Beyond Compliance
in the Finance Sector:

A review of statements produced by asset managers
under the UK Modern Slavery Act.

Download Dataset

Contribute Research


Modern slavery represents a tragic market failure, where some companies maintain competitive advantage and large profits through unethical and unsustainable business practices that rely on the exploitation of workers.

In 2020, Walk Free, WikiRate, and the Business & Human Rights Resource Centre assessed the statements produced by 79 asset managers identified as having to report under the MSA. These statements were assessed against:

The purpose of the assessment was to understand the level of awareness of modern slavery risks among asset managers, to identify good practice, and to highlight gaps in reporting. By conducting this assessment, we aim to support the financial sector to improve transparency and drive better practice.

For more information about this project, please visit:

How to use this page

The below highlights the key findings of our assessment of asset managers’ MSA statements. These findings are organised by sections outlining the level of disclosure in line with the minimum requirements, the Home Office guidance, and the consideration of modern slavery risk in investment portfolios.

Click any section to investigate the data behind our assessment. Clicking on the subtitle of a graph will take you to the overall results for that metric, while clicking on a particular section of a graph will take you to the relevant underlying data.

The ‘Filter the data’ option on the top right allows you to examine the data by AUM category, geographical region, or membership of FTSE 100, S&P 500, or PRI.

In this section, we analyse the minimum requirements under Section 54 of the MSA, where each statement must be signed by a director (or equivalent), approved by the Board of Directors (or equivalent management body), and linked from the company’s homepage.

Companies Meeting Minimum Requirements

Do the statements meet the minimum requirements?

Reporting Periods for Assessed Modern Slavery Statements

How recent are the modern slavery statements?

Companies meeting minimum requirements

Which minimum requirements do these companies meet?

Beyond minimum requirements in the MSA, the accompanying Home Office statutory guidance outlines the actions companies should take to ensure their supply chains are free from exploitation. From this guidance, we developed further metrics which we present in this section organised under the following groups:


Disclosing ownership structures and supply chains is an important step towards greater transparency and improves understanding of where risk may occur.

Ownership Disclosure

Supply Chain Disclosure


Policies are important for companies to establish their priorities for their direct operations and supply chains.

Modern Slavery Supply Chain Policies

Which modern slavery policies are mentioned in the statements?

Addressing Risks

Assessing and identifying modern slavery risks is an important part of targeting effective responses and resources.

Risk Assessment

Which risk assessment tools are mentioned in statements?

Risks identified by risk category

Which risks are identified in the statements?

Risk Management

Which risk management strategies are disclosed in the statements?

Risk Assessment Tool & Risks Identified

How many companies disclose using risk assessment tools and identifying risks?

Whistleblowing and Remediation

As part of companies’ responsibility to respect workers’ rights, those affected by modern slavery or witnessing violations in any part of a company’s operations should be able to freely report incidents through grievance mechanisms. Companies should also have remediation procedures in place.

Whistleblowing or Grievance Mechanisms

What whistleblowing or grievance mechanisms are disclosed in the statements?

Incident Remediation

What incident remediation strategies do companies mention in their statements?

Training and performance

Training is important for raising awareness of the issue of modern slavery, while helping employees and suppliers identify risks, and how to address them.

Companies can use key performance indicators to measure effectiveness and can review business KPIs to understand how their business needs may increase the risk of modern slavery.

Modern Slavery Training

How many statements disclose modern slavery training provisions and to which target audiences?

Key Performance Indicators

How many statements disclose key performance indicators on the effectiveness of modern slavery responses and review business KPIs to ensure the risk of modern slavery is not increased?

All metrics (in line with Home Office guidance)

This graph shows how many metrics derived from the Home Office guidance are met by companies.

Disclosure Rates by Asset Manager

Investors which do not integrate ESG considerations into their investment practices and decision making are failing in their fiduciary duties. Modern slavery is clearly a human rights and labour standards issue and should be considered as part of the S in ESG. Reporting on addressing modern slavery risks in MSA statements is good practice, offering an opportunity for asset managers to show transparency and leadership.

Despite this, many asset managers do not disclose modern slavery risks as a consideration in their investment decisions.

The investor-specific metrics used to assess the statements were:

  • Takes part in modern slavery industry initiatives
  • Has a human policy for investments
  • Requires investees to report under the UK MSA
  • Conducts risk assessment prior to investment
  • Engages with investees on human rights matters

Modern Slavery Due Diligence Processes in Investments

How many statements disclose due diligence processes in investments?

Modern Slavery Due Diligence Processes in Investments

What due diligence processes in investments are disclosed by the statements?

Investment Portfolio Due Diligence

Are asset managers engaging with their investment portfolios on modern slavery?