9 April 2025
James Corah, Head of Sustainability
There are many techniques that we can use, as investors, to drive change. These vary based upon their intensity and scale from intensive 1:1 engagement meetings, that aim to change something at a specific company, to programmes like our corporate mental health benchmark, that aim to change behaviours across a large number of businesses.
One of the most effective tools is public policy advocacy. This is where investors work with governments and regulators with the aim of, positively, influencing regulation or legislation. The theory of change is simple. If you can alter the rules of the game, you can change how all participants play it.
On this basis, and whilst it isn’t strictly regulation or legislation, I am so pleased with the UK Home Office's new statutory guidance for businesses on how to tackle and report upon modern slavery. Released ten years ago, the UK’s Modern Slavery Act has been hugely influential in harnessing the power of businesses to address modern slavery in their supply chains and operations.
As detailed below, the new guidance for businesses draws upon – and references - the framework we developed for the CCLA Modern Slavery Benchmark. We believe, if properly implemented by companies, this guidance has the potential to further increase the effectiveness of corporate actions to end modern slavery.
I hope this newsletter gives you further insight into how we are using our position as an investor to help build a Better World.
Engaging with the Home Office on the Transparency in Supply Chains (TISC) Statutory Guidance
CCLA has a longstanding engagement focus that aims to increase the effectiveness of corporate actions against modern slavery. To support this work, we also engage with UK policymakers aimed at pushing for more progressive modern slavery legislation.
One such example is our engagement with the Home Office Forced Labour Forum, a group of stakeholders from business, civil society, academia and trade unions. Through this Forum, we have been heavily involved in a series of meetings over several months with the Home Office and their consultants. These were during the drafting stage of updated statutory guidance for the 2015 Modern Slavery Act’s Transparency in Supply Chains (TISC) provisions.
The TISC provision (Section 54 of the Act) requires businesses operating in the UK above a certain size to report annually on the steps they have taken to tackle modern slavery in their operations and global supply chains. The corresponding guidance provides advice on how organisations can produce high quality modern slavery statements and develop a more effective approach to tackling modern slavery.
In March, coinciding with the ten-year anniversary of the Modern Slavery Act, the Home Office published its updated statutory guidance. We were very pleased to see that this draws on CCLA’s UK Modern Slavery Benchmark framework and that our benchmark is linked to and positively referenced throughout.
We expect that the guidance will be the first port of call for all companies in scope of and working to comply with the Modern Slavery Act and are delighted that our benchmark has received such acclaim. Hopefully, this will play a small – but meaningful role – in helping companies find and then assist some of the World’s most vulnerable people.
Key milestones
- Pushing for climate action: Having filed a climate-related shareholder resolution at NextEra Energy in late 2024, we agreed to withdraw this proposal in Q1 2025 after the company committed to new lobbying disclosures. NextEra has a target to reach net-zero carbon emissions by 2045, although some of the trade associations to which it belongs can present forceful obstacles to addressing climate change. Our proposal asked the board to report to shareholders on its approach to identifying and addressing misalignments between its lobbying and policy influence activities, and its ‘Real Zero’ goal. The company has committed to publishing a lobbying report.
- In 2023, a series of New York Times articles uncovered exploitative abuse, forced labour and coerced hysterectomies in the Maharashtra sugar cane industry. As a direct investor in Coca-Cola Co, we took the lead in engaging the company - alongside Mercy Investment Services – about this issue. Together, we are asking Coca-Cola to demonstrate leadership in tackling this deep-rooted issue and ensure there are effective social dialogue mechanisms with affected workers. Coca-Cola has engaged constructively and launched several initiatives in India. Whilst change will take time, the company has now published a statement outlining the steps it has taken to address this problem. We will continue to push them on this important issue.
CCLA in the news
- “The Importance of Strong Sustainable Disclosure Rules for Investors” Tessa Younger, CCLA’s Better Environment Lead, is interviewed for a podcast covering proposed changes to EU sustainability legislation.
- On ESG and Defence: James Corah, CCLA’s Head of Sustainability, tells Ignites why it should be clients who choose whether or not to invest in defence stocks.
- Transparency and Engagement: James Corah writes in Investment Week about how to make sure engagement is effective during the second Trump Presidency.
- Pushing for Diversity: Financial News covers CCLA’s longstanding commitment to promoting gender diversity on company boards.
- 10 Years of the Modern Slavery Act: Portfolio Adviser Future talk to CCLA’s Dame Sara Thornton and Martin Buttle about the need to reform the UK’s Modern Slavery Act.
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