The Organizational Dynamics of Compliance with the UK Modern Slavery Act in the Food and Tobacco Sector

Abstract

Empirical studies indicate that business compliance with the UK Modern Slavery Act is disappointing, but they struggle to make sense of this phenomenon. This paper offers a novel framework to understand how business organizations construct the meaning of compliance with the UK Modern Slavery Act. Our analysis builds on the endogeneity of law theory developed by Edelman (2016). Empirically, our study is based on the analysis of the modern slavery statements of ten FTSE 100 companies in the food and tobacco sector, backed by interviews with business, civil society and public officers. We offer a dynamic model that draws attention to the role of compliance professionals in framing ambiguous rules and devising a variety of organizational responses to modern slavery law. Contrary to extant research that tends to praise organizations for going ‘beyond compliance’, our study underlines the risks of managerialization of modern slavery law, whereby merely symbolic structures come to be associated with legal compliance, even when they are ineffective at tackling modern slavery.