Translating Modern Slavery into Management Practice

Galit A. Sarfaty, Allard School of Law at the University of British Columbia

Abstract

This article examines how ill-defined legal norms around modern slavery are being outlined in supply chain legislation and then interpreted by management professionals. Building on an infrastructural analysis of supply chain governance, I uncover the set of practices that underlie recent regulations around modern slavery. I track the implementation of these laws by following the “chain of translation,” whereby information is transformed from on-the-ground raw data; to quantitative metrics of modern slavery risks; and finally, to polished corporate statements. This analysis focuses on the critical role being played by Sedex (Supplier Ethical Data Exchange), which is a platform for sharing responsible sourcing data. While Sedex is not an auditor and is not governed by lawyers, it is nonetheless serving an important function in interpreting legal norms around modern slavery and facilitating the implementation of supply chain laws. Yet there are potential costs to its expansive role. Sedex is translating modern slavery into a management problem largely based on quantitative metrics such as indicators and risk scorecards. While Sedex provides limited opportunities for public participation, it needs to be more transparent as to the methodology behind its metrics and provide further opportunities for comments by parties underrepresented in its governance.