For financial year ending 31 March 2025

Introduction

CCLA Investment Management Limited (CCLA) remains committed to eradicating modern slavery and human trafficking across our operations and supply chains. In 2025, we strengthened our governance framework, enhanced supplier due diligence, and expanded our engagement through the Find it, Fix it, Prevent it coalition. We have also produced other media such as film/video for staff, clients, suppliers and other stakeholders on modern slavery and CCLA’s distinctive approach. These actions reflect our determination to move beyond compliance and deliver measurable impact, in line with the UK Modern Slavery Act and international best practice.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and covers the financial year ending 31 March 2025.

About CCLA

CCLA Investment Management Limited is a private company limited by shares, registered in England and Wales and incorporated in the United Kingdom, providing investment management products and services to charities, Church of England organisations, the public sector and retail clients. CCLA Fund Managers Limited is a wholly owned subsidiary of CCLA Investment Management Limited.

CCLA shareholders are dominated by the funds we manage:

  • The CBF Church of England Investment Fund (53.69%)
  • COIF Charities Investment Fund (22.37%)
  • The Local Authorities Mutual Investment Fund (13.42%)
  • Employees (10.52%)

We manage over £15 billion on behalf of more than 32,000 not-for-profit clients and offer a variety of investment solutions to meet the needs of our clients. These include: multi-asset class pooled funds and single asset class pooled funds, which cover bonds, cash, equities and property, and may be used alone or in combination (usually as part of a client’s investment strategy) managed funds service, which offers clients a blended portfolio using CCLA funds segregated investment services for clients where, for various reasons, pooled funds are not appropriate.

While our clients are based in the UK, we are global investors. Our funds and products are managed responsibly and in line with our clients’ values.

CCLA is committed to ensuring that its dealings with its own employees, and with its suppliers, are conducted ethically and responsibly. Our clients are UK-based, we are global investors, and our funds are managed responsibly in line with our clients’ values.

Governance

The CCLA Board retains ultimate responsibility for our modern slavery policy. It consists of three executive directors, three non-executive directors representing our largest shareholders, and three independent non-executive directors (including the Chair).

In 2024, we formally established a Modern Slavery Committee chaired by an executive director. In 2025, the committee met three times (February, July, November) and expanded its remit to include monitoring KPIs and reviewing supplier dashboards. Membership includes representatives from finance, risk, compliance, legal, IT, HR, market development and sustainability.

Organisational structure and workforce

The Chief Executive leads implementation of our modern slavery policy, supported by the Executive Committee. As of December 2025, CCLA employs 190 staff and two contractors. None were outsourced. We disclose workforce composition to ensure transparency, recognising that flexible and outsourced workers can be more vulnerable to exploitation.

Policy framework

Our nine guiding principles remain unchanged:

  • Employment is freely chosen.
  • Freedom of association is respected.
  • Working conditions are safe and hygienic.
  • Child labour shall not be used.
  • Living wages are paid.
  • Working hours are not excessive.
  • No discrimination is practised.
  • Regular employment is provided.
  • No harsh or inhumane treatment is allowed.

Suppliers must comply with these principles and relevant ILO Conventions, applying a risk-based approach to their own supply chains.

Modern slavery and CCLA

We define modern slavery in line with the UN: “Modern slavery is an umbrella term encompassing slavery, servitude, human trafficking and forced or compulsory labour.”

We acknowledge that modern slavery is systemic and may exist in any supply chain. While most of our direct suppliers are professional services (low-risk sectors), we recognise elevated risks in technology hardware, construction (linked to property funds), and hospitality services.

We believe our risk in our direct operations and supply chain to be low, as we are a professional services company and the majority of our 700 suppliers are based in the UK.  We believe our biggest modern slavery risk lies in our investments.

Due diligence and risk assessment

Supplier management platform
Implemented in Q4 2025, providing real-time dashboards for compliance monitoring of our suppliers.

Enhanced questionnaires
Now include detailed questions on human rights, grievance mechanisms, and governance.

Risk mapping
Completed geographic mapping of suppliers and initiated indirect supplier risk assessments.

Escalation process
CCLA expects its suppliers to uphold international labour standards, human rights and align with the Ethical Trading Initiative Base Code. Non-compliance triggers corrective action plans; persistent breaches lead to responsible exit.

Actions taken in 2025

Sustainability initiatives
Hosted roundtables on AI-driven risk detection, construction sector vulnerabilities, and seasonal agriculture.  Held seminars for investors on developments in due diligence legislation across Asia, the work of Investors Against trafficking Asia Pacific and the role of investors in promoting remedy.

Corporate engagement
Engaged with 68 companies in the CCLA Modern Slavery Benchmark.

Training
Mandatory e-learning achieved 100% completion rate; supplemented by Lunch & Learn sessions and video content.

Collaboration
Continued leadership in Find it, Fix it, Prevent it coalition and UN PRI Advance programme.

Impact case studies

Case study 1: supplier risk escalation

During routine monitoring, our dashboard flagged a Tier 1 supplier in facilities management for incomplete compliance documentation.

Action taken:

  • Initiated an urgent review and requested corrective action within 14 days.
  • Supplier implemented enhanced labour checks and provided evidence of worker protections.

Outcome:

  • Compliance restored; supplier retained under strict monitoring.
  • Lessons shared internally to strengthen onboarding protocols.

 

Case study 2: collaborative remediation

Through the Find it, Fix it, Prevent it coalition, we identified a subcontractor in the construction sector with potential recruitment vulnerabilities.

Action taken:

  • Worked with the prime contractor to implement ethical recruitment standards.
  • Provided training resources and guidance on grievance mechanisms.

Outcome:

  • Subcontractor adopted new policies and reported zero recruitment-related risks in subsequent audits. 

 

Case study 3: technology-driven risk detection

Leveraging AI-based screening tools piloted in 2025, we detected elevated risk indicators in a technology hardware supplier’s extended supply chain.

Action taken:

  • Engaged directly with the supplier to review sourcing practices.
  • Required disclosure of labour conditions in upstream factories.

Outcome:

  • Supplier committed to quarterly reporting and joined an industry initiative on responsible sourcing.

Measuring effectiveness:

  • 100% Tier 1 suppliers assessed against modern slavery criteria.
  • 100% staff completed on-line training (target mark: 75%).
  • Strengthened detection and remediation protocols.

Beyond procurement: active ownership

We continue to use our influence as investors to combat modern slavery:

  • Supported shareholder proposals urging Nike to review cotton sourcing from high-risk regions.
  • Engaged Compass Group on ethical recruitment and migrant worker protections.
  • Led engagement under UN PRI Advance with a US clean energy utility to address solar supply chain risks.

Future commitments (2026)

  • Extend risk assessments beyond Tier 1 suppliers.
  • Publish anonymised remediation case studies.
  • Develop and integrate KPIs in greater detail for our downstream value chain.
  • Consider integrating modern slavery KPIs into executive performance reviews.
  • Align with anticipated Home Office guidance updates.

Board approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes CCLA’s slavery and human trafficking statement for the financial year ending 31 March 2025 and was approved by the Board of CCLA Investment Management Limited on 19 November 2025 and signed by:

Peter Hugh Smith, Chief Executive                                       

Richard Horlick, Chairman of CCLA Investment Management Limited