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IMPORTANT INFORMATION
All data as at 31 December 2024, 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 (a company registered in England and Wales with company number 2183088), whose registered address is One Angel Lane, London EC4R 3AB, is authorised and regulated by the Financial Conduct Authority.
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CCLA Modern Slavery UK Benchmark

There are clear steps that companies can take to reduce modern slavery around the world. Large listed companies can be particularly influential in setting international norms and in efforts to find, fix and prevent modern slavery.
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Pamela Bentley
The CCLA Modern Slavery UK Benchmark, launched in 2023, aims to:
  • develop a framework on the degree to which companies are active in the fight against modern slavery
  • create an objective assessment of corporate modern slavery performance aligned with statutory requirements, government guidance, and international voluntary standards on business and human rights
  • support investor engagement with companies on their approach to modern slavery
  • provide a vehicle for learning and sharing good practice
  • create a mechanism to leverage business competition to drive improvement in practice.
2024 Modern Slavery UK Benchmark in numbers
0
companies assessed
in 2024
0
companies engaged
directly with CCLA1
0
companies mentioned
the CCLA Modern Slavery UK Benchmark in their public reporting2
0
companies improved
sufficiently to move up by one or more performance tier
1 Includes engagements between the launch of the 2023 benchmark and the end of 2024.
2 Abrdn, Anglo American, Marks & Spencer Group, National Grid, NatWest Group, Persimmon, RELX, Rio Tinto, Schroders and Tesco.
The CCLA Modern Slavery UK Benchmark assesses the largest UK-listed companies on the following:
  • Modern Slavery Act compliance and registry
  • conformance with Home Office guidance
  • efforts to find, fix and prevent modern slavery in business operations and supply chains.
Companies are assigned to one of five Performance Tiers based on an assessment of their published information. The Performance Tiers are designed to correspond with the Independent Anti-Slavery Commissioner’s maturity framework:
  • Tier 1: Leading on human rights innovation
  • Tier 2: Evolving good practice
  • Tier 3: Meeting basic expectations
  • Tier 4: Barely achieving compliance
  • Tier 5: No modern slavery statement.
Modern Slavery UK Benchmark: 2024 improvers
The 35 companies listed below improved their score sufficiently between their 2023 and 2024 modern slavery assessments to move up by one or more Performance Tier. For the full company rankings, refer to the 2024 CCLA Modern Slavery UK Benchmark report.
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*Not held in CCLA portfolio(s) as at 31 December 2024.
Top improvers by percentage score 2023–2024
The following companies improved their score by 10 or more percentage points in the CCLA Modern Slavery UK Benchmark between its first iteration (in 2023) and 2024. For the full company rankings, refer to the CCLA Modern Slavery UK Benchmark report.
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*Not held in CCLA portfolio(s) as at 31 December 2024.

Modern slavery UK Benchmark assessment criteria

The CCLA Modern Slavery UK Benchmark assessment criteria were created by mapping and combining content from the following resources:
  • Modern Slavery Act 2015
  • Guidance derived from the Modern Slavery Act 2015
  • Business & Human Rights Resource Centre
  • Ethical Trading Initiative Base Code
  • International Responsible Business Conduct
  • KnowTheChain
  • Stronger Together
  • UN Guiding Principles on Business and Human Rights
  • UN Guiding Principles Reporting Framework.
CCLA’s Find it, Fix it, Prevent it modern slavery initiative
Find it, Fix it, Prevent it is an investor collaboration created, convened and resourced by CCLA. It was formally launched at the London Stock Exchange in 2019 and is overseen by an advisory committee that brings together investors, academics and non-governmental organisations to share knowledge, set targets and monitor progress.
At the end of 2024, the Find it, Fix it, Prevent it investor coalition numbered 70 investors with a combined £18 trillion in assets under management. For details of the collaboration, refer to the 2024 Find it, Fix it, Prevent it annual report.
KEY
No response
Discussions ongoing
Positive change
Met engagement target

Progress on modern slavery

The outcomes of our engagement on modern slavery in 2024 are set out below.
Admiral Group Financials
Admiral is included in the Modern Slavery UK Benchmark, ranked in Tier 3 in 2023 (meeting basic expectations). We met its representatives in 2024 to discuss the company’s approach to modern slavery. It remains in Tier 3 (meeting basic expectations) and discussions continue.
Ashtead Group Industrials
Ashtead Group is in the Modern Slavery UK Benchmark and improved by one Performance Tier in 2024, moving from Tier 4 to Tier 3 (meeting basic expectations). It disclosed working with the Slave Free Alliance and disclosed more in the Find it Fix it, Prevent it sections of the scorecard.
AstraZeneca Health care
AstraZeneca is in the scope of the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 2 (evolving good practice). We corresponded with the company in 2024 to discuss its approach to modern slavery. It remains in Tier 2.
Auto Trader Group Communication services
Auto Trader was ranked in Tier 4 (barely achieving compliance) in the 2023 Modern Slavery UK Benchmark. We met the company during 2024 to discuss its approach to modern slavery. It remains in Tier 4 in 2024 and discussions continue.
Berkeley Group Holdings Consumer discretionary
Berkeley Group was rated Tier 3 (meeting basic expectations) in the 2023 Modern Slavery UK Benchmark. It was also part of our Find it, Fix it, Prevent it modern slavery engagement focused on construction firms. We invited the company to attend a construction sector investor roundtable that we hosted in April 2024. The company remains in Tier 3 in 2024.
Bunzl Industrials
Bunzl is in the scope of the Modern Slavery UK Benchmark and ranked in Tier 3 (meeting basic expectations) in 2023. We corresponded with the company during 2024, and it subsequently moved up to Tier 2 (evolving good practice) in 2024.
Compass Group Consumer discretionary
Compass was selected as a priority company for engagement on modern slavery in 2020 under the Find it, Fix it, Prevent it initiative. It is also part of the Modern Slavery UK Benchmark, where it was ranked in Tier 2 (evolving good practice) in both 2023 and 2024. Compass Group have taken the lessons from their due diligence and remedy in the Middle East and applied the learnings to their broader supply base. They are members of the Fair Food Program in the US, for example.
Croda International Materials
Croda is in the scope of the Modern Slavery UK Benchmark. In 2023 it was rated Tier 4 (barely achieving compliance). We met the company in March and November 2024 to discuss its approach to modern slavery. In its 2024 benchmark assessment, it moved up one Tier to Tier 3 (meeting basic expectations).
Diageo Consumer staples
Diageo is in the scope of the Modern Slavery UK Benchmark. In 2023 the company was rated Tier 2 (evolving good practice). We met the company in September 2023 and in 2024 it retains its Tier 2 position.
Diploma Industrials
Diploma is in the scope of the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 4 (barely achieving compliance). It remains in Tier 4 in the 2024 benchmark and has not yet engaged with us on this topic.
Experian Industrials
Experian is in the scope of the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 3 (meeting basic expectations). We met the company in 2023 to discuss its approach. In 2024 the company has moved up one Tier in the benchmark to Tier 2 (evolving good practice). We continue to engage with the company on this topic.
Genuit Group Industrials
Genuit was targeted for engagement under our Find it, Fix it, Prevent it construction sector engagement on modern slavery. We met the company to discuss its approach in January 2024 and representatives joined the construction sector roundtable.
Halma Information technology
Halma is in the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 3 (meeting basic expectations). We corresponded with the company in 2024 and it retains its Tier 3 ranking.
Informa Communication services
Informa engaged with the benchmarking process but remained at Tier 2 (evolving good practice) in 2024.
InterContinental Hotels Group Consumer discretionary
The InterContinental Hotels Group was selected for engagement in 2020 under the Find it, Fix it, Prevent it initiative. CCLA continues to engage with the company via the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 2 (evolving good practice), where it remains in 2024.
Intermediate Capital Group Financials
Intermediate Capital Group is in the scope of the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 4 (barely achieving compliance). We corresponded with the company during the year and by the 2024 assessment, it had improved sufficiently to move up to Tier 3 (meeting basic expectations). They improved by committing to further mapping their supply chain, signing up to a policy aligned to the UN Guiding Principles, and disclosing further information about its grievance mechanisms.
Intertek Group Industrials
Intertek is in the scope of the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 3 (meeting basic expectations). We corresponded with the company during the year. By its 2024 assessment, it had improved sufficiently to move up to Tier 2 (evolving good practice).
Lloyds Banking Group* Financials
Lloyds is in the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 3 (meeting basic expectations). We met the company in May and October 2024 to discuss its approach to modern slavery. It subsequently moved up to Tier 2 (evolving good practice) in 2024.
London Stock Exchange Group Financials
The London Stock Exchange Group is in the scope of the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 4 (barely achieving compliance). We met with the company in 2024 to discuss its approach to modern slavery. By its 2024 modern slavery assessment, it had improved sufficiently to move up to Tier 3 (meeting basic expectations).
McDonald’s Consumer discretionary
In September 2024, BBC Panorama broadcast ‘Slavery on the high street’, a documentary uncovering how an organised crime group had trafficked vulnerable Czech nationals into the UK and forced them to work in McDonald’s restaurants in Cambridgeshire, while controlling their movement and taking their pay. See the section on controversies for details of our engagement.
Prudential Financials
Prudential is in the scope of the Modern Slavery UK Benchmark. In 2023 it was ranked in Tier 3 (meeting basic expectations). We met the company in October 2024 to discuss its approach to modern slavery. It continues to rank in Tier 3 in the benchmark in 2024.
Reckitt Benckiser Group Consumer staples
Reckitt Benckiser topped the Modern Slavery UK Benchmark in 2023 and representatives from the company spoke at our benchmark launch event. We met with Reckitt Benckiser in September 2024 and they continue to be ranked in Tier 1 (leading on human rights innovation) in 2024.
RELX Industrials
RELX engaged with the Modern Slavery UK Benchmark but did not improve its performance in 2024, remaining in Tier 2 (evolving good practice). Discussions continue.
Rightmove Communication services
Rightmove is in the scope of the Modern Slavery UK Benchmark and ranked in Tier 3 (meeting basic expectations) in 2023. We corresponded with the company during in 2024 to discuss its approach to modern slavery. It continues to rank in Tier 3 in the benchmark in 2024.
Rio Tinto Materials
Rio Tinto is in the scope of the Modern Slavery UK Benchmark and ranked in Tier 2 (evolving good practice) in 2023. We corresponded with the company in 2024 and it improved sufficiently to move up to Tier 1 in 2024 (leading on human rights innovation).
Sage Group Information technology
Sage Group is in the scope of the Modern Slavery UK Benchmark and ranked in Tier 4 in 2023 (barely achieving compliance). We met the company in March and September 2024 to discuss its approach to modern slavery. It continues to rank in Tier 4 in 2024. However, due to its reporting cycle, it had not had a chance to respond to engagement on this topic. We expect improvements in 2025.
SEGRO Real estate
SEGRO is in the scope of the Modern Slavery UK Benchmark and ranked in Tier 3 in 2023 (meeting basic expectations). We corresponded with the company in 2024 and it remains in Tier 3 in 2024.
Spirax Group Industrials
Spirax Group is included in the Modern Slavery UK Benchmark and ranked in Tier 4 in 2023 (barely achieving compliance). We met the company in February 2024 to discuss its approach to modern slavery. It improved sufficiently to move up to Tier 3 in 2024 (meeting basic expectations).
Unilever Consumer staples
Unilever is in the scope of the Modern Slavery UK Benchmark. In 2023 it was ranked in the top Tier of the benchmark (leading on human rights innovation). We met the company to discuss this topic in 2024 and the company retains its Tier 1 position.

Progress on the Living Wage

In early 2023, we commenced engagement with several UK-listed companies with the aim of persuading them to become Living Wage accredited. We chose companies in sectors where there is a high proportion of low-paid workers, namely hospitality and retail, as well as businesses with large call centres.
Also in 2023, we joined an alliance of financial institutions known as the Platform Living Wage Financials (PLWF). The alliance encourages companies to aim for living wages in their global supply chains. We are a member of PLWF’s apparel and textile working group and are part of the engagement working group for the following companies.
The outcomes of our engagement on the Living Wage in 2024 are set out below.
Greggs Consumer discretionary
We have been engaging with Greggs on its policies on pay and retention as a member of ShareAction’s Good Work Coalition since 2023. We met with the company in March and October 2024. Although Greggs is not a Living Wage accredited employer, it does have a collective bargaining agreement with the Bakers, Food and Allied Workers Union and claims that wages and benefits are negotiated with workers on an annual basis. Discussions continue.
LVMH Moet Hennessy Louis Vuitton Consumer discretionary
LVMH is a focus of our engagement under PLWF. In June 2024, news emerged that Italian authorities had put LVMH subsidiary Dior under special measures after finding that the company had not taken sufficient measures to address the exploitation of Chinese migrant workers in northern Italy. CCLA joined engagement calls with PLWF members to address these concerns. LVMH has announced that Dior plans to bring more Italian production in-house to address this problem.
Nestlé Consumer staples
As part of PLWF, we have been engaging with Nestlé to ensure that workers in the company’s supply chain are paid a living wage or have a living income. Nestlé is ranked as ‘maturing’, the middle tier of five in a PLWF analysis published in 2023. The next PLWF report is scheduled for publication in January 2025 and we await the outcome.
Watches of Switzerland Consumer discretionary
Following engagement that commenced in 2023, Watches of Switzerland became a Living Wage accredited employer in 2024.

Progress relating to the UN PRI Advance programme

The outcomes of our engagement relating to the United Nations Principles for Responsible Investment (PRI) Advance programme in 2024 are set out below.
NextEra Energy Utilities
In 2023, CCLA joined the UN PRI Advance work programme as lead investor for NextEra Energy. The focus of the engagement is the company’s approach to human rights – in particular, forced labour in its solar panel supply chain. During 2023, the company confirmed a new onshoring/nearshoring/friendshoring strategy for solar and said that it was working on a new human rights policy. We met to discuss this with the company in July 2024, but it became clear that little progress had been made. A shareholder proposal has been filed at the company, which we plan to support when it goes to vote.


*Not held in CCLA portfolio(s) as at 31 December 2024.