26 March 2025

Rathbones’ ‘Votes Against Slavery’ targets FTSE 350 and AIM companies for breaches of Modern Slavery Act disclosure requirements

  • Award-winning* ‘Votes Against Slavery’ initiative launches sixth campaign.

  • Engagement targets 86 companies.

  • Includes a record 168 investors with combined funds under management of £2.96tn.

In the tenth year since the introduction of the Modern Slavery Act 2015 (the “Act”), Rathbones, one of the UK’s leading wealth and asset management companies, has launched its sixth Votes Against Slavery campaign (VAS), securing support from a record 168 institutional investors, with funds under management totalling £2.96 trillion**.

To address non-compliance with the Act, in 2020 the Rathbones Stewardship team began challenging companies suspected of not meeting the reporting requirements. "In the absence of regulatory enforcement, investors have a vital role to play in respecting fundamental human rights,” said Matt Crossman, Stewardship Director, Rathbones.

“On average, it takes around seven interventions before someone being exploited is identified and rescued. So, this is about encouraging companies to identify any suspicious behaviours on which they can then act.

“Investors hold considerable influence, particularly through voting on standard AGM resolutions. This is about urging investors to exercise their strongest form of censure, and voting against the annual report and accounts of companies that fail to comply with the Act. We also call on the Government to commit to making changes to the current Act, to make it stronger, clearer, and more effective.”

Modern slavery has a significant human and economic impact globally. A 2024 report from the International Labour Organisation (ILO) found that forced labour in the private economy generates US$236 billion in illegal profits per year. While the UK’s response has improved due to the introduction of the Act, there are currently no effective sanctions being used for those companies that fail to comply.

The 2025 engagement, led by the Rathbones’ team and co-ordinated through the UN PRI Collaboration Platform(1), has brought together asset managers and asset owners to target both AIM and FTSE 350 companies, suspected of failing to comply with Section 54 disclosure requirements of the Act***. This requires companies to publish an annual statement on their efforts to prevent modern slavery happening in their operations and supply chains.

This year 61 AIM companies and 25 FTSE 350 companies have been engaged by a record total of 168 investors.

Further policy engagements 
In 2024, Rathbones and asset manager CCLA jointly submitted to the House of Lords consultation on the impact of the Modern Slavery Act. Alongside CCLA, Rathbones will continue its policy engagement with the Home Office, with the aim of strengthening the quality of Section 54 of the Act.****

And along with CCLA and Walk Free, the international human rights group, Rathbones also submitted to the ‘Joint Committee on Human Rights call for evidence into forced labour in UK supply chains’, which referenced VAS and CCLA’s ‘Find it, Fix it, Prevent it’ initiative, a collaborative investor engagement programme with the aim of helping companies find, fix, and prevent modern slavery in their supply chains.

Archie Pearson, ESG and Stewardship Analyst and Voting Lead, said: “This is a poignant anniversary. Despite the Modern Slavery Act, Walk Free estimates that there are still nearly 50 million people trapped globally in modern slavery. Although there has been some progress, there’s a frustrating lack of headway. We believe the Government, which is responsible for protecting against modern slavery in the UK, should be prepared to use the sanctions available within the Act against those companies which fail to produce adequate modern slavery statements.”

Ends

For further information, please contact: 
Tessa Curtis, Rathbones Group - Tessa.Curtis@rathbones.com - +44 (0)7833 346 238

Frances McNab, Rathbones Group - Frances.McNab@Rathbones.com - +44 (0)7585 981 924

Madhu Kalia, Rathbones Group - Madhu.Kalia@Rathbones.com - +44(0)7825 596 302

Sam Emery, Quill PR - Sam@quillpr.com - +44 (0)7798 881 770

The information contained in this note is for use by professional investors and journalists and must not be circulated to private clients or to the general public.

Notes to editors:
If you wish to see a list of the participating investors in the 2025 Votes Against Slavery engagement, please do get in touch.

(1)    PRI Collaboration Platform
The Collaboration Platform is a unique form that allows investors to pool resources, share information and enhance their influence on ESG issues. It is also a hub for academics and investors to connect and engage with research. Posts include invitations to sign join letters to companies and join investor-company engagements, proposals for research, calls to foster dialogue with policy makers and requests for support on upcoming shareholder resolutions.

For further information, please see: https://collaborate.unpri.org/

* The Votes Against Slavery campaign, co-ordinated through the UN PRI Collaboration Platform and led by Rathbones’ Stewardship team, won the UN PRI Awards 2022 ‘Stewardship Initiative of the Year’ award.

* Environmental Finance - ESG engagement initiative of the year, EMEA: Votes Against Slavery 2024

**At time of writing.

***Section 54 reporting requirements of the Modern Slavery Act 2015:

1. Companies should update modern slavery statement every year: the Home Office statutory guidance states that companies should do this within six months of their financial year-end.

2. Companies should publish their modern slavery statements on their UK websites: a link should be published in a prominent place on their homepage

3. Companies should get approval from the board of directors: the statement should clearly state that the board approval has been given, along with the date of approval

4. Companies should get sign-off from a director: this should include the director’s name, job title and the date. It does not require a physical signature, but it should still clearly state that it has been signed.

**** Government response to House of Lords Modern Slavery Act 2015 Committee report, 'The Modern Slavery Act 2015: becoming world-leading again' (accessible) - GOV.UK

Matt Crossman, Stewardship Director, Rathbones
Matt is the stewardship director for the group. Overseeing the work of the stewardship committee, he ensures active voting at company AGMs, whilst also being the Vice Chair of the Responsible Investment Committee and a member of the ESG Integration Committee. He also leads thematic engagement with companies on ESG issues, especially that undertaken via the UN-backed Principles for Responsible Investment. He is a graduate of the University of Bristol where he studied law, with a particular interest in the administration of environmental law, and also has post-graduate qualifications in Sustainable Development theory and practice. He is a trustee of LoveBristol, and urban regeneration charity, and served on the board of the Ecumenical Council for Corporate Responsibility between 2007 and 2012.

Archie Pearson, ESG & Stewardship Analyst - Voting Lead, Rathbones
Archie joined Rathbones in 2018 as a voting and governance analyst. He supports Matt Crossman on the stewardship team, ensuring informed proxy voting and corporate engagement activities as part of Rathbones’ stewardship policies, and helps to promote the integration of ESG within the investment process. Prior to Rathbones, Archie worked for Oikocredit. During his time there, he worked as a client executive, tasked with generating capital from individuals and institutions. Archie graduated in 2015 from the University of Edinburgh with an MA in Theology.

Previous Votes Against Slavery engagements 
2024
The 2024 Votes Against Slavery engagement comprised 154 investors with £1.99 trillion in assets under management. The campaign targeted 158 FTSE 350 and AIM companies. Of those 112 subsequently became compliant with the Act.

2023
For the 2023 Votes Against Slavery campaign, 132 investors representing £8.1 trillion in assets under management supported the engagement. 29 FTSE350 companies were targeted, including 16 normal operating companies and 13 investment trust companies. As a direct result of the engagement, 27 companies became compliant with the Act or confirmed to the coalition’s satisfaction that no statement was required (and committed to make this clearer in future reporting).

2022
In the 2022 Votes Against Slavery campaign, 122 investors representing £9.6 trillion in assets under management supported the engagement. Of 44 FTSE 350 companies targeted, 41 were compliant with section 54 of the Modern Slavery Act (2015) in January 2023.

2021
Rathbones welcomed 97 investors with £7.8 trillion in assets under management to the coalition in 2021. Of 61 companies in the FTSE350 identified as non-complaint, by the year end, 59 companies (97%) had become compliant as a direct result of the engagement. The remaining two companies became compliant in January 2022.

2020
In 2020, 20 investors supported with £3.2 trillion in assets under management. As a result of the engagement, 20 out of 22 companies contacted (90%) were compliant as of 31 December 2020.