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Modern slavery in supply chains: Modern

slavery in
insights through supply chains

strategic ambiguity
Joanne Meehan and Bruce D. Pinnington 77
Management School, University of Liverpool, Liverpool, UK
Received 18 May 2020
Revised 11 October 2020
Abstract 18 December 2020
Accepted 23 January 2021
Purpose – The purpose of this paper is to assess whether firms’ transparency in supply chain (TISC)
statements indicate that substantive action is being taken on modern slavery in UK government supply chains.
Design/methodology/approach – The authors analyse 66 of the UK government’s strategic suppliers’ TISC
statements and 20 key documents related to the policy intent of the UK Parliament, 2015 TISC requirements.
Qualitative document analysis identifies what suppliers say they are doing and what they are not saying to
provide novel insights into how firms employ ambiguity to avoid timely action on modern slavery in their
supply chains A set of propositions are developed.
Findings – The authors elaborate the concepts of time and change in socially sustainable supply chains and
illustrate how firms use ambiguity in TISC statements as a highly strategic form of action to defend the status
quo, reduce accountability and delay action for modern slavery within supply chains. The authors identify
three ambiguous techniques: defensive reassurance, transfer responsibility and scope reduction that deviate
from the policy intention of collaborative action.
Social implications – The results illustrates how ambiguity is preventing firms from taking collaborative
action to tackle modern slavery in their supply chains. The lack of action as a result of ambiguity protects firms,
rather than potential victims of modern slavery.
Originality/value – Prior research focuses on technical compliance rather than the content of firms’ TISC
statements. This qualitative study provides novel insights into the policy-resistant effects of ambiguity and
highlights the dynamic and instrumental role of modern slavery reporting. Theoretically, we identify
accountability as an essential concept to address the causes of modern slavery in supply chains and for
developing collaborative supply chain environments to tackle the issues.
Keywords Supply chains, Ambiguity, Modern slavery, Socially sustainable supply chains
Paper type Research paper

Introduction
Contemporary supply chains are emerging as a key area for urgent attention in modern
slavery research (LeBaron, 2013) because their complex networks can create risks that leave
workers vulnerable to exploitation (Martin-Ortega, 2017). Modern slavery is pervasive, and
while quantification remains problematic, the latest figures estimate 16 million people are in
forced labour exploitation in the private economy worldwide (Global Slavery Index, 2019).
Modern slavery covers a range of exploitative practices, including bonded labour, forced
labour and human trafficking. Procurement is commonly positioned in public policy as a
primary lever to eradicate modern slavery from corporate supply chains, yet there are limited
studies in the operations management (OM) and supply chain management (SCM) fields
(Benstead et al., 2018; Flynn and Walker, 2020; Gold et al., 2015).
Global supply chains are increasingly commonplace as a result of transboundary
production and the consumption of goods and services (Vaughn et al., 2019). Operational
practices to manage supply chain complexity, including outsourcing and subcontracting,
generate conditions that create and sustain modern slavery risks (Allain et al., 2013; LeBaron,
2013; LeBaron and R€ uhmkorf, 2017). The Global Slavery Index (2018) reports that the G20 International Journal of Operations
& Production Management
Vol. 41 No. 2, 2021
pp. 77-101
The authors thank Matt Mitchell, Anneke Schaefer, Nathan Davies, Oliver Kennedy, and Demitri © Emerald Publishing Limited
0144-3577
Kyriacou, for their research assistance. DOI 10.1108/IJOPM-05-2020-0292
IJOPM countries annually import US$354bn of “at-risk” products, and the lack of supply chain
41,2 transparency can unintentionally implicate businesses in these practices (Bales, 2012).
The scale of modern slavery, and the growing acceptance that businesses and
governments need to respond urgently, has led a number of countries to pass legislation
(Caruana et al., 2020). The UK Government’s Modern Slavery Act came into force in 2015. The
Act’s (Section 54) transparency in supply chains (TISC) provision places an annual public
reporting obligation on firms with a turnover of ≥£36m (UK Parliament, 2015). Supply chain
78 research has predominantly focused on TISC statements’ technical compliance rather than
their content (Flynn and Walker, 2020; LeBaron and R€ uhmkorf, 2017; Stevenson and Cole,
2018). The lack of research attention on what firms are reporting is particularly important for
modern slavery, as perhaps surprisingly, the focus for legal compliance is the TISC
statement’s publication, not the changes adopted or commitments to act. Therefore, a firm
can be technically compliant by reporting that they have taken no steps to tackle it. For firms
that are prepared to go beyond a null statement, a range of ambiguous responses are possible.
Ambiguity can give the illusion of action in lieu of real change across supply chains. This is
important as buyers use suppliers’ TISC statements in their sourcing and supplier evaluation
processes as the best available proxy for action.
Our research adopts strategic ambiguity as a theoretical lens to examine the extent to
which the UK Government’s own suppliers are taking responsibility for tackling modern
slavery in their supply chains. Four research questions frame the study. The first asks what
the supply chain objectives of the UK Government’s Section 54 TISC reporting requirements
are. This is an important question, as the extant research focuses on the publication not the
content of firms’ TISC statements. Tackling modern slavery in supply chains is a complex
undertaking. An understanding of the thematic principles underpinning the legal framework
is an important contribution to the field to assess the legislation’s alignment with socially
sustainable supply chain (SSSC) theory.
Second, we investigate how firms temporally situate action. Firms with a turnover of
≥£36m have statutory obligations to report annually on modern slavery, yet progress still
appears to be slow, which could be suggestive of a lack of urgent action. Our third research
question asks how supply chain perspectives are reported. As the TISC legislation only
covers large firms, tackling modern slavery is predicated on the diffusion of policy and
practice through supply chains. An understanding of how large firms take account of supply
chain responsibilities may provide insight into the legislation’s effectiveness. Finally, we
explore how firms employ ambiguity to avoid timely action on modern slavery in their supply
chains. Through this research question, we seek to contribute to the theoretical base by
revealing the mechanisms employed by firms in their modern slavery reporting, in response
to the need for urgent change to supply chain practice.
We analyse 66 of the UK Government’s own suppliers’ TISC statements and 20 key
documents related to the policy intent of the UK Parliament (2015) TISC requirements.
Qualitative document analysis is used to identify what firms say they are doing, and
through the theoretical lens of strategic ambiguity, we also reveal what they are not saying
to provide novel insights into how firms are responding to modern slavery legislation. Our
findings elaborate the concepts of time and change in SSSCs and reveal how ambiguity is
used in TISC statements as a highly strategic form of action to reduce firms’ accountability
and delay action for modern slavery within supply chains. We identify subtle techniques
of ambiguity, which highlight the dynamic and instrumental role of modern slavery
reporting, which has not been identified previously in the supply chain literature. We
contribute to the sustainability theory by identifying accountability as an essential
concept for generating action. We posit that SSSCs, and the legislative framework for
modern slavery, requires firms to take more systemic accountability for creating
conditions for labour exploitation and also to develop collaborative supply chain
environments to tackle the issues. Propositions are developed to inform the research Modern
agenda. slavery in
supply chains
Modern slavery legislation
Modern slavery lacks legal clarity (Gallagher, 2017), but broadly captures a range of
violations that exploit people for the purposes of work or services (Nolan and Bott, 2018). The
removal of peoples’ social and economic freedoms for financial gain can be in the form of 79
threats, potential or actual violence, coercion and deception (Bales, 2006). Legislation in the
UK, USA (California), France, Australia and Singapore, targets only large firms (≥£36m,
≥AUS/US$100m) and reporting is expected to trigger a “trickle-down” response through
these firms’ supply chains.
The UK’s Parliament (2015) requires commercial firms with a turnover of ≥£36m to
annually publish on their website’s homepage, a TISC statement that reports either the steps
taken to ensure slavery is not taking place in their operations and supply chains or to confirm
that no action has been taken (UK Government, 2017). A firms’ duty to publish a statement
can be legally enforced, but there are no binding standards for the content (LeBaron and
R€uhmkorf, 2019). The TISC requirements in relation to due diligence have been criticised for
being weak compared to other corporate disclosure and reporting legislation, e.g. the UK’s
Bribery Act (2010), the French Corporate Duty of Vigilance Law “devoir de vigilance” (2017)
and Section 1502 of the US Dodd Frank Act (2010) conflict minerals provision (c.f. LeBaron
and R€ uhmkorf, 2017, 2019).

Theoretical framework
Socially sustainable supply chains (SSSCs)
The importance of addressing corporate sustainability is growing in OM (Walker et al., 2014).
Modern slavery, along with other issues relating to health and safety, human rights and
community impact programmes, falls under the concept of SSSCs (Walker et al., 2014). A
firms’ attention to social issues is identified as a crucial part of a supply chain’s overall
sustainability performance (Kang et al., 2018) and an antecedent for both basic and advanced
sustainability practices (Croom et al., 2018). Yet, social sustainability remains under-
researched in comparison to environmental issues (Meehan and Bryde, 2015; Silvestre et al.,
2020a, b). Whilst SSSC has a potentially broad scope, there is a lack of research on socially
responsible sourcing (Zorzini et al., 2015), and even less on modern slavery in supply chains
specifically (Benstead et al., 2018).
Time and change are two inter-related concepts embedded in theories of sustainability,
with debates in the literature centred on the urgency of change and the extent of change
required. Time is important in sustainable supply chains (Roy et al., 2018), most notably in its
underpinning of the Brundtland Commission’s ubiquitous definition of sustainable
development that “seeks to meet the needs and aspirations of the present without
compromising the ability to meet those of the future” (WCED, 1987, p. 39). A firms’ long-term
orientation is identified as important for SSSC outcomes (Croom et al., 2018) and longevity
(Wu and Pagell, 2011), but balancing future needs and current pressures can create temporal
conflicts (Klassen and Hajmohammad, 2017). For example, sustainable supply chains develop
over time, signifying a slower pace of change (Klassen and Vereecke, 2012; Silvestre et al.,
2020a, b), whereas international modern slavery legislation creates an urgent imperative to
change current practices (Mende, 2019).
Sustainable supply chain research tends to focus on evolutionary change (Huq et al., 2016),
but some scholars identify the need for urgent fundamental change to business models and
practice (c.f. Hart and Milstein, 2003; Pagell and Shevchenko, 2014; Pagell and Wu, 2009;
Wolf, 2011). Similar calls are made to address modern slavery, as the problem is entrenched in
IJOPM wider social and economic systems of inequality (Crane, 2013). The exploration of
41,2 fundamental systemic change is beyond the scope of this paper, yet recognition of the
debates is still important to frame the scale and urgency of change needed to deliver SSSCs,
rather than providing a mere impression of change (New, 2015). Given the tensions between
pressures for urgent action versus evolutionary long-term change in SSSCs, how firms
temporally situate their TISC responses emerges as a critical question.
Modern slavery is claimed to be present in the supply chains of almost all industries (Walk
80 Free Foundation, 2016). To tackle this widespread prevalence, legislation uses transparency
as a catalyst for action, combined with trickle-down logics, where change in practice by larger
firms will diffuse over time throughout their supply chains. The efficacy of modern slavery
legislation that focuses on supply chain reporting to stimulate urgent transformative change
is questionable (Stevenson and Cole, 2018). Change can be hampered by difficulties in
adapting sustainability indicators to fragmented, multi-tier supply chain contexts (Gold et al.,
2015). Further, suppliers susceptible to sustainability-related risks can limit the diffusion of
change if they are dropped from a firm’s supply base rather than being developed (Connelly
et al., 2011), creating niche supply markets rather than mainstreaming population-wide
changes (Hajmohammad and Shevchenko, 2020). The active engagement of the supply chain
is positioned as an important lever for ensuring widespread change in SSSC, yet the extent to
which this is reflected in TISC statements is, as yet, unknown.
The wider sustainability research reveals stakeholders as an additional dynamic, as they
can create pressure that encourages firms to move towards sustainable supply chain practice
(Foerstl et al., 2010; Gualandris and Kalchschmidt, 2014; Hajmohammad and Shevchenko,
2020). Responding to stakeholder pressure can avoid reputational damage (Hofmann et al.,
2014; Roehrich et al., 2014). However, sustainability reporting may not correlate with firms’
actual commitment (Tate et al., 2010). Reputation management suggests that firms report only
positive attributes to stakeholders (Elsbach, 2003; Elsbach et al., 1998; Nath et al., 2020), yet
studies also show, perhaps counterintuitively, that firms can downplay their achievements
to protect their reputation (Kim and Lyon, 2015; Nunes et al., 2020; Testa et al., 2018),
particularly where the lack of supply chain transparency could obscure risks that lay firms
open to claims of corporate hypocrisy (Glover and Touboulic, 2020; Wagner et al., 2020).
International modern slavery legislation is built on the assumption of available data to
understand, and where necessary, change firms’ practices throughout the tiers of their supply
chains. However, transparency is not a proxy for embracing adoption of sustainable practice
(Haack et al., 2020). Further, if firms are refraining from reporting their prosocial actions or
certifications, then the diffusion of new practices is reduced (Carlos and Lewis, 2018).
Achieving supply chain transparency is operationally challenging, as firms outsource or
subcontract low-value or high-risk activities (Stringer and Michailova, 2018). Externalising
these activities separates firms from workers (Crane, 2013) and makes access to reliable
transparent data, beyond tier-one suppliers, difficult (Guth et al., 2014; New, 2015), even for
large firms (Barna, 2018). An emerging debate in the literature raises a more fundamental
question of the effectiveness of delegating authority for sustainability issues through the tiers
of globally dispersed complex supply chains (Grimm et al., 2018; Wilhelm et al., 2016).
Mandatory reporting under modern slavery legislation may increase the saliency of
reputation management for firms, particularly if firms have unknown risks in opaque areas
of their supply chains. How firms respond to this challenge is a key question that remains
unanswered in the literature.

Strategic ambiguity
The challenge of supply chain transparency brings the efficacy of modern slavery reporting
to the fore. Although some countries set legal requirements for large firms to report on
modern slavery, the use of ambiguous language may afford discretion over how rules and
policies are interpreted and applied (Kinderman, 2013). In other settings, the use of ambiguity Modern
in corporate documents creates room for multiple interpretations whereby different slavery in
audiences are able to apply different meanings to the same information (Davenport and
Leitch, 2005; Eisenberg et al., 1993). This can allow firms to control information or obscure
supply chains
their actions (Leitch and Davenport, 2003). A range of techniques are identified in corporate
reporting. Selective disclosure (Marquis et al., 2016) and strategic silence (Carlos and Lewis,
2018), both aim to limit access to information to manage reputational risks, whereas
obfuscation uses complex language to make it difficult for stakeholders to evaluate a firm’s 81
real performance (Fabrizio and Kim, 2019).
Ambiguity is a highly political and powerful resource (Jarzabkowski et al., 2010). For
firms, it serves four functions: it provides space for high-level goal agreement without
operational constraints, it allows for flexibility to shift and change meanings, it enables future
deniability of intent and it uses rhetorical control to preserve positions of power (Eisenberg,
1984). Ambiguity sits in contrast to notions of clear leadership (Ravishankar, 2013) and
precise language (Edenfield, 2018). The use of ambiguity increases the “play” within
organisational responses (Mahoney and Thelen, 2010). There are three dimensions: goal
ambiguity, authority ambiguity and means ambiguity (Cohen and March, 1986). Goal
ambiguity refers to the plurality of interests and interpretations presented to multiple
stakeholders. Authority ambiguity provides dispersed authority across organisational actors
to allow for partial solutions to various conflicting interests. Means ambiguity decouples the
relationship between goals, actions and performance to provide space and time for
interpretation in implementing solutions (Cohen and March, 1986).
The role of vague or ambiguous language in inter-organisational rivalry is a common
focus in prior studies (Guo et al., 2017; Rindova et al., 2004; Smith and Grimm, 1991), but little
is known on how it is used in a supply chain setting. The opportunity to explore ambiguity for
modern slavery in a supply chain context is of value, as it is more likely to be employed in
complex environments (Eisenberg, 1984), or when practices, operations, ideas and concepts,
span different cultural contexts (Meyer and H€ollerer, 2016). Despite the urgency to address
problematic supply chain practices, firms use symbolic measures that imply, rather than
confirm, social sustainability (Blome et al., 2017; Huq and Stevenson, 2020; Nath et al., 2020;
Villena and Dhanorkar, 2020). Similarly, firms use virtue signalling in modern slavery
statements, where broadly moral sentiments are employed to give a positive ethical
impression in lieu of genuine transparency (New, 2020). Given the emerging stream of
research on discretionary approaches in corporate documents that obscure or resist change,
studies of ambiguity in firms’ reporting may provide valuable contributions to the nascent
literature on modern slavery.

Method
This study analyses the TISC)statements of 66 of the UK Government’s tier-one suppliers,
published in line with the UK Parliament (2015). The research seeks to assess the extent to
which the UK Government’s own suppliers are taking responsibility for tackling modern
slavery in their supply chains in line with the government’s objectives. To answer our first
research question, we analyse the policy background to identify the intended supply chain
objectives for Section 54 TISC reporting, beyond the technical aspects of compliance (e.g. we
look how the government hoped the TISC statements would contribute to tackling modern
slavery, rather than where/how information is to be reported).
Strategic ambiguity was identified during the selective coding phase in our qualitative
examination of government suppliers’ TISC statements. Through this theoretical lens, we
address our second and third research questions by examining the inferences made on how
firms are embracing the challenge of modern slavery with respect to urgency of action and the
supply chain perspective. Ambiguity themes are investigated iteratively against concepts in
IJOPM the literature, and against the legislative context of TISC, to provide insights into our final
41,2 research question that explores how firms avoid timely action on modern slavery in their
supply chains.

Empirical context
The UK Government has a dual role in the modern slavery agenda; it creates and enforces
82 legislation and is a powerful player in demonstrating best practice in its supply chains. Public
procurement has significant economic power to achieve social sustainability across supply
chains that encompass both public and private organisations (Amann et al., 2014). In the UK,
the Crown Commercial Service (CCS) is responsible for managing the annual procurement of
£12bn common goods and services for the UK’s central government and over 17,000
organisations in the wider public sector (UK Government, 2021). This study provides insight
into whether CCS’s suppliers’ TISC statements suggest that policy objectives to tackle
modern slavery are being achieved in the government’s own supply chains, or if they are able
to avoid urgent change through the use of ambiguity. The empirical focus for this research is
CCS’s framework suppliers with a turnover of ≥£36m, with the highest value and/or in
categories of spend where risks of modern slavery were deemed high. CCS identified 80 of
their suppliers that met these criteria.

Data collection
Two datasets were drawn from publicly available documents. The use of secondary data
analysis is common in research of modern slavery (Flynn and Walker, 2020; LeBaron and
R€uhmkorf, 2017; Stevenson and Cole, 2018), sustainability (Jose and Lee, 2007; Silvestre et al.,
2020a, b; Tate et al., 2010) and of ambiguity (Meyer and H€ollerer, 2016). Secondary data are
appropriate for modern slavery research because of the difficulties in obtaining reliable
primary data in cases of potentially illegal activities (Stevenson and Cole, 2018). Document
analysis data are derived from any form of words, including published statements, reports or
transcribed debates, which are free from a researcher’s intervention (Bowen, 2009). As a
qualitative approach, document analysis is concerned with eliciting meaning and
understanding from the data, rather than more quantitative frequency counts of terms
(Corbin and Strauss, 2008). Interpretative approaches are common in document analysis
(Scott, 1990), as it is recognised that published documents serve particular purposes for firms,
so there is a necessity for a more critical reading than might be obtained from quantitative
approaches (Atkinson and Coffey, 2004).
The first dataset was used to examine CCS’s suppliers’ responses to the TISC
requirements in the UK’s Modern Slavery Act. CCS identified 80 of their framework
suppliers with a turnover of ≥£36m. The suppliers were from high-value frameworks and/or
categories of spend where risks of modern slavery were considered high. Data consist of 66
modern slavery statements downloaded from corporate websites from the sample of 80
suppliers. The remaining 14 suppliers were either yet to publish a statement or had such an
insubstantial return that it would not contribute productively to the research. The 66 TISC
statements ranged from 1 to 11 pages, with an average of four pages. The statements resulted
in a dataset of 248 pages (87,736 words). Table 1 provides a summative profile of the final
sample of firms.
The second dataset was used to identify the legislative policy intentions and framing of
the UK’s TISC requirements in relation to supply chain practice. The dataset consisted of all
the key documents generated by parliamentary and legislative bodies relating to the passing,
implementation and official reviews of the UK Parliament (2015). A total of 20 documents
dated between 2014 and 2019 were retrieved: three full transcripts of the parliamentary
debates from the official Hansard records of the House of Commons and House of Lords that
Industry (count) Average annual profit Average annual turnover
Modern
slavery in
Automotive (12) £132,657,083 £6,375,851,750 supply chains
Communications (5) £8,257,503 £4,762,757,297
Construction (2) £17,223,225 £684,073,641
Consultancy (8) £293,922,625 £1,748,537,625
Customer service (1)
£3,661,000 £99,228,000
Defence (1) £1,605,000,000 £18,407,000,000 83
Engineering (1) £196,500,000 £4,474,800,000
Financial (3) £1,934,092,333 £12,970,735,333
IT (16) £41,755,424 £2,554,985,543
Legal (1) £110,600,000 £422,600,000
Oil, gas and coal (1) £7,802,000,000 £252,095,900,000
Recruitment (7) 16,922,695 £325,629,314
Telecommunications (3) £1,114,012,667 £17,410,873,000
Travel (3) £59,600,000 £976,350,000 Table 1.
Utilities (2) £505,000,000 £18,718,500,000 Firms’ industry and
Total average £392,942,781 £ 8,928,929,096 financial profile

documented the passing of the UK Parliament (2015) through both houses of parliament; all
five published UK Government’s policy statements and official TISC guidance documents; all
five independent commissioned policy reviews; all three official government reviews; two
ministerial press statements; and the transcript of a speech by the Prime Minister (Theresa
May) to the International Labour Organisation. The documents resulted in a dataset of 625
pages (210,803 words) and 8.25 h of parliamentary debates (transcribed as a further 146 pages
– 73,429 words).

Data analysis
TISC statements were analysed qualitatively using the Nvivo12 software package through
inductive coding processes to establish themes (Strauss and Corbin, 1998). Line-by-line open
coding was used to identify concepts and actions. Codes were generated “in-vivo” (from the
data) in line with inductive coding principles. Related codes were then grouped into categories
at the axial coding stage and organised hierarchically. Progressively, more abstract core
categories were created through which the themes identified could best be explained (Strauss
and Corbin, 1998). As the properties and dimensions of the core categories were explored,
those with the greatest explanatory relevance were further refined and iteratively compared
across examples (Bowen, 2009). The iterative re-reading of the data identified that firms’
reported actions commonly lacked detail or evidence. The coding process identified the
“unspoken voice”, “implied exceptions” and “ambiguous actions” that sensitised researchers
to what was not being said, or what was potentially missing in the reports. These absences
were then explicitly identified through what we have termed “antithetical inferencing”.
Where, for instance, a company states that it works with its biggest suppliers on modern
slavery, we noted the inference that its other smaller suppliers remained uninvolved. A
sample of examples is found in Table 2. This technique is common in interpretative document
analysis to enable equal examination of what is, and is not, said (Jarzabkowski et al., 2010;
Rouleau, 2005; Scott, 1990).
The ability to resist change through ambiguous language emerged as a conceptual theme
from the statements, prompting a return to the literature base on strategic ambiguity. Three
dimensions of ambiguity (goals, authority, means) (Cohen and March, 1986) were adopted to
iteratively explore the data through this sensitising concept (Charmaz, 2014). Through this
detailed process, each code that related to any inclusive action, or contained any form of
IJOPM Example statement quote [company] Antithetical inference
41,2
We have. . .written to our top 50 suppliers and asked them . . . The potentially large number of excluded
[Banner Group] suppliers have not been engaged
. . .where appropriate, we carry out due diligence on prospective A potentially large number of suppliers will
suppliers [Brook Street] be excluded from due diligence
We apply a consistent screening process to all suppliers based . . . but not elsewhere including UK?
84 in Asia [Berensden]
GM periodically conducts supplier compliance surveys to Checks potentially are not being made
confirm compliance [GM] between periodic checks
We assess our suppliers’ compliance. . .via our supplier pre- Compliance may not be being checked
qualification questionnaire [PA] during contract management
We expect each entity in the supply chain to, at least, adopt We manage at tier-1 and “expect” the
Table 2. “one-up” due diligence on the next link in the chain [Fleetcor] supply chain to manage itself
Examples of No concern. . .reported through our Whistleblowing system or Absence may indicate poor reporting and
antithetical inferences raised through audits in 2016 [Berensden] auditing processes

boundary on actors, process, scale or geography, was further examined through the lens of
ambiguity. Statements for instance that used terms such as “focused on” were examined
further to reveal which actors or actions were excluded as a consequence on the boundaries
imposed.
At the selective coding stage, we developed explanations for what the core themes meant,
so we not only investigated themes iteratively against concepts in the literature, but also
against the legal context in which they were being developed. The evaluation of context when
developing explanations is an important step in inductive analysis (Clarke, 2005; Strauss and
Corbin, 1998). The dataset of policy documents was, therefore, analysed to identify the
government’s primary intentions for the TISC legislation and to connect ambiguous wording
with potential consequences. Thematic analysis was undertaken to identify the government’s
aims for the TISC reporting. The policy-related data were reviewed against the core concepts
as part of the selective coding process, to help to elaborate the core concepts’ properties and
dimensions and to develop an explanation of how they related to each other (Strauss and
Corbin, 1998). This analysis situates ambiguity techniques in the context of the government’s
policy intent to make sense of its bounding effects. Through this extended analysis, core
categories were rationalised to three, with the additional qualifiers in parentheses: (transfer)
responsibility, (defensive) reassurance and (scope) reduction (Table 3), as discussed in the
findings and analysis section.
Fit and relevance are assessed (Glaser and Strauss, 2017) by conducting a qualitative
rating of the TISC statements’ use of ambiguity, set against the two dimensions that emerge
from the policy analysis (discussed in the results section). Four quadrants are created
(Figure 1), and the scoring criteria against a five-point scale (
2 to þ2) were defined for both
axes, see Table A1, reflecting the use of ambiguity and the policy aims. The 66 modern
slavery statements were re-analysed and scored with the final combinations mapped against
the quadrants. Two people individually coded and mapped the statements against the
scoring criteria (Wesley, 2014). Although many statements used more than one of the three
ambiguity techniques identified, each statement was allocated a score that corresponded
most closely to one of the quadrants. Only one quadrant, collaborative action, aligns with
policy intention of change and a broadened supply chain accountability. Inter-rater reliability
was tested by a Mann–Whitney U test (at p < 0.05). The results indicated the scores were not
significantly different for either dimension: U 5 399, p 5 0.56, r 5 0.06; U 5 405, p 5 0.57,
r 5 0.06. A set of propositions are developed in the discussion section from the resulting
insights.
Core category/sub-
Modern
categories Example open codes Example statement quote [company] slavery in
supply chains
1. Reduction of scope Different routes through which organisations seek to reduce the extent of their modern
slavery supply chain management commitments
Reduction: task Supplier assessment Stone employs a formal supplier approval process . . . as far
scope Practical limitations as is practical [Stone]
Reduction: org scope Constrained to Dedicated training is completed at appropriate levels in the 85
appropriate levels procurement and supply chain teams [Berendson]
Limiting supplier GM requires its direct first tier suppliers [GM]
numbers
Practical limitations It is not practical . . . to have a direct relationship with all
links in the supply chain [Fleetcor]
Reduction: spend Limiting suppliers by Suppliers who . . .(1) operated in a Higher Risk industry
thresholds spend (2) were paid over £100,000 per annum . . . [Deloitte]
Limiting supplier
numbers
. . .review covered over 3,900 supplier records with . . .
minimum spend threshold of £10,000 . . . [Barclays]
written to our top 50 suppliers . . . [Banner Group]
Reduction: Scope geographic Within our UK supply chain . . . [Brook Street]
geographic High-risk countries We apply a consistent screening process to all suppliers
based in Asia [Berensden]
Reduction: by risk Limiting suppliers by Due to our large number of suppliers, we take a risk-based
assessment risk approach . . . [Impellum]
Risk-based approach We take a risk-based approach to addressing concerns that
may arise from our supply chain. [Brook Street]

Extent to which responsibility for managing modern slavery in supply chains is

2. Responsibility assumed by the organisation (positive) or devolved to suppliers (negative)

Responsibility: Adhering to values/ “. . . and we expect all our suppliers to adopt adequate
expectations ethics ethics and values” [Comparex]
Supplier expectations
Suppliers must “Potential suppliers must demonstrate their capability to
demonstrate capabilities meet our contractual requirements.” [Babcock]
Supplier expectations “We expect all suppliers to operate in accordance with
our . . . Policy” [Brook Street]
Responsibility: Delegating responsibility We expect each entity in the supply chain to, at least,
delegating adopt “one-up” due diligence on the next link [Fleetcor]
Contracts with suppliers We’ve introduced a legally-binding clause in our
Delegating responsibility strategic supplier contracts [PWC]
Contracts with suppliers . . . we now place obligations on relevant suppliers
Delegating responsibility [Toyota]

Mechanisms through which organisations seek to establish trust and reassure

3. Reassurance stakeholders without supporting evidence

Reassurance: Reassurance low risk “. . .does not occur in our business operations or within our
nothing found Reassuring supply chain” [Herbert Smith]
Reporting no concerns No concerns relating to modern slavery were reported . . .
or raised through audits [Berensden]
We do not use forced labour in any form [JLR] Table 3.
Coding table for TISC
(continued ) statement analyses
IJOPM Mechanisms through which organisations seek to establish trust and reassure
41,2 3. Reassurance stakeholders without supporting evidence

Reassurance: by Industry collaboration deeply involved . . . through organizations such as

association Automotive Industry Action Group (“AIAG”) [GM]
Commitment to external . . . fully committed to . . . the “Reform Programme” being
initiatives developed by Electronics Watch [Stone]
86 UN Global Compact . . . member of the United Nations Global Compact [PA]
Reassurance: via Awards and . . . recognised as one of the World’s Most Ethical
awards commendations Companies . . . by the Ethisphere Institute [CapGemini]
. . . recognised seven times by the Ethisphere Institute
Table 3. [Ricoh]

Figure 1.
Ambiguity use in TISC
responses

Findings and analysis

Three core categories related to the use of ambiguity in TISC statements are identified:
responsibility, reassurance and reduction. The coding table is summarised in Table 3.

Policy intent for tackling modern slavery through transparency in supply chain
The documents and parliamentary debates related to the passing and implementation of
TISC legislation and guidance are unambiguous in their aim: to tackle modern slavery, firms
should work collaboratively across their supply chains to drive changes in practice. TISC
reporting is positioned as supporting this aim through increasing supply chain transparency
to enable a level playing field for competing firms that act responsibly (Field et al., 2019). Two
clear dominant policy intentions of TISC are stated – a change in business practice and
accountability that encompasses firms’ supply chains.
The first policy intention is that firms should change their processes and practices to
address modern slavery to ensure it is regarded as seriously as other regulatory and
governance obligations. Yet, unlike other obligations, e.g. the UK Bribery Act 2011 (Section 7),
the TISC regulation does not include binding standards, in particular for due diligence
reporting and liabilities. Thus, tackling modern slavery in supply chains relies on the
collective action and determination across firms and their supply chains, to generate change
in practice.
 The theme of embracing change is inferred in all the government documents to stress that Modern
TISC is not solely about technical compliance. Indicative examples include debate in the slavery in
House of Commons, where members of parliament expressed that it is “. . .really important
that their [firms] response is about not just rhetoric, but action” (Williamson, 2014,
supply chains
Col.445WH), and similarly in the House of Lords, Baroness Kennedy of Cradley remarked that
the supply chain clause must “act as a catalyst for change” (2014, Col.252). In the
Government’s 2018 review on modern slavery, the then Home Secretary, the Rt Hon Sajid
Javid reported the importance of “driving industry action” and recognised the need for “a 87
step-change in businesses’ efforts to end slavery in their supply chains” (UK Government,
2018, p. 3). The Rt Hon Theresa May, as the UK’s Prime Minister in 2019, further stressed the
necessity for firms to match “. . ..words with action” (2019), in a speech to the International
Labour Organisation. Although the need for change is emphasised in parliamentary debates
and reports, it is positioned generically, rather than focused on specific procurement practice
and contracting liabilities, despite the overt supply chain context of the regulation.
The second policy intention is that firms should consider their supply chains not only their
own operations. Early debates on the Modern Slavery Bill in the House of Commons saw
members of parliament urging firms “. . .to take a stand on the world stage. . .[and]. . .go far
beyond what regulations deliver” (Lavery, 2014, Col.441WH). The inclusion of the supply
chain is explicit in the title of the requirements for TISC statements – transparency in supply
chains – and the published guidance states that “no single business can do this alone”, but
that each business should “lead and drive the measures required to address this problem”
throughout their supply chain operations (UK Government, 2017). In 2018, the governments
in the UK, Canada and New Zealand, released a set of principles under the UN’s General
Assembly that sought to use international legislation to specifically promote government
supply chains as a source of best practice for collaborative action between public and private
sector firms (UK Government, Government of Canada, & New Zealand Government, 2018).
Tackling modern slavery in collaboration with suppliers was deemed to be facilitated
through supply chain transparency (Sancroft-Tussell, 2018).

Policy-divergent transparency in supply chain responses

Figure 1 illustrates ambiguity techniques used in government suppliers’ TISC statements,
mapped against the two primary legislative goals. The top right quadrant, labelled
collaborative action, is in line with government’s aims to deliver changes to practice that
encompass a firm and its supply chains. The other three quadrants demonstrate the use of the
ambiguity techniques (transfer responsibility, defensive reassurance, scope reduction) that
suggest the government’s policy ambitions are not being met. The mean score for change to
supply chain practice is
0.65, and for broadening accountability, it is
1.06, indicating that
on both measures, insufficient progress is being made towards embracing UK Government’s
modern slavery policy aims.

Quadrant 1: transfer responsibility

Firms that transfer responsibility are changing some of their supply chain practices, e.g.
increasing reporting, but are shifting the responsibility for tackling modern slavery to their
suppliers. Firms use goal ambiguity to indicate to different audiences, including customers
and government, that they embrace corporate responsibility, whilst the inference here is that
firms are handing-off responsibilities for modern slavery detection, reporting and
remediation, to other members in their supply chains. Whilst it is reasonable that firms
also require suppliers to actively manage modern slavery in their operations, a firm cannot
simply pass that responsibility to its supplier, if it is to truly be accountable.
The language used to describe suppliers’ obligations is imperative rather than
collaborative using words, including “expect”, “mandates” and “must”. The wording
IJOPM provides indications that for most firms, action on modern slavery is being taken at arms-
41,2 length through contracts with tier-1 suppliers, rather than through collaboration and
transparent management of supply chains. Interestingly, the responsibilities passed to
suppliers use strong imperative language and sit in contrast to the actions that firms report
that they themselves are taking, which are frequently aspirational and vague, e.g. “strive”,
“encourages” and “efforts”. There is a near absence of statements reporting that issues are
being managed collaboratively through the supply chain, or that suppliers have agreed, or
88 have even been party to the decision-making. Responsibility is also limited by use of the terms
“supplier” and “employee”, without specific definitions, creating ambiguous risks for contract
workers who may not be directly covered by corporate codes of practice.

Quadrant 2: defensive reassurance

The most common response (67%) fell within the defensive reassurance quadrant. Responses
here use palliating statements that convey an impression of best practice rather than
providing evidence or action specifically related to modern slavery. Defensive reassurance
deflects attention away from action by signalling allied areas of broader corporate
responsibility. Authority ambiguity is used to provide partial solutions through reassurance
by association to ethical action groups, e.g. “PA is a member of the United Nations Global
Compact”, or with awards, “Ricoh has been recognised seven times by the Ethisphere
Institute”. Signalling by association presents a reassuring image of a “successful” business
model, yet none of the statements asks more fundamental questions of whether their business
model or sourcing practices contribute to risks of modern slavery in the supply chain.
Defensive reassurance was also observed through negative assertion where it is stated
that modern slavery “does not occur in our business operations” [Herbert-Smith]. Our
antithetical approach leads us to question whether statements reporting that there was
“nothing found” reflect poor detection practices rather than effective SCM. The
underpinning, but unspoken message of defensive reassurance, is that practices, including
those of consumers, do not need to change. Inaction can maintain inequities and risks within
the system. The lack of voice by workers in exploitative conditions through the supply chain
enables this message to go largely unchallenged.
Quadrant 3: scope reduction
Scope reduction was identified as the dominant approach by 11% of firms, although many
more exhibited some use of scope reduction in their statements. Means ambiguity decouples
goals and actions, and whilst some firms are committing to broadening their own
accountability for modern slavery, there is lack of clarity on timescales, e.g. stating change is
“developing”, or actions taken “periodically”. Scope reducing techniques include narrowing
the task; limiting the range of internal staff involved; and the use of thresholds, risk
assessments and geographic boundaries to reduce the number of suppliers that are assessed.
Firms use highly subjective terms such as “. . .as far as is practical” to reduce the scale of their
supplier approval and due diligence processes. Others limit the number of suppliers that are
required to provide information, based on spend, either in absolute terms (e.g. over a given
monetary value), or through targeting “top” suppliers. Although criteria are rarely stated for
which suppliers are considered “top”, this is likely to be based, at least in part, on high-spend
profiles, rather than necessarily where modern slavery is likely to occur within their supply
chains. As a result, firms can be looking in the wrong places for modern slavery, so while they
may be taking action, it might not result in any impactful change.

Quadrant 4: collaborative action

Collaborative action represents firms that are embracing the need to change practices and are
broadening attention across the supply chain to address issues of modern slavery. The UK
Government’s policy ambition for tackling modern slavery in supply chains sits firmly in this Modern
quadrant. In contrast to the other three quadrants, and owing to the alignment to policy slavery in
intent, ambiguity is either not present or is minimal. The need for change is acknowledged, as
is the importance of working collaboratively with suppliers through the chain. This quadrant
supply chains
represented the lowest number of cases, at only 5%.
The use of ambiguity techniques by sector is illustrated in Table 4. The small sample sizes
by industry limit the ability to generalise, but it is noteworthy that defensive reassurance,
arguably the most resistant use of ambiguity, is prominent in information technology (IT), 89
automotive and recruitment where the risks of modern slavery are considered high.

Discussion
The research sought to assess the extent to which the UK Government’s own suppliers are
taking responsibility for tackling modern slavery in their supply chains. We adopt ambiguity
as a theoretical lens to provide insight on how urgent change within supply chains is avoided.
Three quadrants in our model identify techniques used in firms’ TISC statements that deviate
from the government’s intention of the TISC provision, which is represented by the fourth
quadrant, collaborative action. We explain how firms are reducing the boundaries of their
legal responsibility through the lens of strategic ambiguity (Cohen and March, 1986). Firms
use ambiguity as a strategic resource (Jarzabkowski et al., 2010) by employing three
techniques of defensive reassurance, transfer of responsibility and scope reduction. These
techniques convey an impression of best practice, unilaterally push accountability to
suppliers and reduce the scope of a firm’s attention, all of which restrict the legislative reach
of the UK’s Modern Slavery Act.
The transfer of responsibility and scope reduction techniques only provide partial
alignment to legislative aims. Ambiguity is employed to present a message that measures are
in place to tackle modern slavery whilst simultaneously limiting action and slowing the pace
of change in practice. It is important to state that the TISC guidance does not allow firms to set
arbitrary boundaries for addressing modern slavery. However, the statutory focus on
publishing statements, rather than their content or practice, generates space for firms to
transfer and limit their responsibility and their use of ambiguity affords discretion in the
interpretation of policies (Kinderman, 2013).

Defensive Transfer Scope Collaborative

Sector reassurance responsibility reduction action

Automotive 8 3 1 0
Communications 4 1 0 0
Construction 1 0 1 0
Consultancy 4 2 1 1
Consumer services 0 0 1 0
Defence 0 0 0 1
Engineering 1 0 0 0
Financial 2 1 0 0
IT 15 0 1 0
Legal 0 0 0 1
Oil, gas and coal 0 0 0 1
Recruitment 6 1 0 0
Telecommunications 1 2 0 0 Table 4.
Travel 2 1 0 0 Ambiguity techniques
Utilities 0 0 2 0 by industry
IJOPM The ability of firms to transfer responsibility or reduce the scope of attention adds support to
41,2 the criticisms that the TISC legislation is weak (LeBaron and R€ uhmkorf, 2017), and our
results extend this view by providing insight into how firms exploit the lack of binding
standards. The policy documents and parliamentary debates highlight the reliance on firms’
engagement across their supply chains to generate change. It is interesting that while firms
report peer-to-peer collaboration through industry associations, there is a lack of similar
attention to collaborative action within supply chains, and instead, the impression is of arms-
90 length supplier relationships. TISC statements use coercive language to mandate that
suppliers take responsibility for modern slavery, running contrary to the SSCM literature
that points to inefficiencies of delegating authority for sustainability issues (Grimm et al.,
2018; Wilhelm et al., 2016). Although our findings preclude data on motive, an ambiguity lens
highlights reputational management as a potential reason for transferring responsibility.
Transferring responsibility to suppliers creates ambiguity, which provides protection for
the firm, not only from reputational risk (Carlos and Lewis, 2018; Marquis et al., 2016), or
from the spatial separation of firms from workers (Crane and LeBaron, 2017), but also we
argue, legally and temporally. The arms-length framing of relationships can reinforce the
perception that suppliers are independent contractors, thus protecting reputations against
potential future claims of corporate hypocrisy (Glover and Touboulic, 2020; Wagner et al.,
2020), should modern slavery be found in their supply chains. Transferring responsibility
does not use ambiguity to confuse through obfuscation or complex language, as seen in prior
studies (e.g. Fabrizio and Kim, 2019), but serves to cloud the edges of a firm’s own
responsibility.
Although many statements contained elements of delegation to suppliers, the firms that
predominantly used this technique were from industries with high levels of third-party
service operations (e.g. consultancy, communications, finance, recruitment, travel) or with
global supply chains (e.g. automotive and telecoms). In both situations, the risk of modern
slavery, and the associated responsibility for it, is framed as externally located within supply
chains. This externalisation may be indicative of a limited perspective on the risks of modern
slavery, or of opaque supply chains where risks are as yet unknown. The suggestion is that
protection of the firm’s own reputation is prioritised over accepting full accountability for
tackling modern slavery that may reveal, and require firms to accept, additional risks. Thus,
we propose:
P1. Firms that prioritise their reputation will transfer responsibility for modern slavery
to their suppliers.
Scope reduction through spend filtering implicitly frames a comprehensive approach to
managing modern slavery across supply chains as implausible, unreasonable or too costly.
Scope reduction may appear pragmatic from a resource perspective, yet as detailed in
Table 1, the average annual profit for the sample of government suppliers was £393m, with
an average annual turnover of £8bn, suggesting a lack of will, priority, or complexity, rather
than a lack of resource. There is no specific provision for scope reduction in the legal
requirements for TISC reporting, which covers firms and “. . .any of its supply chains”.
Further, arguments of impracticality are inconsistent with other corporate legislation, e.g. the
EU’s General Data Protection Regulations (GDPR), where reductive techniques are not legally
permissible.
Scope reduction is largely arbitrary in relation to risk with firms’ attention focused on
high-spend, tier-one suppliers, which are not necessarily where modern slavery risks are
situated in extended global supply chains. Restricting the scope can exclude smaller
suppliers, low-paid labour contracts, suppliers at tier two and beyond and indirect products
and services. Although risk assessments are used to identify high-risk categories or
geographic regions, scope reduction still focuses on what firms buy, and from whom, which
can obscure or sidestep questions of how firms buy. Thus, a firm’s own practices that erode Modern
margins and intensify pressure on production and delivery times through the supply chain slavery in
are less likely to be systemically considered or challenged. Our results provided no examples
of firms reporting that they evaluate the extended impacts of their own competitive business-
supply chains
level strategies, sourcing criteria or outsourcing and subcontracting practices, despite the last
two being identified as high-risk practices for modern slavery (Allain et al., 2013; LeBaron,
2013; LeBaron and R€ uhmkorf, 2017).
While our analysis of published TISC statements may not reflect the full extent of firms’ 91
modern slavery efforts in practice, scope reduction techniques give an impression of action
whilst simultaneously implying a limited risk of modern slavery. This can prevent firms from
acknowledging their role in creating conditions for modern slavery or uncovering unknown
modern slavery risks in supply chains that are not being prioritised. From this position,
existing business models are maintained and reproduced, and the call for sustainable supply
chains to embrace fundamental change (Hart and Milstein, 2003; New, 2015; Pagell and
Shevchenko, 2014; Pagell and Wu, 2009; Wolf, 2011) is unlikely to be addressed. Our second
research proposition is:
P2. Reductive approaches to modern slavery will reduce the attention a firm gives to
evaluating the impacts of its own commercial practices.
Mandatory legal requirements for large firms to report on modern slavery remove some of the
voluntary reporting decisions related to reputation management seen in the wider
sustainability literature (Glover and Touboulic, 2020; Kim and Lyon, 2015; Nath et al.,
2020; Nunes et al., 2020; Tate et al., 2010; Testa et al., 2018; Wagner et al., 2020), but our results
show that there is still significant room for temporal interpretation through strategic
ambiguity. Goal ambiguity enables different messages to be interpreted by different
audiences, providing space, at least in the short term, for resolution of these competing
demands.
From a theoretical perspective, the employment of ambiguity in TISC statements runs
counter to the urgent attention demanded by SSCM (New, 2015; Roy et al., 2018). The temporal
challenge of tackling modern slavery goes beyond the need for a long-term orientation
identified in the social sustainability debates (Croom et al., 2018; Klassen and Hajmohammad,
2017; Roy et al., 2018; Wu and Pagell, 2011). Ambiguous timeframes for action can position
modern slavery as a strategic future consideration, not as an urgent priority requiring action,
revealing a temporal tension in the SSCM concept. It has been argued that legislation creates
an urgent imperative for action (Mende, 2019). However, our results show that legislation may
create the imperative for reporting, but ambiguity is a mechanism that enables action to be
postponed, critically while still being legally compliant. The annualised reporting regime may
not attune buyers sufficiently to notice changes in practice. Thus, we propose:
P3. Firms using high levels of goal ambiguity will postpone urgent action on modern
slavery.
Defensive reassurance is arguably the most change-resistant technique evidenced within the
TISC statements, therefore running contrary to SSCM (Huq et al., 2016), and to a core intention
of the modern slavery legislation. The identification of defensive reassurance techniques
adds further support to the use of symbolic measures that imply, rather than confirm, SSCM
(Blome et al., 2017; Huq and Stevenson, 2020; Nath et al., 2020; Villena and Dhanorkar, 2020).
The implication here is that for many firms, the case for addressing modern slavery resides
not in the benefits of aligning with the legislative intent to actively tackle it in their supply
chains, but in the benefits accrued through pushing out the timeframe for action or
maintaining the status quo. The status quo is achieved through defensive reassurance by
implying to consumers and other stakeholders that modern slavery does not, or could not,
IJOPM exist in a firms’ supply chains, therefore reassuring them that they do not need to change their
41,2 consumption or buying behaviours. Customers and firms can seek comfort in the ambiguity,
yet resisting urgent attention is likely to contribute to maintaining conditions for modern
slavery risk that can further embed social inequities and exploitative labour conditions into
supply chains (Crane, 2013).
If defensive reassurance is merely an impression management technique and firms are not
“walking the talk”, it can normalise existing practice as being acceptable or sufficient.
92 Ambiguity presents conflicting interpretations (Feldman, 1991) to protect from public scrutiny
(Cappellaro et al., 2020). Our results show that the protected space for the status quo created by
ambiguity in TISC statements can convince decision makers and stakeholders that there are no
risks, and legitimise a lack of action. Thus, the likelihood they will actively look for modern
slavery in their supply chains is reduced, and they may disregard future claims to the contrary.
The hidden and complex nature of modern slavery can create further barriers for suppliers,
stakeholders and crucially victims from speaking up for fear of not being believed, even if
supporting processes (whistleblowing hotlines, etc.) are in place. We propose:
P4. High levels of defensive reassurance in modern slavery reporting creates barriers for
change in supply chain practice.
Modern slavery legislation is predicated on the assumption that transparency will lead to
changes in practice, and change will trickle down through supply chains. However, TISC
statements suggest that only the responsibility, not action, is passing through the supply
chain, supported by the one-way flow of information. Transparency is a key tenet in the
modern slavery legislation. As well as the difficulties of gaining real transparency of modern
slavery within supply chains (Barna, 2018; Guth et al., 2014; New, 2015; Stringer and
Michailova, 2018), it is not a proxy for embracing adoption of socially sustainable practice
(Haack et al., 2020). Arguably, the duty to report “. . .steps the organisation has taken” (UK
Government, 2015), as opposed to steps the organisation, has taken with supply chain
members and stakeholders, bounds a firm’s attention on its processes and risks rather than
opportunities for collaborative action to challenge the causes of modern slavery and to
generate change. Non-collaborative approaches run the risk of non-compliant suppliers being
dropped (Connelly et al., 2011), reducing the diffusion of new practices (Carlos and Lewis,
2018) and creating niche supply markets rather than mainstreaming population-wide
changes (Hajmohammad and Shevchenko, 2020).
The TISC provision requires action taken by firms “. . .to ensure that slavery and human
trafficking is not taking place” (UK Government, 2015), a requirement that belies the
complexity and hidden nature of the problem. The unspoken question here is what if it is
taking place? In reality, it may be difficult to eradicate and transparency does not necessarily
equate to being able to act. From a reporting perspective, questions emerge on whether firms
openly report modern slavery if identified, or if they use ambiguity to selectively disclose
information. Beyond questions of transparency, the defensive techniques evidenced in the
TISC statements suggest that firms, even if reporting transparently, would distance
themselves from cases rather than work collaboratively with their supply chains. Thus, our
final proposition is:
P5. Firms that engage in active collaboration within their supply chains are better
positioned to learn, adapt and tackle modern slavery than firms relying solely on
arms-length transparency.

Conclusions
Our results contribute to the nascent study of modern slavery in supply chains through an
explanatory model (Figure 1) that identifies four responses in firms’ TISC reporting: transfer
of responsibility, defensive reassurance, scope reduction and collaborative action. The first Modern
three responses use ambiguity to restrict action on modern slavery with only the latter, slavery in
collaborative action, being in line with government’s policy intentions. The analysis builds on
prior studies that assess compliance to modern slavery legislation (Flynn and Walker, 2020;
supply chains
LeBaron and R€ uhmkorf, 2017; Stevenson and Cole, 2018), by identifying not only what
suppliers say they are doing, but also what they are not saying, to provide novel insights into
the policy-resistant effects of ambiguity. We reveal how ambiguity is used to defend and
legitimise the status quo and to reduce the boundaries of a firm’s attention and responsibility. 93
The results speak to the emerging critical turn in the literature that challenges our fields’
insufficient scepticism of firms’ espoused policies (New, 2015), and the dominant empiricist
approach that requires firms to change before we report on it (Pagell and Shevchenko, 2014).
By exposing the mechanisms of subtle resistance in firms’ TISC reporting, we respond to the
call for greater attention to be given to the political agency of firms (LeBaron and R€uhmkorf,
2019) and the politicisation of organisations (Matten and Crane, 2005; Scherer and Palazzo,
2011; Stevenson and Cole, 2018).
The study contributes to emerging debates in the literature that call for understanding on
how to move beyond intent, or the impression of change, in socially oriented supply chains
(New, 2015, 2020). We propose that the UK’s weak legislative environment for modern slavery
reporting (LeBaron and R€ uhmkorf, 2017) creates the opportunity for ambiguous responses
that allow firms to decouple goals and action and prioritise reputation management over
change to supply chain practice. Prior studies have shown how concepts of obfuscation
(Fabrizio and Kim, 2019) and selective disclosure (Marquis et al., 2016) limit or blur a
stakeholders’ access to information to protect a firm’s reputation. By examining firms’ TISC
responses in relation to the government’s policy ambitions, we reveal ambiguity as a more
active strategy, as, in addition to its protective role, it reduces and shifts accountability. We
posit that reputation management is a strategic choice for firms, and ambiguity is a method
for enacting it.
Defensive reassurance, as the most used technique in TISC statements, sits in contrast to
the intention for the TISC provision, as it maintains existing approaches and limits supply
chain engagement. This technique is also more aligned to traditional notions of ambiguity by
creating an impression of good practice and sufficiency. We contribute to the literature by
identifying scope reduction and transference of responsibility as subtler forms of ambiguity
in modern slavery reporting, where firms partly address government intent whilst
simultaneously shifting the boundaries of their attention and responsibility. Thus, we
build on prior compliance-focused research (Flynn and Walker, 2020; LeBaron and
R€uhmkorf, 2017; Stevenson and Cole, 2018), by revealing how TISC statements serve a
more dynamic and instrumental role in supply chain practice.
Time and change are two inter-related concepts embedded in both the modern slavery
agenda and the broader theory of sustainability. We add additional evidence to support time
and change as key components of the SSSC theory, but we reveal how firms use ambiguity as
subtle forms of resistance against them. TISC statements suggest that firms buy in to SSSC at
an abstract level but use ambiguity to decouple time and change at lower levels of
abstraction. We identify three techniques – defensive reassurance, transfer responsibility
and scope reduction – employed in firms’ TISC reporting to slow down, or negate, the need for
urgent change and to limit the extent of change. Even with statutory pressure, firms are not
simply acquiescing to the demands of urgent change. Thus, we highlight the importance of
time and change, not just as positively valenced concepts, but as interactive points of
resistance in SSSC.
The TISC responses indicate that firms are not taking substantive measures to address
modern slavery in their supply chains. Therefore, along with time and change, we contribute
to the sustainability theory by identifying accountability as an essential concept for
IJOPM generating action. The notion of complicity is under-scrutinised in the supply chain literature,
41,2 as rarely do studies address the dominant supply chain practices, e.g. outsourcing and
subcontracting, that create the conditions for modern slavery (for a notable exception, see
Crane and LeBaron, 2017). The three techniques of ambiguity in modern slavery reporting
reveal how firms are able to avoid scrutiny and accountability. Crucially, the framing of risks
on what firms buy and from where shifts the responsibility for solutions to other, likely
weaker, supply chain members. We posit that the concept of SSSC, and the TISC provisions,
94 requires firms to fully own their accountability for modern slavery. Importantly, this does not
preclude suppliers’ contractual obligations, but these should be in conjunction with a firms’
own responsibilities, not in place of them. The establishment of suppliers’ responsibilities can
be critical to align supply chain processes, but what is missing is overall leadership from large
firms and supply chain heads alluded to in the policy debates. Accountability requires firms
to embrace systematic evaluation of the impact of their sourcing practices as potential causes
of risk beyond typical geographic-based assessments for modern slavery, and to take action,
critically with a supply chain perspective. From this position, accountability also extends to
developing collaborative environments that allow learning, discovery and disclosure.
The use of ambiguity as a strategic resource has potential resonance for other corporate
responsibilities beyond financial return, including social and environmental issues. In the
management field, research has focused largely on how ambiguity is used as a rhetorical
resource within organisations (Jarzabkowski et al., 2010) or in collaborative membership
groups (Huxham and Vangen, 2000). We extend the theoretical application of ambiguity to a
new context of supply chains to provide insight into how the adoption of ambiguous
language in corporate reporting can limit supply chain action, despite legislative pressure.
The lack of action as a result of ambiguity protects firms (Cappellaro et al., 2020; Davenport
and Leitch, 2005) instead of protecting potential victims of modern slavery. The set of
propositions developed from the insights provide a basis for further empirical study in an
emerging research area.

Implications
Implications for policy makers arise from the research. Ambiguity can be reduced through
legislation by (1) introducing additional liabilities in the TISC requirements, (2) greater
enforcement of the existing requirements and (3) strengthened policy guidance for firms.
Because passing new legislation and increasing enforcement can be lengthy processes, as a
first step, we urge additional government guidance focused on how firms can demonstrate
accountability of the solutions for, and causes of, modern slavery in supply chains.
Guidance should reinforce the legislative boundaries and contest defensive, reductive or
exclusionary approaches. As the results demonstrate how firms are circumventing urgent
action, the government and procurement professionals need to ensure that TISC statements
are not taken as a proxy for substantive action. To demonstrate best practice and leadership
in their own supply chains, government buyers need to shift their attention to the content of
their suppliers’ statements, beyond assessments of technical compliance. They also need to
assess what firms are doing – and not doing – in practice, not just what they report.
Solutions, and root causes, should be explored and tackled in collaboration with supply
chain members.
The research also provides examples for managers responsible for the production of TISC
statements of how to embrace the legislative intent of the UK Government’s UK Parliament
(2015), and importantly, it highlights the need for firms to adopt accountability in a supply
chain context. Firms can achieve greater alignment with the legislation, and thus, a greater
potential for tackling modern slavery, through collaborative action within their supply
chains. This will require working with suppliers, beyond the first tier, to actively engage in
finding instances of modern slavery and to acknowledge their own role in creating pressures Modern
within the supply chain. Firms may be reluctant to embrace a more active approach to “find” slavery in
modern slavery, for fear of reputational damage if it is found. Yet, while ambiguity might hide
modern slavery from sight, it does not remove it.
supply chains

Future research
Empirical testing of the propositions provides initial areas of focus for future research. 95
Modern slavery in supply chains is a nascent area of research, as the legislative environment
is also newly emerging. As there is a need for an annual TISC statement to be published, there
is an opportunity for future research to take a longitudinal approach to assess how TISC
statements evolve over time, if at all. Future research could use our model (Figure 1) to map
changes in ambiguity over time, for different sectors, and potentially in different legislative
jurisdictions, which could help to contrast their relative effectiveness. Our study looked at a
set of government suppliers and therefore covered a range of industries. A limitation of this
sample is the inability to draw generalisable conclusions of patterns of ambiguity techniques
by industry, but the identification of defensive reassurance approaches in known high-risk
sectors warrants more detailed future research. Finally, an acknowledged limitation of our
method is that it precludes the attribution of firms’ motives. A qualitative case-based study to
delve into the tensions between commercial, regulative, competitive and social imperatives in
practice promises a rich area for future research.

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Appendix Modern
slavery in
supply chains

Criteria Accountability Supply chain practices

2 Do not mention that their operations need to Excuses why no change necessary in own 101
change. Consider MS someone else’s business (e.g. “no risk identified”, “continue”,
responsibility (suppliers). Limit to first tier “maintain”), defend why maintain own policies
supplier or another subset. Specific limiting (e.g. “existing policies xyz address MS. . .”). Push
responsibility to suppliers, use of prescriptive
language, e.g. “we expect”

1 Do not mention that their operations need to No current change but mention that policies
change. Consider MS someone else’s reviewed at (non-specified) intervals, push
responsibility (suppliers) but not necessarily changes into future, lack of action and lack of
restricted to subset. Perhaps vague limiting acknowledgement of consequences
0 No attempt to limit but nothing about Mention of change by introducing specific
inclusivity/working with suppliers or policies but lack of clarity in timescales. Already
customers within the supply chain had policies in place before legislation (e.g.
monitoring) but did not expand those after
1 Working closely with suppliers. How not Some changes reported, e.g. increase in
explained or evidenced transparency, monitoring or reporting. Focus on
policies rather than practices
2 Proven commitment to tackle MS by specific Concrete evidence what has changed (e.g. “we
actions taken since legislation introduced: e.g. changed from A to B”, but practice not policy).
“we have taken or begun to take the following Explains how they do things differently than they
steps over the last year” used to (e.g. “we stopped, ceased,
implemented. . .”). Change own practices and
enable suppliers to do the same by working with Table A1.
them and addressing issues such as cost pressure Criteria for mapping
caused by their own operations TISC statements

Corresponding author
Joanne Meehan can be contacted at: [email protected]

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