20 November 2025
Leading UK companies have improved their performance in tackling modern slavery, according to CCLA’s updated investor-backed benchmark.
Finance sector firms have particularly increased their scores, accounting for six of the 10 most improved since 2023.
Few companies are going beyond regulatory compliance, with only a relative few seeking to actively fix modern slavery in their supply chains.
But regulation around the issue is set to tighten in the UK and overseas, meaning corporate performance will need to improve further.
UK companies have improved their performance in addressing modern slavery, according to the third annual assessment for CCLA’s UK Modern Slavery Benchmark. But with governments in the UK and overseas tightening rules designed to tackle forced labour and related abuses, companies need to go further to meet regulatory requirements and avoid economic risks from fines and litigation.
Financial services firms have particularly improved since investment firm CCLA first published the benchmark, in 2023. They account for six of the 10 most improved companies over that period.
In this year’s benchmark, 56 firms are in the top two of its five tiers, up from 46 last year and 37 when the benchmark was first published. However, six firms remain in Tier 4 (there are no companies in Tier 5) and disclosure remains uneven. And only 12 companies are in the top tier – the same number as last year – meaning that they are taking meaningful action to find, fix and prevent modern slavery.
Modern slavery is a moral stain on the global economy. Companies have a clear responsibility to stamp it out throughout their operations and value chains, and it is encouraging that companies assessed in our benchmark are improving their performance.
As investors, we have an obligation to work with companies to help them do so, and to hold them to account when they fail to take modern slavery seriously. Our benchmark brings much-needed transparency to the corporate response to modern slavery, and we encourage investors to join us in using it to engage with companies on the issue.
Peter Hugh Smith, CCLA Chief Executive
A tightening regulatory environment
Governments in the UK and around the world are responding to modern slavery with new regulations and the tightening of existing rules. For example, the British government’s Employment Rights Bill, which is going through Parliament, will create a Fair Work Agency with powers to investigate modern slavery. It is also facing calls to strengthen the regulatory framework centred on the 2015 Modern Slavery Act.1
In Europe, the Corporate Sustainability Due Diligence Directive (CSDDD), passed in 2024, requires large companies operating in the EU to conduct due diligence on their value chains to prevent violations of human rights, including modern slavery. While it is currently subject to review, its requirements are likely to continue to apply to the biggest companies.2 Germany, France and Norway have all introduced laws mandating human rights due diligence and therefore set higher standards than those in the UK.
Beyond Europe, countries in Asia such as Indonesia, Japan, South Korea and Thailand are starting to address modern slavery. Thailand has drafted a Mandatory Human Rights Due Diligence law3 and Japan introduced a voluntary Respecting Human Rights in Responsible Supply Chains framework in 2022.4 Australia has recently announced a tightening of its Modern Slavery Act 2018 and is considering introducing mandatory due diligence.5
Companies need to be aware that addressing modern slavery is not just the right thing to do – it is also a growing regulatory imperative. We are pleased to see countries around the world introducing legislation to tackle this scourge, and we urge the UK government to act to bring its 2015 Modern Slavery Act – which was world-leading when it was passed – up to date by ensuring that its transparency rules are tougher. But government needs to go further, requiring companies to undertake due diligence, and introducing an outright ban on the import of goods made with forced labour.
Dame Sara Thornton, Consultant Modern Slavery for CCLA
Our Joint Committee found that the UK’s patchwork of legislation is not preventing goods linked to forced labour from entering the UK market, nor is the Modern Slavery Act preventing forced labour in supply chains. It is clear that new legislation is required.
However, it is encouraging to see the current legislation being used by CCLA to hold UK companies to account, including for their performance in finding modern slavery and addressing it in line with the UN Guiding Principles on Business and Human Rights.
Lord Alton of Liverpool, Chair of the UK Parliament’s House Joint Committee on Human Rights
Improving performance – but more is needed
The assessment assigns companies to one of five tiers. Twenty-two companies improved their performance sufficiently to improve one tier this year. In addition, this year’s results show companies rising to tiers 2 and 3 – evolving good practice and meeting basic expectations – but few are advancing to tier 1, which denotes leading on human rights innovation. This is a sign that companies are achieving compliance with regulation but are not advancing sufficiently to take a leadership position on the issue.
We are concerned that too many companies are meeting the letter of the law but are not going further to find and fix modern slavery – by actively seeking it out in their operations and supply chains and providing redress to any individuals that have been affected. We will continue to engage with companies to encourage them to adopt leading practice.
Dr Martin Buttle, Better Work Lead at CCLA
Twelve companies are identified as ‘leaders in human rights’, in the top tier of the benchmark: Associated British Foods, British American Tobacco, Burberry Group, Imperial Brands, Intercontinental Group, J Sainsbury, Kingfisher, Marks & Spencer Group, NEXT, Reckitt Benckiser Group, Tesco and Unilever.
The highest scoring company in the benchmark was J Sainsbury.
In reaction to the company's achievement, Ruth Cranston, Director of Sustainability at Sainsbury's, said:
We can only live up to our commitment to make good food joyful, accessible and affordable for everyone, every day if the people in our business and supply chains are treated with dignity and respect. We're proud of the progress we're making in addressing modern slavery risks and upholding human rights, and are pleased to see this recognised by the CCLA in their latest benchmark. We're committed to continuing to work with our suppliers and partners to tackle these challenges, while supporting legislation that protects the workers and communities linked to our supply chains, helping us to secure a resilient and sustainable food system for generations to come.
Financial services firms are stepping up
The top 10 most improved companies since the benchmark was first published in 2023 are, in order of the number of points improved:
Investec, Airtel Africa, International Consolidated Airlines Group, Legal & General Group, London Stock Exchange Group, Beazley, Lloyds Banking Group, Croda International, M&G and St James's Place.
Six of these are Financial Services companies, illustrating how companies within the sector are responding positively to engagement from investors on the issue, and to the negative associations of lagging performance in a public benchmark during previous editions.
As part of its work on modern slavery, in 2019 CCLA founded the Find it, Fix it, Prevent it investor coalition to share knowledge, set targets and monitor the progress of addressing modern slavery in businesses’ supply chains. It is backed by 70 global investors, representing £19.3 trillion in assets under management.6
The Modern Slavery Benchmark provides a tool to help investors engage with portfolio companies to address modern slavery risks. CCLA has also committed to engage with companies performing most poorly in the benchmark in which it holds equity to encourage them to improve their performance and has engaged with 68 companies since the last report was published.
