Modern slavery statement

CCLA is convening the ‘Find It, Fix It, Prevent It’ programme that aims to mobilise the UK investment community to work against modern slavery.

If you would like to sign the Investor Statement, join the engagement group, or learn more about the project please visit www.modernslaveryccla.co.uk or email andrew.adams@ccla.co.uk to find out more.

CCLA Investment Management Limited (CCLA) manages investments for charities, religious organisations and public sector bodies, has 130 full time employees and a limited number of regular contractors. These are predominantly based in London, with a small presence in Edinburgh. We are largely owned by our clients, the two largest shareholders are The CBF Church of England Investment Fund and the COIF Charities Investment Fund. We have one, wholly owned, subsidiary; CCLA Fund Managers Ltd.

CCLA’s purpose is to help our clients maximise their impact on society by harnessing the power of investment markets. This requires us to provide a supportive and stable environment for our staff and deliver trusted, responsibly managed and strongly performing products and services to organisations, irrespective of their size.

Looking after charities, religious organisations and the public sector is all that we do. The majority of our clients invest via one of our pooled funds. We offer three, flagship, multi-asset Investment Funds and a suite of single asset class funds covering global equities, fixed income, the money markets and commercial property. 

We are committed to respecting human rights in all our operations and, whilst CCLA is a small business with a limited number of suppliers, we are aware that modern slavery (for the purposes of this statement modern slavery is defined as modern slavery, servitude, forced or compulsory labour and human trafficking) is likely to be present in the supply chain of nearly every company. For this reason, we assess potential suppliers’ approach to addressing modern slavery prior to us entering into a business arrangement. We also regularly review the approach taken by our existing suppliers and pay particular attention to the 20 largest. Where we have questions or concerns, we meet with the management of the supplier in question. During the reporting year our analysis identified one supplier that operates in a high-risk sector but does not meet the revenue threshold required to report under the Modern Slavery Act. For this reason, we met with them to discuss their approach to sourcing the materials that they use.

Whilst our direct operations are limited to the UK we invest our clients’ assets in businesses that have global operations and supply chains. As a consequence, we believe that our highest exposure to modern slavery is likely to be through the companies and assets held in client portfolios. To address this, we have developed an active engagement programme that encourages prioritised investee businesses to develop strong governance mechanisms to identify, and then address, instances of modern slavery. During 2019-2020, we developed the ’Find It, Fix It, Prevent It’ engagement initiative which is seeking to act as a catalyst for investor action on modern slavery. This has involved developing open source materials, engaging with companies and promoting more meaningful public policy.  We were disappointed that none of the businesses that we invest our clients’ capital in reported finding, and providing remedy to, victims of modern slavery in their supply chain this year and are hopeful that our enhanced engagement programme will increase the effectiveness of corporate action on this horrific crime.

As CCLA’s Chief Executive, I am responsible for the implementation of this policy and our wider adherence with the UN Guiding Principles on Business and Human Rights and the ILO Core Labour Standards. I am assisted in this by the company’s Modern Slavery Working Group, which includes members from each of our major business areas.

Peter Hugh Smith
Chief Executive, CCLA

June 2020

This statement for our financial year ending 31 March 2020, has been approved by the Board of Directors of CCLA and has been published in compliance with Section 54 of the UK Modern Slavery Act 2015. CCLA Investment Management Limited and CCLA Fund Managers Limited are authorised and regulated by the Financial Conduct Authority.