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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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Review of the Modern Slavery Act 2015
Review of the Modern Slavery Act 2015
As investors, we have long argued that the UK’s Modern Slavery Act 2015 needs to be strengthened so that the requirements placed on companies to publish modern slavery statements are clearer and more exacting. We have also argued that there need to be sanctions for non-compliance and that the law should apply to public bodies as well as companies.
During 2024 we gave both written and oral evidence to the House of Lords review of the Modern Slavery Act. We collaborated with Rathbones to make a joint written submission to the inquiry, and in April CCLA’s Dame Sara Thornton and Dr Martin Buttle gave evidence to the committee. They argued for the Modern Slavery Act to be amended but also advocated for the need for the UK to go further and adopt mandatory human rights due diligence.
There had been a lengthy debate in the European Union on this issue over the past few years and, after several setbacks, the European Parliament formally adopted the Corporate Sustainability Due Diligence Directive in May 2024. The directive introduces legal obligations on large companies trading in Europe in respect of the adverse impacts of their activities on human rights and environmental protection. We believe that a similar approach in the UK would provide consistency of standards for businesses and would reduce the risk of goods made with forced labour being deposited in the UK.
Other work on modern slavery policy
Other work on modern slavery policy
Over the course of the year, we engaged with Baroness Young of Hornsey as she sought support for her private members’ Bill, the Commercial Organisations and Public Authorities Duty (Human Rights and Environment) Bill. The Bill had its second reading, but the July general election meant that it could progress no further.
We continued to focus on exploitation in UK agriculture and in March met with Mark Spencer MP, then Minister of State for Food, Farming and Fisheries. We were accompanied by a group of 14 institutional investors. This was the group that had supported us in 2023 in writing to Thérèse Coffey, then Secretary of State for Environment, Food and Rural Affairs, urging the government to implement the recommendations of an independent review into labour shortages in the UK’s food supply chain.
During the meeting we urged the government to support work being done by the Seasonal Worker Scheme Taskforce (SWST) on recruitment-related costs borne by agricultural workers. In particular, the Seasonal Worker visa scheme is not compliant with international best practice on the Employer Pays Principle. We welcomed a joint feasibility study between the Department for Environment, Food and Rural Affairs and the SWST and are pleased to be the investor voice on the Project Advisory Group.
During 2024, we contributed to the Migration Advisory Committee’s report on the Seasonal Worker visa, which was published in June. The report recommends that there needs to be greater security about the future of the scheme, fairer work and pay for workers, and better communication and enforcement of worker rights. Significantly, the report also recommended consideration of the Employer Pays Principle. Professor Brian Bell, chair of the committee, attended a meeting of CCLA’s Find it, Fix it, Prevent it initiative to share his findings with investors. We then wrote on behalf of six investors with over £1 trillion in assets under management and advisement to Daniel Zeichner MP, Minister of State for Food Security and Rural Affairs, in support of the Migration Advisory Committee’s report.
Construction is another high-risk area for modern slavery and we have continued to work with investors and the construction sector to urge robust action. In April we convened a roundtable bringing together investors, law enforcement, civil society, government officials and 23 construction industry representatives. The debate was positive. Since then, several companies have overhauled their approach, and representatives of the sector are working together to develop information and intelligence-sharing. We published a joint statement in August that was signed by 17 organisations, including seven major construction companies. We continue to work with this sector and have participated in several events since our seminal roundtable.
Over the past year we have contributed to the Home Office’s Modern Slavery Engagement Forum on Prevention and Enforcement. In particular, we are members of the Forced Labour Forum, which is advising the Home Office as it revises the statutory guidance on transparency in supply chains. This guidance for businesses on Section 54 of the Modern Slavery Act is important and our work on the Modern Slavery UK Benchmark has demonstrated the need for it to be updated and revised. The Forced Labour Forum is a good opportunity to provide an investor perspective.
The 2024 CCLA Modern Slavery UK Benchmark, published in November, also gave us a strong platform for engagement with policy professionals. In December, we presented our findings at both the Westminster Legal Policy Forum and the Cross Whitehall Group on Forced Labour in Supply Chains.
Lastly, we were delighted to present an investor perspective to the Commonwealth Parliamentary Association. This group of legislators, from across the Commonwealth, is considering the need for law and regulation on modern slavery. Led by CCLA’s CEO, Peter Hugh Smith, we set out CCLA’s approach to modern slavery within the wider context of ‘good investment’, the Financial Conduct Authority’s Sustainability Disclosure Requirements regime and broader public policy.