By Clive Booth ESG Foundation Board Member

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

By March 26, 2025No Comments

“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, 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.”

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

Sam Emery, Quill PR                                                                       Sam@quillpr.com

+44 (0)7798 881 770