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The UK Modern Slavery Act 2015 requires organisations to certify that they protect individuals in their organisations and supply chains from slavery anywhere along their supply chain, from raw material extraction to the final customer, for the purpose of service provision or production.The UK government claims this protects companies and institutions from reputational damage and promotes sustainability but even universities, which should have the easiest time complying, are unable to keep up with the bureaucratic demands. 

Government believed that by creating a regulatory requirement, the business and government community would be motivated to create a culture of continuous improvement, where organisations developed new and better ways of addressing modern slavery and shared those innovations with others for the greater good. Instead they got what critics said they would get; a box-ticking approach to basic compliance because it's a problem so few companies and institutions have it is just greater expense. Few feel like they are helping anyone in developing nations.

Some of it is inability to comply with rules that politicians create without understanding the challenges in implementation. Only around a quarter of UK universities can fully comply for various reasons. They are publicly funded, for example, which means they often buy through consortia and cannot have clear view of the supply chains to conduct effective due diligence. A university is often at end of the chain, meaning they did not have effective in-house supply chain management skills and were reliant on the guarantees of third-party suppliers. So they are compliant, but it may be making no difference at all.

Supply chain investigation is not a core function of universities so they feel all they can do is check off the boxes, but they have greater expenses doing it. Government believed there would be a groundswell of enthusiasm by groups forced to comply, instead the enthusiasm was for minimizing the cost; by sharing templated mission statements or showing each other how to achieve a basic level of pro-forma compliance. Even that is not being done. An organization that spent a lot of money on website design is now being told to put the anti-slavery statement on their and another requirement is for an executive to sign the document - which few want to do because they are then legally at risk if somewhere along the supply chain the company that bought pencils for them turned out not to know everything about who made them.


Rogerson, M., Crane, A., Soundararajan, V., Grosvold, J. and Cho, C.H. (2020), "Organisational responses to mandatory modern slavery disclosure legislation: a failure of experimentalist governance?", Accounting, Auditing & Accountability Journal, Vol. ahead-of-print No. ahead-of-print.

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