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Organisational responses to mandatory modern slavery disclosure legislation: a failure of experimentalist governance?

Michael Rogerson (School of Management, University of Bath, Bath, UK)
Andrew Crane (School of Management, University of Bath, Bath, UK)
Vivek Soundararajan (School of Management, University of Bath, Bath, UK)
Johanne Grosvold (School of Management, University of Bath, Bath, UK)
Charles H. Cho (Schulich School of Business, York University, Toronto, Canada)

Accounting, Auditing & Accountability Journal

ISSN: 0951-3574

Article publication date: 8 July 2020

Issue publication date: 20 October 2020




This paper investigates how organisations are responding to mandatory modern slavery disclosure legislation. Experimentalist governance suggests that organisations faced with disclosure requirements such as those contained in the UK Modern Slavery Act 2015 will compete with one another, and in doing so, improve compliance. The authors seek to understand whether this is the case.


This study is set in the UK public sector. The authors conduct interviews with over 25% of UK universities that are within the scope of the UK Modern Slavery Act 2015 and examine their reporting and disclosure under that legislation.


The authors find that, contrary to the logic of experimentalist governance, universities' disclosures as reflected in their modern slavery statements are persistently poor on detail, lack variation and have led to little meaningful action to tackle modern slavery. They show that this is due to a herding effect that results in universities responding as a sector rather than independently; a built-in incapacity to effectively manage supply chains; and insufficient attention to the issue at the board level. The authors also identity important boundary conditions of experimentalist governance.

Research limitations/implications

The generalisability of the authors’ findings is restricted to the public sector.

Practical implications

In contexts where disclosure under the UK Modern Slavery Act 2015 is not a core offering of the sector, and where competition is limited, there is little incentive to engage in a “race to the top” in terms of disclosure. As such, pro-forma compliance prevails and the effectiveness of disclosure as a tool to drive change in supply chains to safeguard workers is relatively ineffective. Instead, organisations must develop better knowledge of their supply chains and executives and a more critical eye for modern slavery to be combatted effectively. Accountants and their systems and skills can facilitate this development.


This is the first investigation of the organisational processes and activities which underpin disclosures related to modern slavery disclosure legislation. This paper contributes to the accounting and disclosure modern slavery literature by investigating public sector organisations' processes, activities and responses to mandatory reporting legislation on modern slavery.



This paper forms part of a special section Accounting for modern slavery, employees and work conditions in business, Guest edited by Katherine Christ, Roger Burritt and Stefan Schaltegger. Michael Rogerson gratefully acknowledges the funding contribution of the Economic and Social Research Council (UK), grant reference ES/P000630/1. Charles Cho acknowledges the financial support provided by the Erivan K. Haub Chair in Business and Sustainability at the Schulich School of Business.The authors would also like to thank the editors of this special issue, Dr. Katherine Christ, Professor Roger Burritt, and Dr Stefan Schaltegger, and the two anonymous reviewers, who encouraged significant improvement in the paper during the review process. We would also like to pay a tribute to the memory of Professor Rob Gray who recently passed away. Professor Gray is the pioneer of the Social and Environmental Accounting field from which this research emanates, and the founder of the Centre for Social and Environmental Accounting Research (CSEAR). We are forever indebted to him for paving the way, which has enabled us to conduct meaningful research in this area to make the world a better place


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. 33 No. 7, pp. 1505-1534.



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