28 May 2025
- Global companies on average scored lower than UK companies in the 2024 benchmark, suggesting the UK imports greater modern slavery risk through its open markets
- There was significant disparity between the best (Cisco Systems, Costco, and Nestlé) and worst performing companies. 4 firms scored less than 12 out of a maximum of 62 points – raising questions about minimum compliance
- A gap exists between policy and practice, with greater transparency on policy and procedure and less disclosure on practice and how the harm to victims was rectified
- Only one in four companies (23) disclosed finding a case of modern slavery, and just one company confirmed that victims were satisfied with the redress provided
- Consumer staples and materials were the highest scoring sectors with financials and energy the lowest
CCLA today announced the launch of its inaugural Global Modern Slavery Benchmark Pilot to evaluate how global companies combat modern slavery in their operations and supply chains. The pilot benchmark assesses the efforts of the 100 largest globally listed companies by market capitalisation1 that provide goods or services within the UK and are therefore subject to the UK Modern Slavery Act .2
As the UK marks the 10-year anniversary of its landmark Modern Slavery Act 2015, the benchmark assesses corporate performance against UK statutory requirements, government guidance, and international human rights standards, to support investors in understanding the forced labour risks in their global holdings and to help with corporate engagement.
One of the key questions we had is to what extent foreign domiciled companies respect UK reporting requirements in both letter and spirit? As investors, we expect businesses to undertake human rights due diligence, not merely as part of a tick-box exercise, but dedicating appropriate care and resources to play their part in addressing and preventing modern slavery in their businesses and supply chains. We have seen companies in CCLA’s UK Modern Slavery Benchmark improve and we hope to see this trend reflected in the global benchmark also.
Dr Marin Buttle, Better Work Lead at CCLA
The benchmark showed plenty of room for improvement with global companies scoring less (average was 30/62) than those included in the UK benchmark last year (average was 36/62).3 There was also significant disparity between the top performer (score of 53) and the lowest performer (score of 3).
Notably, across the benchmark sections, compliance with Modern Slavery Act and conformance with the Home Office Guidance4 were the strongest scoring areas. A gap exists between the number of companies disclosing policies on responsible procurement (48) while relatively few (9) disclosed how this worked in practice.
The fact only 23 companies disclosed finding a case of modern slavery, raises questions on the effectiveness of due diligence processes and limits companies in their approach to providing redress to victims on the basis that ‘you can’t fix what you have not found’. For the companies that have disclosed, this level of transparency should be recognised and encouraged.
Concerningly, the lowest average scores (1.5/8) were in relation to providing redress to victims of forced labour. Of the 23 companies that disclosed finding modern slavery, only 13 companies reported the outcome of providing redress to victims, and only one company disclosed that survivors had been satisfied with the redress provided to them.
This benchmark shows too many businesses focussed merely on policies and compliance rather than developing robust discovery and redress practices. Companies can and must do more than simply meet the minimum requirements. There is an opportunity for companies to ensure liberty and dignity for their employees and those within their supply chains. Modern slavery is endemic, but companies can play a vital role in changing victims’ lives for the better. The true measure of a company is not whether there is forced labour within their supply chains, but how robustly they look for it, and what they do when they find it.
Peter Hugh Smith, CCLA Chief Executive
Sectoral results
There were notable differences between sectors. Sectors like financial services and energy, perceived to have a lower risk of forced labour, were lowest scoring suggesting they may have developed less robust practices for finding it. For example, while the finance sector has less exposure to risk in its supply chains, the greatest exposure to risk is in its downstream value chain either via investments or customers.
Meanwhile, historically higher-risk sectors like consumer staples and materials have evolved to be more proactive, therefore score higher. The technology sector scores positively in their discovery mechanisms but less well in prevention measures such as responsible supply chain exit and supplier disclosure.
A growing global issue
Modern slavery, encompassing human trafficking, forced labour, and exploitation, is a pervasive global issue, with nearly 28 million people in conditions of forced labour worldwide.5 In 2021, G20 countries imported US$468 billion worth of goods at risk of modern slavery, according to international human rights group Walk Free.6 The International Labour Organization estimates that forced labour in the private sector generates US$236 billion in illegal profits per year since 2014.7
Both the US and the European Union have developed legislation to prevent the import of goods and services tainted with modern slavery into their territories.8 For example, in 2024 the US Customs Border Enforcement Agency blocked US$0.23bn worth of goods from entering the US under the Uyghur Forced Labour Prevention Act based on a rebuttable assumption they were tainted by forced labour.9
The UK Modern Slavery Act was world-leading in 2015, but that was a decade ago now. As peer nations continue their progress to toughen legislation to combat modern slavery, notably the EU and the US, we are now falling behind, leaving the UK exposed to being seen as a dumping ground for goods tainted with forced labour. As a first step we would like to see the UK Modern Slavery Act require companies to disclose modern slavery when they find it. This would give investors and others good indications of how hard companies are looking for it and would focus accountability for providing redress to victims.
Dame Sara Thornton, Director, Modern Slavery at CCLA
Methodology
The assessment framework was developed from CCLA’s Find it, Fix it, Prevent it initiative which was created to guide investors’ engagements with companies.
It is based on the UN Guiding Principles on Business and Human Rights (UNGP) and draws on existing best practice developed by the likes of the Business and Human Rights Resource Centre, the UK Ethical Trading Initiative and KnowTheChain.11 All the questions in the benchmark’s framework are derived from international standards, widely used and recognised frameworks, and best practice standards.
The framework of the Modern Slavery Benchmark is broken down into five sections: Modern Slavery Act compliance and registry; Conformance with Home Office Guidance; Find it; Fix it; Prevent it.
The benchmark assesses the modern slavery related disclosures of the top 100 Global companies by market capitalisation that “supply goods or services” in the UK and are therefore subject to Section 54 of the UK Modern Slavery Act.12
Please find the full methodology here.