Illustration by Pamela Bentley
‘Given the scale of forced labour and its prevalence in the private economy, CCLA believes that all large, listed companies are exposed to the risk of modern slavery through their global operations and supply chains. Companies can therefore implement policies to actively find, fix and prevent modern slavery and set corporate and industry standards with their good practice.’
The ethical investment firm CCLA has produced its 2025 modern slavery benchmark, which assesses and ranks companies on their involvement with and response to modern slavery.
Peter Hugh Smith, CCLA chief executive, said, “Modern slavery is a moral stain on the global economy. Companies have a clear responsibility to stamp it out throughout their operations and value chains, and it is encouraging that companies assessed in our benchmark are improving their performance.
“As investors, we have an obligation to work with companies to help them do so, and to hold them to account when they fail to take modern slavery seriously. Our benchmark brings much-needed transparency to the corporate response to modern slavery, and we encourage investors to join us in using it to engage with companies on the issue.”
Modern slavery is an umbrella term for human rights abuses including forced labour, human trafficking, servitude and forced marriage. Eradicating modern slavery is a target of the UN Sustainable Development Goals, but the International Labour Organisation estimates that a shocking 50 million people (a number almost as big as the population of England) are currently trapped in modern slavery around the world, with 28 million of these in forced labour. This number is still increasing.
An estimated 122,000 people are subjected to modern slavery in the UK, but this number is likely to be a drop in the ocean compared with the scale of forced labour and other forms of modern slavery in UK companies’ international supply chains.
Lord David Alton, Chair of the UK Parliament’s Joint Committee on Human Rights, said, “Goods which are produced or part-produced with forced labour are being sold to consumers in the UK – including cotton, processed tomatoes, fish, solar panels and critical minerals. The patchwork of legislation [is] not preventing goods linked to forced labour from entering the UK market.
“In particular, we heard evidence that the requirement in the Modern Slavery Act for commercial organisations with a turnover exceeding 36 million pounds a year to make a slavery and human trafficking statement for each financial year was not effective in preventing forced labour in supply chains.”
Launched in 2023, the CCLA Modern Slavery UK Benchmark seeks to fill the gap in modern slavery data available to investors by assessing and ranking companies based on their modern slavery disclosures. They aim to encourage investors to engage with companies on the issue, to leverage business competition to drive improvement in practice.
The report said, “CCLA believes that investors have a key role to play in helping companies and other stakeholders to deliver systemic change in the fight against modern slavery. As stewards of business, investors can work with business leaders and engage with companies to ensure that better practices are normalised and incentivised. The benchmark provides these investors with a regular, consistent assessment of companies’ modern slavery commitments and practices, highlighting where there has been progress and where more work is needed.”
The benchmark assesses the modern slavery-related disclosures of the largest UK-listed companies on the degree to which they conform with the requirements of Section 54 of the Modern Slavery Act 2015, disclose information aligned with the Home Office guidance on modern slavery, and report on finding, fixing and preventing modern slavery in their operations and supply chains.
The assessment classifies companies in five tiers. According to this year’s report, twenty-two companies have improved their performance sufficiently to go up one tier this year. In addition, this year’s results show companies rising to tiers 2 and 3, meeting basic expectations. Overall, 60 companies increased their score compared with the 2024 benchmark.
However, only 12 companies are currently in tier 1, reserved for companies that are leading in human rights innovation, the same number as last year. The benchmark shows that although companies may be achieving compliance with regulation, they are not advancing sufficiently to take a leadership position on the issue.
Only a few companies have shown evidence of actively and meaningfully finding, fixing, and preventing modern slavery in their supply chains. The report shows there is a need for improvement even among top companies, particularly in compensating survivors of labour exploitation.
The report also called for stronger legislation to hold companies to account: “CCLA supports the Joint Committee on Human Rights’ conclusion that ‘there is currently a piecemeal and ad hoc approach to addressing forced labour using domestic policy’. We believe that the UK government needs to introduce mandatory human rights due diligence legislation and forced labour bans similar to those adopted by our nearest trading partners.”
Dame Sara Thornton, consultant on modern slavery for CCLA, said, “We urge the UK government to act to bring its 2015 Modern Slavery Act – which was world-leading when it was passed – up to date by ensuring that its transparency rules are tougher. Companies need to be aware that addressing modern slavery is not just the right thing to do – it is also a growing regulatory imperative. But government needs to go further, requiring companies to undertake due diligence, and introducing an outright ban on the import of goods made with forced labour.”
Lord Alton also said, “It was encouraging to hear that the government is considering how to strengthen this legislation, including the reporting requirements, the turnover threshold and penalties for non-compliance. However, our committee went further and recommended new legislation to mandate corporates to undertake due diligence, an import ban on goods linked to forced labour, and a ‘duty to prevent’ to establish civil liability for companies that do not take adequate steps to prevent forced labour in their supply chains. We await the government’s response to our recommendations.
“While it is clear that new legislation is required, it is encouraging to see the current legislation being used by CCLA to hold UK companies to account. This CCLA benchmark assesses not only companies’ modern slavery statements but also their performance in finding modern slavery and addressing it in line with the UN Guiding Principles on Business and Human Rights. I warmly welcome this third modern slavery benchmark of the top UK companies.”