CCLA published the Modern Slavery Global Benchmark 2025 (January 2026) which assesses the modern slavery-related disclosures of the top 100 global companies that operate in the UK by market capitalisation as of 31 March 2025, plus 11 additional companies that were assessed in the pilot and have been retained for ongoing analysis. The benchmark aims are threefold: 1) to assess how listed companies publicly disclose their approach to manage modern slavery risks and impacts; 2) to encourage improved practice; and 3) to be used as a tool for investors, who have a key role to play in working with companies to ensure that better practices are normalised and incentivised.
Human Level’s Take:
- Benchmarking shows a wide performance gap: leaders score up to 85%, while laggards score as low as 2%, highlighting significant weaknesses in corporate reporting and due diligence
- Strong company performance correlates with robust national human rights legislation, suggesting regulation plays a key role in driving better practices
- Nearly one-third of companies identified modern slavery cases; of those, 82% disclosed actions taken to address and mitigate risks
- So, what can companies do?
- Ensure human rights reporting complies with all applicable jurisdictions, including the UK
- Understand the UK Modern Slavery Act and updated Home Office guidance, and conduct a gap analysis against strengthened Level 1 requirements
- Establish strong governance, including board-level accountability and meaningful engagement with workers and stakeholders
- Conduct and disclose comprehensive risk assessments covering direct operations and multi-tier supply chains, informed by engagement with at-risk groups rather than desk-based analysis alone
- Disclose suspected cases, remediation actions taken, and outcomes for affected individuals
- Implement and report on responsible procurement practices that enable suppliers to meet the company’s codes of conduct and international standards
- Monitor evolving corporate sustainability due diligence legislation and import bans in both the EU and the United States, as well as in regions beyond like the Asia-Pacific region
Some key takeaways:
- Modern slavery is a critical global crisis: Estimates show that 50 million people are trapped in modern slavery, with 28 million being victims of forced labour, and these figures are likely to continue growing. The economic scale of forced labour is significant with $236 billion generated every year in illegal profits from forced labour. These profits directly derive from the coercive exploitation of vulnerable people. The private economy is implicated, accounting for 86% of all forced labour. Four sectors (i.e., industry, services, agriculture, and domestic work) accounts for 89% of all forced labour victims, highlighting the systemic nature of forced labour. At the same time, analysis by the ILO highlights how the return on investment of implementing key interventions to address forced labour can be threshold: the one-time cost of implementing key interventions to eliminate forced labour is estimated at $212 billion. Releasing 28 million people from forced labour and integrating them into the formal economy would generate an estimated $611 billion in additional global GDP. The report also outlines the lay of the land in relation to the corporate human rights reporting landscape, including how it is moving from voluntary principles (e.g., the UN Guiding Principles on Business and Human Rights) to mandatory legal obligations, driven by legislation, investor pressure, and a broadening understanding of corporate responsibility. The financial implications of enforcement under the laws is also highlighted by the report. For instance, between January and October 2025, the US Customs and Border Protection stopped 10,478 shipments of products valued at $890 million under the US Uyghur Forced Labor Prevention Act. While there is uncertainty around mandatory human rights due diligence in Europe, there are many positive developments in other parts of the world, especially in the Asia-Pacific region in countries like Thailand, South Korea, Indonesia, and Japan. For instance, Thailand has drafted the Act on the Promotion of Business Conduct 2025 which includes mandatory human rights and environmental due diligence provisions.
- The themes and results: The benchmark assesses companies’ modern slavery-related disclosures and ranks them according to five different performance tiers: 1) Leading on human rights innovation; 2) Evolving good practice; 3) Meeting basic expectations; 4) Developing approach; and 5) Unsatisfactory. Of the 111 benchmarked companies, five rank in the top performance tier, followed by 17 in the second, 41 in the third, 40 in the fourth, and 8 in the fifth. Companies in the top performance tier are considered leading on human rights due diligence (HRDD) with discussions of meaningful activities to find, fix and prevent modern slavery. 45 was the average percentage score, putting the average company in tier 3 (meeting basic expectations). In addition, 13 companies had not published a UK modern slavery statement that covered all their UK operations, highlighting the need for the UK Home Office to clarify which global companies are in scope of the 2015 Modern Slavery Act. In relation to key emerging themes, the benchmarking exercise demonstrates that:
- There is a compliance gap between UK-listed and global companies, with the latter underperforming their UK counterparts on the ‘UK Modern Slavery Act compliance and registry’ section of the benchmark. This underperformance likely reflects the fact that global companies have many human rights reporting requirements and may be less familiar with the details of how to comply with the 2015 UK Modern Slavery Act
- Companies still score higher on compliance and conformance with statutory guidance than on the voluntary performance metrics. For instance, companies score lower on the sections of the benchmark that are based on the UN Guiding Principles on Business and Human Rights and other international best practice standards (i.e., ‘Find it’ (38%), ‘Fix it’ (18%) and ‘Prevent it’ (41%)) - when compared to sections based on compliance with laws and statutory guidance (i.e., ‘UK Modern Slavery Act compliance and registry (63%) and ‘Conformance with UK Home Office guidance on modern slavery’ (62%))
- Performance scores varied significantly between the leaders and laggards, with the former scoring up to 85% and the latter scoring 2%. This highlights that there are significant room for improvement in corporate reporting and HRDD
- Country performance is likely linked to human rights legislation. The results indicate a correlation between companies that perform well on the benchmark and their listing in countries with more comprehensive human rights legislation
- Nearly a third of companies found modern slavery cases. 27 companies in total disclosed modern slavery findings in their operations or supply chains, with 82% of this group outlining the steps they had taken to end and mitigate ongoing risks
- What companies can do: The report outlines seven key recommendations for companies, which are:
- Ensure human rights reporting meets the requirements of all jurisdictions in which the business operates in, including the UK
- Become familiar with the scope of the UK Modern Slavery Act and the new UK Home Office guidance on transparency in supply chains and conduct a gap analysis at least against the new Level 1 requirements, which have been strengthened
- Ensure there is strong internal governance on modern slavery - including responsibility at board level and appropriate committees or structures - and be sure to include workers’ and relevant stakeholders’ perspectives
- Conduct and disclose detailed operational and supply chain risk assessments. These should include forced labour risks across supply chain locations (beyond tier one) and, importantly, direct operations. Risk assessments should go beyond desk-based assessments to include engagement with people at risk of modern slavery
- Disclose and provide details of suspected cases of modern slavery, the steps that have been taken to provide remedy for victims, and the outcomes of this process
- Adopt and disclose responsible procurement practices that enable suppliers to uphold the standards that are in the company’s supplier code of conduct and in line with international best practices
- Closely monitor developments in legislation on corporate sustainability due diligence in the European Union and import bans both there and in the United States
