Abstract
Little is known about the hotel's response to increased legislation on the unethical practice of modern slavery in their operations and supply chains. We examine i) the extent, and quality, of the content of their disclosures and the managerial actions, ii) the communication efforts, through moral legitimacy appeals, and iii) the managerial and disclosure gaps influenced by the UK Modern Slavery Act. Substantive actions dominate. Hotels focus on their direct operations and Tier 1 suppliers, and on isolated risk assessments and due diligence. They omit the victims' perspectives and remedies. By disclosing procedures and structures, hotels demonstrate ‘reasonable effort’ as a proxy for effectiveness in eliminating modern slavery. We advance legitimacy theory, identifying different disclosure behaviors based on either symbolic or substantive actions. We propose two new appeals—Value-based and Personal—relevant to human rights. Reporting turns into a discursive device for moral legitimacy, with implications for policy and practice.
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