Deconstructing Modern Slavery Statements: A Detailed Analysis of Arcadia Group and Babcock International

Abstract

What can be learned from a detailed reading of the statements made by firms in response to Section 54 of the UK’s Modern Slavery Act 2015? This paper presents an in-depth analysis of the development of the statements over time for two large companies in different sectors and with contrasting characteristics. We show that the statements progress in sophistication over time, but have serious limitations. We demonstrate that although they present interesting information about the management of working conditions in the firms’ supply chains, they do little to address the problems of modern slavery per se. Furthermore, we show that the statements can contrast strongly with other documents published by the firm, and with established patterns of business practice. For both firms, we show that a deep understanding of the context of the organization is essential for interpreting the statements – but this contextual information is unlikely to be available to the casual reader. We conclude that the statements, as they are currently specified may in fact provide a way of deflecting the engagement of Civil Society Organisations, in a way not envisaged in the formulation of the Act. This paper is an extended version of a section of the report Hsin, L., New, S.J., Pietropaoli, I. and Smit, L. (2021). Accountability, Monitoring and the Effectiveness of Section 54 of the Modern Slavery Act: Evidence and Comparative Analysis. London: Modern Slavery Policy and Evidence Centre, providing greater detail than was possible to include in that report.