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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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Public policy engagement

At CCLA, public policy engagement is a key tool for tackling systemic risks that threaten to undermine societal and economic stability in the long term. We actively collaborate with regulators, legislators and civil society to advocate for policies that promote corporate accountability, social justice and environmental sustainability.
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Place I Miss Most (Being Inside), HM Young Offender Institution Aylesbury | Courtesy of Koestler Arts
The purpose of engagement with policymakers is to cultivate a more progressive landscape for companies to operate within. Our efforts focus on areas where voluntary corporate action has proven insufficient, such as business and human rights, modern slavery, and climate action.
Through our public policy engagement, we aim to shape regulatory frameworks that raise minimum standards across markets. This work is grounded in our belief that healthy markets require healthy communities, and that responsible investors have a duty to help build the policy infrastructure necessary for both to thrive.

Better work policy engagement

Theme: Work – Living Wage Approach: Investor statement

In October 2025, we added our support to an investor statement, ‘Advancing living wages at the Second World Summit for Social Development, a collective call to action to UN member states’. The statement was developed by the Platform Living Wage Financials together with Harvard University, IDH, Unilever, Shift, UN Global Compact, the World Benchmarking Alliance and the World Business Council for Sustainable Development. It asserts the importance of social sustainability, living wages and living incomes for vulnerable people in UN member states. The statement calls for member states and companies to address the issue of living wages in order to align with the UN Guiding Principles on Business and Human Rights but also to foster efforts to attain the UN Sustainable Development Goals.

Theme: Work – modern slavery Approach: Sovereign engagement (UK)

In March 2025, we led a delegation of investors to meet Daniel Zeichner, the then Minister of State for Food Security and Rural Affairs, to discuss the risks of modern slavery in UK agriculture. At the meeting, we supported the position of Professor Brian Bell, chair of the Migration Advisory Committee, who has highlighted issues with the seasonal agriculture visa scheme, which exposes seasonal workers to a greater risk of forced labour and labour abuse. We shared the work that we have been doing with the Seasonal Worker Scheme Taskforce, a multi-stakeholder body formed by the supermarkets and the Department for Environment, Food and Rural Affairs (Defra) to ensure that supermarkets operationalise the Employer Pays Principle in the UK agriculture sector. CCLA sits on the taskforce to bring the investor voice to the discussion. For more detail, see the case study.

Theme: Work – modern slavery Approach: Sovereign engagement (UK)

In 2024, we were invited by the UK Home Office to take part in its Forced Labour Forum, a group of stakeholders from business, civil society, academia and trade unions. Through this forum, we were heavily involved in a series of meetings with the Home Office and its consultants over several months in 2024–2025. Our involvement coincided with the drafting of updated statutory guidance on the 2015 Modern Slavery Act’s transparency in supply chains provisions.
In March 2025, the Home Office published new statutory guidance on transparency in supply chains. This new guidance adopted many of the metrics in the CCLA Modern Slavery Benchmark (see the case study for further details).
We will continue to engage with the Forced Labour Forum in 2026.

Theme: Work – modern slavery Approach: Sovereign engagement (UK)

In July 2025, the Joint Committee on Human Rights, consisting of 12 members appointed from both the House of Commons and the House of Lords, published a new report on forced labour in UK supply chains. This influential committee has a mandate to examine matters relating to human rights in the UK and to scrutinise every government Bill for its compatibility with human rights.
Earlier in the year, we had submitted joint evidence to the committee with Rathbones and our knowledge partner Walk Free Foundation. We were delighted to see that the committee’s report reflected many of our advocacy points and cited CCLA multiple times. This indicates that our work on modern slavery and forced labour – encompassing our collaborative engagement programme, Find it, Fix it, Prevent it, and our modern slavery benchmarks – is increasingly being recognised, not only by business but also in Parliament.

Theme: Work – modern slavery Approach: Sovereign engagement (UK)

In March 2025, Dame Sara Thornton met with Baroness May of Maidenhead, the chair of the Global Commission on Modern Slavery and Human Trafficking, to share CCLA’s work on modern slavery. The commission is an international initiative launched in 2023 to exert high-level leverage to restore momentum towards achieving target 8.7 in the UN Sustainable Development Goals (to end forced labour, modern slavery and human trafficking).
The commission has a diverse global membership and leadership, with representation from both the Global South and the Global North. It operates independently of any government or international organisation and aims to complement and amplify existing international collaborations on modern slavery and human trafficking.
In the meeting, Dame Sara updated Baroness May on the work of CCLA and the role of investors in engaging companies on modern slavery. Dame Sara and Baroness May also discussed the need for the UK to update the 2015 Modern Slavery Act and the need for the introduction of a proportionate, risk-based approach to mandatory human rights due diligence.

Theme: Work – modern slavery Approach: Sovereign engagement (UK)

In February 2025, Dame Sara Thornton met with UK Home Office minister Jess Phillips – in her role as Minister for Safeguarding and Violence Against Women and Girls – to share CCLA’s latest modern slavery benchmarks and to advocate for the need for stronger legislation. The minister is responsible for the government’s response to modern slavery. Dame Sara updated the minister on CCLA’s work to tackle modern slavery, sharing that investors support well-designed regulation that requires businesses to undertake human rights due diligence. Dame Sara and Ms Phillips also discussed the benefits of forced labour bans, such as the US Uyghur Forced Labor Prevention Act 2021 and the EU Forced Labour Regulation.

Theme: Work – modern slavery Approach: Sovereign engagement (UK)

In October 2025, CCLA hosted a roundtable on modern slavery and exploitation in the construction sector attended by Jess Phillips (Minister for Safeguarding and Violence Against Women and Girls) and Sam Ulyatt (CEO of Crown Commercial Services). Construction continues to rank among the highest-risk sectors for modern slavery and labour abuses.
As one senior official noted, construction operates in many ways like a gig economy, where constant subcontracting entrenches precarity and limits workers’ ability to effectively report abuses. The roundtable involved 70 stakeholders, with significant participation from the sector, investors, civil society and government. A full write-up is available on our website.

Theme: Work – modern slavery Approach: Sovereign engagement (UK)

In September–October 2025, Dame Sara Thornton attended the Labour Party conference to speak at an event hosted by the Ethical Trading Initiative on the need for due diligence legislation. Dame Sara provided an investor perspective on a panel with the general secretary of the Trades Union Congress, the corporate relations director of Princes Group and the CEO of Anti-Slavery International. This was a timely debate as the government is currently reviewing its guidance on responsible business conduct and ministers have expressed a desire to raise standards.

Theme: Work – modern slavery Approach: Sovereign engagement (Taiwan)

In June 2025, we co-signed a letter to the Taiwanese Ministry of Economic Affairs. The letter was drafted by First Sentier Investors in Australia and sent on behalf of the investor coalition Investors Against Slavery and Trafficking Asia Pacific (IAST-APAC), the sister initiative of CCLA’s Find it, Fix it, Prevent it. The letter called on the Taiwanese government to align its regulations and laws governing modern slavery, forced labour and protection of its sizeable migrant worker population with growing international expectations on forced labour and human rights.

Theme: Work – modern slavery and contemporary forms of forced labour Approach: Policy consultation (United Nations)

In April 2025, we wrote to Professor Tomoya Obokata, special rapporteur on contemporary forms of slavery at the Office of the United Nations High Commissioner for Human Rights, in a joint submission with international human rights group Walk Free. This responded to a call for input for a report being written by Tomoya Obokata, ‘A/80/182: The role of financial sector actors in eradicating contemporary forms of slavery’ for the UN General Assembly 80th session.
We provided evidence on the function of the finance sector in eliminating contemporary forms of slavery, emphasising investors’ important role in the value chain, highlighting our role as stewards of assets, and sharing the work of our Find it, Fix it, Prevent it initiative and Modern Slavery Benchmark. Our submission was cited frequently in the report ‘The role of financial sector actors in eradicating contemporary forms of slavery’ and Find it, Fix it, Prevent it was described as an ‘encouraging collaborative effort’.

Theme: Work – responsible business conduct and mandatory human rights due diligence Approach: Sovereign engagement (UK)

In June 2025, the government’s new trade strategy was published. It stated that ‘all UK businesses should respect human rights and the environment in line with the OECD Guidelines on Multinational Enterprises, UN Guiding Principles on Business and Human Rights, and the ILO Declaration on Multinational Enterprises’ and that ‘businesses should conduct risk-based human rights and environmental due diligence’. As part of the strategy, the government announced a review of its approach to ensuring responsible business conduct, focusing on the global supply chains of businesses operating in the UK and the formation of a new Office for Responsible Business Conduct (ORBC).
In the autumn we wrote to Peter Kyle, Secretary of State for Business and Trade, in support of proposed human rights due diligence legislation. The letter was supported by 19 investors with £1.4 trillion in assets under management. In the letter, we stressed that the UK needs to follow its nearest trading partners in the European Union and create some proportionate, risk-based mandatory human rights due diligence legislation. Rather than being anti-competitive, this form of legislation would create a level playing field for business.
Meanwhile, also in December, Dame Sara Thornton attended a ministerial roundtable on responsible business conduct with Chris Bryant, Minister of State for Trade Policy. This invitation-only event was with a small group of business leaders (from companies such as Associated British Foods, M&G, Sky and Tesco) and CEOs of civil society organisations (such as the Ethical Trading Initiative, the Fairtrade Foundation and the Independent Anti-Slavery Commissioner’s Office). The group was convened to discuss the appetite among business and investors to align responsible business conduct requirements with the European Union, the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct – and to discuss the technicalities of what this might involve.
On 16 December, following a request from the ORBC, we convened a consultation roundtable for investors as part of the ORBC’s review of responsible business conduct. We had a rich discussion with a group of 17 investors and await further updates.
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Better environment policy engagement

Theme: Environment – climate Approach: Policy consultation (via the IIGCC UK Policy Working Group)

Participation in the Institutional Investors Group on Climate Change (IIGCC) UK Policy Working Group allowed us to contribute to a wide range of climate-related policy submissions throughout 2025. These included:
  • responses on a UK green taxonomy
  • a consultation by the Department for Energy Security and Net Zero on transition plan requirements
  • a consultation by the Department for Business and Trade on the forthcoming UK Sustainability Reporting Standards
  • IIGCC publications on sector decarbonisation roadmaps
  • written evidence to the Treasury Select Committee’s inquiry on the National Wealth Fund
  • an analysis of recent European Commission papers on the energy transition in the steel and metals sectors
  • responses to the International Sustainability Standards Board’s consultation on amendments to the SASB Standards.
For more information, see the case study.

Theme: Environment – climate Approach: Investor statement

In January 2025 we signed the collaborative ‘Investor joint statement on Omnibus legislation’. This was coordinated by the UN Principles for Responsible Investment (PRI), the Institutional Investors Group on Climate Change and Eurosif in response to the European Commission’s proposed legislative changes to key parts of the European Union’s sustainable finance framework – specifically, the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).
The PRI investor joint statement called on the European Commission to preserve the integrity and ambition of the European Union’s sustainable finance framework, warning against weakening disclosure and accountability requirements.

Theme: Environment – climate Approach: Investor statement

In April 2025 we endorsed a statement coordinated by the French Sustainable Investment Forum calling on European companies to prepare and implement credible climate transition plans. This investor and business joint statement on climate transition plans highlighted the importance of ongoing dialogue with stakeholders and encouraged companies to present their plans for a shareholder vote.

Theme: Environment – climate Approach: Policy consultation (United Nations)

In June 2025 we co-signed a joint submission to the Financial Accounting Standards Board (FASB), which sets US accounting standards, in response to its agenda consultation, a periodic process where the FASB asks investors and other stakeholders which topics it should prioritise in its future standard-setting. The submission encouraged stronger disclosure of climate-related assumptions in company accounts, which would apply to companies that report under the US Generally Accepted Accounting Principles. This includes US-listed companies and others either required to or choosing to use these standards.

Theme: Environment – climate Approach: Policy consultation (United Nations)

In November 2025 we contributed to an IIGCC consultation response on the UK government’s proposal to change the inflation indexation for the Renewables Obligation (RO) and Feed-in Tariffs (FiT) schemes. The RO and FiT schemes are long-standing UK support mechanisms that guarantee revenue for renewable energy projects, helping to make investments bankable. The government proposed shifting these schemes’ inflation link from the Retail Prices Index to the Consumer Prices Index. This potential change raises concerns about policy stability in the UK and could undermine investor confidence in the renewables market. The response advocated for maintaining predictable, stable support terms for existing projects.

Theme: Environment – climate Approach: Investor statement

In December 2025 we signed a statement, ‘Strengthening Europe’s industrial edge: a business roadmap for resilience and competitiveness’, coordinated by the University of Cambridge Institute for Sustainability Leadership as part of the Clean Industrial Deal initiative. The statement calls on EU leaders to strengthen policies that support clean industrial transformation and long‑term competitiveness ahead of discussions on their 2040 emissions target.

Theme: Environment – deforestation Approach: Investor statement

In September 2025 we supported a letter, coordinated by the IIGCC, which was sent to senior officials in the European Commission and the German government. The letter reaffirmed investor backing for a strong and effective framework for companies on deforestation but raised concerns that a proposed ‘zero risk’ classification, allowing certain products or regions to be treated as automatically compliant, could create ambiguity and weaken consistent supply chain monitoring. We followed this up by agreeing to co-sign an IIGCC investor letter to Kerry Group asking the company to clarify and publicly disclose its position on the Regulation on Deforestation-Free Products.

Theme: Environment – microfibre pollution Approach: Investor statement

In October 2025, we co-signed a private letter, sent to the Secretary of State for Environment, Food and Rural Affairs, coordinated by the Investor Coalition on Microfibre Pollution (of which we are a member). The letter requested a meeting to discuss the financial and ecological risks of microplastic pollution from domestic washing machines. It highlighted the problem and encouraged government action through practical regulatory measures requiring microfibre filters to be fitted in washing machines.
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Better health policy engagement

Theme: Health – human capital Approach: Policy consultation

In July 2025, we attended an investor roundtable, hosted by the International Sustainability Standards Board (ISSB), seeking input from investors on a potential new SASB human capital standard.
The SASB Standards enable organisations to provide industry-relevant disclosures about sustainability-related risks and opportunities that could affect their cash flows, access to finance, or cost of capital over the short, medium or long term. They are used in over 3,200 companies in more than 80 jurisdictions around the world. The roundtable represented a significant opportunity for us to influence global reporting standards in this critical area. We emphasised the importance of disclosure on various human capital measures, including physical and mental health support systems. We are awaiting a decision on whether the ISSB plans to move forward with this standard.

Theme: Health – nutrition Approach: Investor statement

In August 2025, we added our support to an investor statement on robust mandatory nutrition disclosure and target-setting. This followed earlier UK policy announcements – part of the government’s 10-Year Health Plan for England – to introduce mandatory healthy food sales reporting for all large companies in the food sector and to set targets to increase the healthiness of sales.
The statement, coordinated by ShareAction, the Food Foundation and the Investor Coalition on Food Policy (of which CCLA is a member), asked the government to swiftly mandate robust metrics and ambitious target-setting, and to implement a credible enforcement mechanism.
A small number of investors, including CCLA, are due to meet with the Department for Business and Trade and HM Treasury in early 2026 to discuss this theme.
See the case study for further details.

Theme: Health – nutrition Approach: Policy consultation

In November 2025, we responded to a consultation on proposed revisions to the SASB Standards on processed foods. The changes would enhance existing metrics, with the aim of better reflecting shifting consumer preferences and regulatory pressures, such as sugar taxes and warning labels.
We broadly welcomed the proposed changes but drew attention to certain problematic areas, such as the inclusion of pet food, which has no obvious bearing on human health. We also suggested enhancements in certain areas, including nutrition governance.

Theme: Health – pollution Approach: Policy consultation

In February 2025, we met technical staff at the ISSB to discuss proposed changes to SASB Standards for the extractives and minerals-processing industry. The invitation came as a result of a project on air pollution that we commenced in 2024. The ISSB team was seeking investor input on the specific pollutants considered significant from a health perspective.
Particulate matter (PM) consists of a variety of chemical compounds, some of which are toxic. Very small PM – in particular, measuring less than 2.5 micrometres in diameter (PM2.5) – can enter the bloodstream via the lungs and be transported around the body, lodging in the heart, brain and other organs. It is increasingly being linked to multiple serious health conditions.
Previously, the SASB Standards included air quality metrics for relevant industries, but PM2.5 was not included. At the meeting, we made the case for a specific PM2.5 metric to be included for extractives and minerals-processing companies.
In September, IFRS Sustainability duly published proposed amendments to the SASB Standards, which included a measure for PM2.5. The proposed revised standards then underwent a consultation process, to which we responded. We hope that the change will be retained in the final output.