap exists between policy and practice, with greater transparency on policy and procedure and less disclosure on practice and how harms to victims are rectified.
  • Only one in four companies disclosed finding a case of modern slavery, and just one company confirmed that victims were satisfied with the redress provided.
  • Consumer staples and materials were the highest-scoring sectors, with financials and energy scoring the lowest.
In January 2026 we will publish a new iteration of the global benchmark based on companies’ 2025 disclosures. This will be an opportunity to see how company reporting has changed since the pilot. The ongoing assessment of these global companies will significantly enhance our ability to engage with them on modern slavery.
Pamela Bentley
xiv Anglo American, Auto Trader Group, Entain, Imperial Brands, Investec, J Sainsbury, Lloyds Banking Group, National Grid, NatWest Group, Ocado Group, Persimmon, Phoenix Group Holdings, RELX, Rio Tinto, SSE, Tesco, Vistry Group and Weir Group.