16 October 2025

31 of 32 FTSE 350 companies comply with UK S54 of Modern Slavery Act after Rathbones Votes Against Slavery engagement

 

  • Rathbones coalition drives compliance among FTSE 350 and AIM companies following targeted engagement
  • Estimated 50 million people trapped in modern slavery around the world
  • Votes Against Slavery, in its sixth year, now backed by 168 investors with £2.96tn AUM, as pressure mounts for stronger legislation

 

Rathbones, one of the UK’s leading wealth and asset management groups, is pleased to report that 31 out of 32 FTSE 350 companies engaged through its 2024 Votes Against Slavery initiative are now compliant with Section 54 of the UK Modern Slavery Act 2015. The final company has committed to make changes.

Led by Rathbones and coordinated through the United Nations Principles for Responsible Investment (UNPRI) Collaboration Platform, the Votes Against Slavery coalition 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 UK Modern Slavery Act 2015. The Act is crucial for the success of the legislation and requires companies to publish an annual statement on their efforts to prevent modern slavery happening in their operations and supply chains. 

Fifty million people are trapped in modern slavery around the world, including 28 million in forced labour, creating untold human harm and posing a significant ethical, legal and financial risk for companies and their investors. Rathbones 2024 Votes Against Slavery report, published today, details that:
 

FTSE 350

  • 31 out of 32 FTSE 350 companies have become compliant
  • The final company committed to make changes but remains non-compliant
     

AIM

  • 81 out of 126 AIM companies have become compliant
  • 9 committed to make changes
  • 11 required further engagement/monitoring
  • 11 did not respond
  • 14 either delisted, had their shares suspended from trading on AIM or explained they followed a different slavery Act (but one had still committed to become compliant).


Matt Crossman, Stewardship Director at Rathbones, said: “As long-term investors, we believe it’s fundamental that companies comply with all provisions of the Act to demonstrate a strong commitment to fighting modern slavery, helping to tackle a systemic problem affects supply chains across our portfolios. A company that does this gives investors more confidence in its risk management culture and signals a commitment to uphold basic human rights and demonstrate transparency and accountability in their operations.

“Since 2020 the coalition has grown from 20 investors to 168, a fact we are very proud of which highlights the growing importance of this issue to investors. We call on the Government to commit to making changes to the current Act, to make it stronger, clearer, and a more effective tool for investor engagement.”

As part of its 2024 activity, Rathbones reviewed the full list of companies on the FTSE 350 and AIM indices and investigated their level of compliance against Section 54 reporting requirements of the UK Modern Slavery Act 2015. The coalition sent the letters to non-compliant companies in March, ahead of the AGM season, to allow companies an opportunity to make changes to their existing modern slavery statement or confirm that they would make changes to the next one. If a company is still non-compliant by the time of its AGM, members of the coalition will give consideration to voting against management.

In the second half of the year, the Rathbones team organised follow-up meetings with target companies to discuss the content of their modern slavery statements and strategy for eradicating modern slavery within their supply chains. Within the time period, the team had meetings with 14 FTSE 350 and AIM listed companies.

Archie Pearson, ESG and Stewardship Analyst and Voting Lead, said: “Businesses play a huge role in eradicating modern slavery. It has been ten years since the Modern Slavery Act 2015 sought to bring the business community to the fight and although the act had good intentions, reporting on modern slavery in companies’ supply chains remains patchy, something we aim to strengthen by engaging with companies, investors and government agencies.

“We will continue our joint policy engagement with CCLA, where we are speaking to the Home Office on how to strengthen the quality of Section 54. The Labour Government in the UK is aware that the UK can no longer lay claim to leadership in this area and is planning to make Parliamentary time available for reforms to the Modern Slavery Act in 2026.”