Goal 8.7 of the UN Sustainable Development Goals calls for ‘immediate and effective measures to eradicate forced labour and end modern slavery and human trafficking’. To support this goal, CCLA has spent years bringing investors together to help improve the efficacy of corporate action to find and fight modern slavery in supply chains.
Modern slavery is an umbrella term encompassing slavery, servitude, human trafficking and forced or compulsory labour. Victims are controlled by punishment, debt bondage, threats, violence, deception and coercion. Whilst the true extent of this crime is hidden from view, the International Labour Organisation (ILO) estimates that 50 million people worldwide are in a state of modern slavery.
While some companies are more exposed than others, we believe that all businesses are linked to modern slavery in some way; either directly, or indirectly via their supply chains. We believe that companies have an obligation to work to find, and then support the provision of remedy to, victims of modern slavery in their supply chain and direct operations.
We look to tackle modern slavery across three work streams:
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Corporate engagement
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Public policy
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Developing better data
CCLA Modern Slavery UK Benchmark
Having identified a gap in the modern slavery data available to investors, we set out to build a benchmark that assesses and ranks companies based on their modern slavery disclosures.
Launched in November 2023, the aims of the CCLA Modern Slavery UK Benchmark are 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 developed guidance, and international voluntary standards on business and human rights
- support modern slavery engagement by investors
- provide a vehicle for learning and knowledge sharing
- introduce a sense of competition between businesses, thereby expediting improvement in corporate practice.
The benchmark assesses 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 outlined in the Home Office Guidance on Modern Slavery
- report on efforts to find, fix and prevent modern slavery.
Companies are assigned to one of five performance tiers that correspond with the Independent Anti-Slavery Commissioner’s ‘IASC Maturity Framework’.
Engagement with benchmarked companies
During the assessment process, each company was provided with a scorecard and given four weeks in which to respond. We liaised with 60 companies to discuss our findings and to suggest ways in which each could improve.
Key findings
Find it, Fix it, Prevent it
Find It, Fix It, Prevent It (FFP) 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 NGOs to share knowledge, set targets and monitor progress.
FFP is designed to harness the power of the investment community to make the corporate response to modern slavery more effective.
In 2023 there was significant progress in the EU on the development of a new directive that is designed to make environmental and human rights due diligence mandatory for businesses. Progress in the UK, however, has been much slower and there has been little movement on modern slavery policy and on business and human rights more broadly.
We have continued to advocate for clear legislation requiring asset managers and other investment businesses to report annually on the steps that they have taken to uncover and fight slavery in their portfolio. We submitted written evidence to the Home Affairs Committee’s inquiry into trafficking and CCLA’s Dame Sara Thornton gave oral evidence to the committee arguing for the explicit inclusion of financial portfolios.
Our work on the CCLA Modern Slavery UK Benchmark demonstrates the need for the Home Office guidance on transparency in supply chains to be updated and we have raised this as a member of the newly formed Home Office Modern Slavery Engagement Forum.
In 2023 we signed a Knowledge Partnership with Finance Against Slavery and Trafficking (FAST), a public-private partnership based at the United Nations University Center for Policy Research in New York. FAST has since contributed two knowledge events to CCLA’s Find it, Fix it, Prevent it collaboration.
We welcomed the Department of Work and Pensions’ focus taskforce on social factors in pension scheme investments. We contributed to the draft consultation paper published in October 2023 and were pleased to see that Find it, Fix it, Prevent it features as a case study of good practice.
Following our work on an investor statement in respect of seasonal workers in the agricultural sector, we contributed to the Independent Review into Labour Shortages in the Food Supply Chain and welcomed its recommendations. We subsequently wrote to the Secretary of State to commend the report and to urge acceptance of its recommendations on migrant labour, labour market enforcement and better data. The Minister has invited us to meet with him.
