Modern slavery governance in universities: beyond compliance

Purpose This study examines how universities address modern slavery within their governance structures and practices, with reference to the UK Modern Slavery Act 2015. Moving beyond analyses of statutory Modern Slavery Statements, it centres on the reflections of officers responsible for designing, implementing and reporting institutional responses. By conceptualising modern slavery as a form of economic exploitation embedded in structural inequalities, the study evaluates whether universities move beyond compliance towards reflexive, justice-oriented engagement, and introduces a systematic, theory-driven approach for assessing institutional practice. Design/methodology/approach The study develops and applies the Modern Slavery Reflexive Assessment Scale, a sixty-item instrument grounded in the Pluralistic Framework for the Study of Economic Exploitation. Data were collected in 2025 from eighteen universities in the UK through structured assessments completed by institutional officers. Responses were analysed across six principles and multiple domains, including governance, procurement, knowledge practices, participation and alignment with the Sustainable Development Goals. Findings The findings indicate that universities are beginning to develop more structured approaches to modern slavery governance. Longer-standing institutional engagement and stronger sustainability performance are consistently associated with higher levels of reflexive practice, suggesting that continuity and embedded governance cultures support movement beyond symbolic compliance. Progress is most evident in policy development, governance arrangements and sustainability integration. However, substantial gaps remain. Engagement with intersectional and decolonial perspectives is limited, while survivor-centred practices, participatory monitoring, iterative learning and systematic impact evaluation are underdeveloped, indicating that many institutional responses remain procedural instead of substantively transformative. Practical implications The findings show that anti-slavery governance is most effective when embedded within wider sustainability and institutional governance frameworks, instead of being treated as a narrow compliance task. The Modern Slavery Reflexive Assessment Scale provides universities with a diagnostic tool to identify gaps between policy commitments and operational practice, particularly in survivor participation, intersectional analysis and evaluation. Stronger performance is associated with sustained institutional engagement, leadership commitment and integration across procurement, risk management and reporting systems. Practically, the results highlight the need to invest in survivor-informed mechanisms, participatory monitoring, disaggregated data systems and iterative learning processes that move institutions beyond symbolic compliance towards substantive impact. Social implications The study highlights the importance of addressing modern slavery as a structural form of economic exploitation embedded within broader inequalities. Universities play a critical social role as employers, purchasers and educators, and their governance practices have wider implications for poverty reduction, gender equality, decent work and institutional accountability. Evidence that long-term engagement and sustainability-oriented governance are associated with stronger reflexive practice underscores the value of continuity, integration and resourced institutional commitment. By embedding anti-slavery strategies within social justice and sustainability agendas, universities can contribute to more durable, participatory and equitable responses to exploitation across supply chains and communities. Originality/value This study makes an original contribution by translating a pluralistic political economy framework of economic exploitation into a systematic, practice-oriented assessment of modern slavery governance in higher education. It develops the Modern Slavery Reflexive Assessment Scale, a novel empirical instrument that moves beyond disclosure-based and compliance-oriented evaluations. By centring the reflections of officers responsible for implementation, instead of relying solely on statutory statements, the study captures how responsibility for modern slavery is interpreted, prioritised and enacted within institutional governance. The findings also provide the basis for developing the Reflexive Anti-Slavery Governance Model for Higher Education, an interpretive framework that synthesises five interrelated dimensions of governance development: Compliance Foundation, Institutional Embedding, Epistemic and Participatory Inclusion, Reflexive Learning, and Transformative Accountability. In doing so, the study advances conceptual, methodological and applied understandings of institutional responsibility for exploitation, positioning universities as active civic and economic actors, beyond the role of passive reporting entities.