Purpose

This paper aims to examine how ethics committee documents shape the negotiation of ethical dilemmas in qualitative management and organisational studies (MOS). We show how biomedical logics of harm reduction, inherited from bioethics, become materialised in forms, decision letters and correspondence, producing both protective effects and unintended constraints.

Design/methodology/approach

Using a case study of a project on migrant brick kiln workers in India, we analyse application forms, decision letters and emails through Fairclough’s critical discourse analysis (CDA), treating these as organising texts that define permissible knowledge and language.

Findings

Ethics documents enact three dynamics that constrain qualitative inquiry: epistemic risk (foreclosing knowledge by privileging immediate utilitarian benefit), political risk (sanitising critical terms such as “modern slavery”) and relational risk (neglecting harms that arise unpredictably in encounters). While committees seek to protect participants and researchers, these textual practices also channel ethics into compliance rituals and depoliticised categories.

Originality/value

By analysing documents as the unit of study, this paper shifts debates from adversarial critique to constructive reform. We argue for a dialogic model of review that retains safeguards while recognising researchers as reflexive ethical agents. Our contribution is twofold: extending QROM’s debates on reflexivity by framing it as both resistance and common ground with committees and advancing research governance scholarship by showing how ethics documents themselves organise epistemic, political and relational risks.

Vignette from Field Research: I (the first author) am undertaking fieldwork for a university research project. The site is a village where brick kiln workers are recruited from, and to comply with the requirements of the ethics review committee, I sought permission from kiln owners to document and record the recruitment process. On my request, Surya-bi (name changed) agrees to take me in his cottage for a cup of tea. We are nattering, occasionally laughing, and suddenly there is loud thud on the door followed by an authoritative, somewhat frightening, voice. “Pe*c**d (abusive slur), how could you allow an outsider in the house. Our women are our honour. Interviewing is fine but having outsiders over for tea while women are in the house is unacceptable behaviour ….” Surya-bi submissively listens and nods to what seemed to be a sermon about community values and advises me to leave. I oblige. On my way out, I see the man. It is the local grocer. I left, apologising on the way out. That ended the fieldwork visit.

Above is a description of an event that took place while doing fieldwork for a university project aimed to explore the conditions that lead to the practice of debt bondage in Indian brick kilns. This incident highlights what Guillemin and Gillam (2004, p. 262) call an “ethically important moment”: a situation in which formal consent had been obtained, yet harm emerged relationally. While unintended, the incident raised an ethical dilemma, could harm have been avoided by engaging with the grocer (explaining intentions to visit), or acknowledging community norms (taking the blame for ignorance)? Such moments, however, are common in Global South fieldwork content, where informality, unpredictability, and trust-building practices shape research encounters. Dzhengiz et al. (2025) argue that standardised Western ethics review—emphasising uniform documentation, blanket risk assessments, and risk-averse logics—often clashes with these realities, creating blind spots and stalling projects.

These concerns resonate with long-standing critiques of the expansion of ethics oversight in qualitative research. Scholars have drawn attention to the dominance of biomedical logics (Tolich and Fitzgerald, 2006; Van den Hoonaard, 2011), the expansionist tendencies of “ethics creep” (Haggerty, 2004), and the restriction of methodological diversity (Dickson and Holland, 2017). While ethics committees are tasked with safeguarding participants through informed consent, harm minimisation, and confidentiality (Bouma and Diemer, 1996; Sheehan et al., 2018), in practice these safeguards often manifest as compliance with forms and procedures. As Alvesson and Stephens (2025) note, ethics clearance can become an “absurdocracy” where the work of ethics is displaced into paperwork.

For qualitative management and organisational studies (MOS), these tensions are particularly acute. Ethical risks in this field are relational. They emerge through interactions between researchers, participants, and communities, and cannot always be predicted or pre-empted in advance. The vignette of Surya-bi illustrates this: consent procedures could not substitute for responsiveness in the moment, nor could they account for the social norms that governed community life.

The framework governing research ethics is deeply shaped by its biomedical inheritance. The Nuremberg code [1] institutionalised informed consent and minimisation of harm as universal principles (Bond, 2012), while in Aotearoa New Zealand the Cartwright inquiry [2] (1988) embedded formal ethical review in national practice. These protections remain essential, but they also cemented a model of harm as individual, measurable, and preventable through procedural safeguards. What emerges for qualitative researchers is a textual process of form-filling, review, and response.

In this paper we ask: How do ethics committee documents and correspondence shape the negotiation of ethical dilemmas in qualitative fieldwork, particularly in contexts of precarity and unequal power? By focusing on forms, letters, and emails as the unit of analysis, we examine how procedural ethics is enacted textually and how these shapes the possibilities of qualitative research.

Our contribution is threefold. First, we show how ethics documents produce not only procedural outcomes but epistemic effects, shaping what kinds of knowledge and language are permissible in MOS research. Second, we extend debates on research ethics by highlighting relational harm and reflexivity as sites of ethical practice. Third, we propose a dialogic model of review that recognises committees as protective but ambivalent actors and researchers as reflexive ethical agents. This moves discussion beyond adversarial critique to constructive reform.

The paper proceeds in five stages. We begin by situating our study within Critical Management Studies (CMS), focusing on Levinasian ethics and responsibility to the other. We then outline our methodology, drawing on Fairclough’s Critical Discourse Analysis (CDA) to examine ethics documents as organising texts. The empirical section presents the brick kiln case, tracing how forms, decision letters, and correspondence enacted textual intensification, epistemic governance, and the politics of naming. The discussion develops three dimensions of risk—epistemic, political, and relational—before turning to reflexivity as resistance and the contradictions of committees. The conclusion outlines the dialogic model and its implications for qualitative MOS.

Critical Management Studies (CMS) has long interrogated the ethical, political, and epistemological assumptions underpinning organisational life. As Alvesson and Deetz (2000, p. 1) note, CMS seeks “to disrupt ongoing social reality” by questioning taken-for-granted managerial logics and foregrounding alternative ways of organising. This disruptive orientation makes CMS an explicitly ethical project, concerned not only with efficiency but with power, justice, and responsibility. Our study is situated within this tradition, focusing specifically on one strand of ethical theory that has become increasingly salient: Levinas’s account of responsibility to the Other. While prior literature has extensively examined ethical dilemmas in qualitative research, particularly around reflexivity, care, and trust (Guillemin et al., 2018; Hamilton et al., 2024), our objective is to situate our study within the CMS tradition and extend this scholarship by interrogating how institutionalised ethical review processes may inadvertently undermine the ethical sensitivities developed in the field.

CMS emerged as a critical response to mainstream management studies, which often naturalised organisational forms and managerial control. Early interventions stressed epistemic reflexivity, non-performativity, and the denaturalisation of managerial discourse (Fournier and Grey, 2000). Over time, the field has drawn on diverse traditions—Marxism (Wray-Bliss and Parker, 1998), feminism (Brewis, 1998), postcolonial critique (Gonzalez, 2003), and poststructuralism (Willmott, 1998)—to challenge the authority of mainstream management knowledge. These traditions converge in treating ethics not as codified rules but as a critical engagement with the power relations shaping organisational life.

Relatedly, recent scholarship in qualitative research ethics has also emphasised that ethical conduct in research cannot be reduced to procedural compliance. A growing body of work underscores the contextual, negotiated, and emergent nature of ethical practice, what Guillemin and Gillam (2004) call “ethics in practice.” Such work foregrounds the dynamic and often unpredictable moral decisions researchers must make in the field, particularly in relation to asymmetrical power relations, emotional labour, and situated judgement (Van den Hoonaard, 2011; Haggerty, 2004). In this context, reflexivity has emerged not only as a methodological sensibility but as a central ethical practice, requiring researchers to interrogate their positionality, attend to power asymmetries in the research encounter, and grapple with the ethical implications of representation (Hamilton et al., 2024; Gillam and Guillemin, 2018; Holland, 1999).

This ethical emphasis reflects a recognition that critique cannot be divorced from responsibility. Researchers are not neutral observers but implicated actors. The growth of qualitative, participatory, and ethnographic approaches within MOS reinforces this point, foregrounding the importance of care, trust, and relational sensitivity in research encounters (Guillemin and Gillam, 2004; Cunliffe and Ivaldi, 2021).

Levinas offers a philosophical grounding for this orientation. For Levinas (1969), ethics is “first philosophy”: responsibility to the Other precedes ontology or epistemology. That is, before I categorise, explain, or interpret the Other, I am already responsible. The encounter is mediated through the face, which is not reducible to expression but signifies from itself. As Levinas (1991, p. 240) writes, “the face signifies from itself—its signification precedes Sinngebung.” The face makes a demand: an injunction to responsibility that interrupts autonomy and requires a response (Levinas, 1980). Responsibility does not arise from calculation or empathy but from the immediacy of encounter, where the Other’s vulnerability obligates me before I can choose. In the vignette of Surya-bi, departure was not merely a reaction to the grocer’s threat but a response to the ethical demand of her exposure and vulnerability.

This conception is asymmetrical: I am responsible for the Other before they are responsible for me. It resists reciprocity and codification; no form can exhaust the ethical demand of the face. For qualitative CMS research, this means ethics must be lived in unpredictable encounters rather than reduced to procedural safeguards.

Yet procedural systems often displace such encounters. Haggerty’s (2004) notion of “ethics creep” describes how oversight expands beyond preventing harm to prescribing design, methods, and even language, reflecting institutional priorities such as risk management and reputational protection. Alvesson and Stephens (2025) extend this critique with “orbizzarization” and “absurdocracy”: the dysfunctions of rigid procedure and the dominance of bureaucracy over genuine ethical reflection. Their analysis resonates with many qualitative researchers who find ethics clearance devolving into compliance rituals that erode, rather than enhance, ethical sensitivity.

Readers of this journal will be familiar with these dynamics. Binary risk categories, word-limited fields, and utilitarian framings of benefit versus harm channel ethical reflection into predefined scripts. Decision letters and correspondence can enforce linguistic sanitisation, filtering out politically charged terms such as “slavery” as happened in the case we examine in this paper, in favour of neutral alternatives. Even words like “emotion” or “vulnerability” may trigger heightened scrutiny regardless of context.

To be fair, committees do encourage reflexivity, but their procedures are shaped by biomedical logics and audit culture less suited to qualitative and Global South contexts, where risk cannot be eliminated but must be negotiated (Dzhengiz et al., 2025). Levinas helps us to see what is lost in this process: ethical responsibility that exceeds compliance, the force of participants’ own words, and the unpredictability of harms that emerge in relational encounters.

This does not mean committees are malevolent or unnecessary. Their protective intent is vital. The challenge is that structural legacies constrain the scope for dialogic and situated ethics. Recognising this ambivalence is essential for reform: committees can both safeguard and constrain. In other words, in developing such ethical sensitivities, CMS researchers often draw upon critical theoretical traditions such as Marxism (Wray-Bliss and Parker, 1998), feminism (Brewis, 1998), post-structuralism (Willmott, 1998), and postcolonial theory (Gonzalez, 2003). These traditions share a commitment to analysing power dialectics, such as those between capital and labour, or between the researcher and the researched, and to unsettling dominant normative frames. Within this ontology of antagonism, the ethical stance is not neutral or detached, but deeply normative: CMS researchers must make judgements about what constitutes oppression, resistance, and justice. As Fournier and Grey (2000) argue, the ability to name practices as “exploitative,” “discriminatory,” or “oppressive” is central to the critical ethos.

This normative stance, however, does not imply moral absolutism. Rather, it calls for a reflexive ethics, one that acknowledges the researcher’s own complicity in knowledge production and the situated partialities that shape interpretation (Holland, 1999). Ethical reflexivity, in this view, is a continuous process of self-interrogation and negotiation, rather than a one-time declaration of principles. It complements and extends the critique of procedural ethics by insisting that the most pressing ethical questions in qualitative inquiry are those that emerge in practice, in relation to others, and often in tension with institutional expectations (Guillemin and Gillam, 2004).

While much of the CMS literature on alternatives adopts an overtly normative stance, framing principles such as autonomy, solidarity, and responsibility as morally preferable to those underpinning mainstream management (e.g. Alakavuklar, 2024; Cheney and Munshi, 2017), this framing often presumes the inherent virtue of the “alternative” by virtue of its non-mainstream status. Such a framing risks reproducing a Manichean binary between “mainstream” and “alternative,” which can obscure the entanglements between the two (Alvesson and Stephens, 2025; Del Fa and Vásquez, 2019) and undermine the very reflexivity CMS espouses. We recognise this tension and seek to avoid it by grounding our ethical stance not in a prefiguration of alternatives as inherently just, but in a relational ethic attentive to the specificity and vulnerability of research participants. Rather than relying on a universalist code, we draw on Levinasian ethics to conceptualise responsibility as arising in the face-to-face encounter with the Other (e.g. Rhodes, 2023; Jones, 2016). Yet we acknowledge that this encounter, while foundational, is not sufficient in itself. Reflexivity, for us, is not merely an act of empathetic projection, but an ongoing interrogation of our own positionality and complicity, one that obliges us to adopt concrete ethical practices such as informed consent, minimisation of harm, and the prioritisation of participants’ voices and autonomy. These are not procedural checkboxes, but ethical commitments arising from the relational nature of knowledge production. In this way, we attempt to bridge the tension between rejecting universal ethical codes and upholding minimum ethical obligations rooted in a politics of care and responsibility.

This approach resonates with Levinasian ethics, which rejects consequentialist moral reasoning in favour of an ethics grounded in responsibility to the Other (Levinas, 1993; Levinas and Robbins, 2001). As Rhodes (2020, p. 1) puts “for Levinas, ethics arises out of the disturbance of selfishness and egoism—a disturbance that would put the other person ahead of me such that I might be commanded by the other’s ethical demand”. Levinas’ account privileges the immediacy and irreducibility of the ethical encounter, arguing that genuine ethical engagement arises not from rules or codes, but from the face-to-face relation that calls the self into account. Bauman (1993, cited in Manderson, 2006, p. 8) underscores this point, noting that “the demand of ethics comes from the intimacy of an experienced encounter, and its contours cannot, therefore, be codified.” In this sense, CMS research calls for an ethical review process that prioritises interpersonal accountability and relational ethics over bureaucratic formalism.

Levinasian ethics constitutes a significant departure from dominant approaches to organisational ethics by displacing the centrality of managerial authority and repositioning ethical responsibility within the singular, embodied encounter with the Other (Rhodes, 2023; Levinas, 1969). Rather than conceiving ethics as a rational, procedural means of achieving organisational objectives, this perspective locates the ethical moment in the pre-cognitive, affective responsiveness to the Other’s vulnerability, an encounter that interrupts the self’s autonomy and resists totalising frameworks (ten Bos, 1997). In this framing, ethics is not codified through institutional norms or managerial oversight but emerges in the immediacy of intersubjective relations, where the face of the other issues a demand that cannot be subsumed within instrumental logics (Rhodes, 2016, 2023). Such a view unsettles conventional assumptions about who or what constitutes the ethical subject in organisations, shifting attention away from managerial elites and towards the situated, often fragile, practices of care, responsibility, and interruption enacted by individuals across organisational life (Svane and Frandsen, 2024). By foregrounding this relational and asymmetrical conception of ethical responsibility, Levinasian thought opens space for rethinking the political and moral contours of organisational life beyond normative prescriptions.

From this position, we turn to our methodology, analysing ethics documents as discursive practices to consider how responsibility is organised and how alternative models might support researchers as reflexive ethical agents.

Our research examines the ethics review process by focusing on its documentary traces: the forms, decision letters, and email correspondence that shaped our project’s trajectory toward approval. By treating these documents as the central unit of analysis, we shift the emphasis away from researcher accounts alone and toward the textual infrastructure through which ethical reasoning is articulated, organised, and enforced. In this sense, ethics committees exercise authority not only in face-to-face deliberations but also—perhaps more enduringly—through the very forms and communications that embody, materialise, and reproduce their power. Examining these documents provides insight into how key concepts such as risk, harm, and vulnerability are defined, operationalised, and continually negotiated in everyday practice.

To analyse these documents, we drew on Fairclough’s Critical Discourse Analysis (CDA) (1992, 2003, 2013). CDA treats language as a form of social practice and highlights its dialectical relation with wider social, cultural, and institutional structures. Rather than treating forms, letters, and correspondence as neutral bureaucratic paperwork, this framework allows us to examine them as techniques of power that organise behaviour, regulate conduct, and structure knowledge through language. CDA is especially useful here because it directs attention not only to the linguistic features of texts but also to the conditions of their production and the broader institutional logics they reproduce.

Our analysis followed Fairclough’s three interconnected levels.

  1. Textual Analysis: it involved examining vocabulary, grammar, and genre features. For instance, we looked at how forms posed binary questions such as yes/no responses to “vulnerability,” how letters framed “risk” against “benefit,” and how politically charged terms like “slavery” were problematised or resisted. These textual choices were not incidental but structured how applicants were expected to articulate their projects and how committees evaluated them.

  2. Discursive practice: we considered how texts are produced, circulated, and consumed. Here, our analysis traced how an initial application form could trigger cascades of further forms – a process we describe as textual intensification. We also examined how decision letters channelled permissible discourse by endorsing certain framings while closing off others, and how email correspondence enacted negotiation, often requiring the applicant to reformulate their descriptions of risk, harm, or vulnerability to align with committee expectations.

  3. Social practice: we situated these textual and discursive dynamics within broader institutional logics. Ethics documents did not merely regulate individual projects; they also reflected and reproduced a biomedical model of harm reduction, privileging calculable forms of risk management. At the same time, they operated within the audit culture of contemporary universities, where accountability and compliance are foregrounded. In this way, the paperwork of ethics serves both local and systemic functions: governing the specific project while enacting broader regimes of regulation.

Our empirical material comprises three types of documents: (1) application forms, including initial risk assessments and full applications; (2) decision letters, the formal responses from the ethics committee (see  Appendix B, anonymised); and (3) email correspondence, which recorded exchanges between the committee and the researcher during revisions. Together these materials capture a seven-month review process in which the application was rejected three times before final approval. Each round generated new layers of text, making the archive not simply a record of decisions but an active site where the meaning of concepts such as risk, harm, and vulnerability was continually negotiated and redefined.

Our analysis proceeded iteratively rather than in a simple linear fashion. Following Fairclough (2013), we attended simultaneously to the textual features of documents (such as vocabulary, modality, genre, and silences), the discursive practices through which they were produced and circulated (including committee deliberations, institutional templates, and email correspondence), and the broader social practices they reflected (for instance, biomedical logics, audit culture, and regimes of risk management). This layered mode of reading enabled us to understand documents not merely as bureaucratic artefacts but as sites where wider discourses of ethics, power, and responsibility are enacted, stabilised, and at times challenged.

We constructed an analytic grid that combined Fairclough’s three levels of CDA with sensitising concepts from our theoretical framing. This allowed us to trace how ethics documents generated relational, epistemic, and political risk through their textual, discursive, and institutional features. At the textual level, we coded vocabulary, modality, and intertextual cues (e.g. binary categories of vulnerability or policy references). At the discursive-practice level, we examined how documents prompted specific actions—such as additional forms, clarifications, or reformulations—focusing on patterns of escalation. At the social-practice level, we analysed how these moves reproduced biomedical logics of harm reduction and institutional risk-management priorities.

Our coding structure aligned with three clusters of risk: relational risk (constraints on researcher–participant interactions, expectations of neutrality or distance), epistemic risk (privileging instrumental benefit and limiting qualitative sensibilities), and political risk (sanitisation of terms such as “slavery” or “bondage”). Each document was coded independently before collaborative comparison. For example, the prompt “Does your project involve vulnerable participants?” was read as a textual binary, a procedural trigger, and an enactment of biomedical constructions of vulnerability.

This grid ensured analytic coherence across heterogeneous documents and demonstrated how specific textual features map onto the three interrelated dynamics elaborated in our findings, enabling a relational interpretation of how ethics documents organise ethical practice in MOS.

In practical terms, this entailed multiple rounds of close reading, collaborative discussion, and systematic comparison across the corpus. We examined how researchers, participants, and committees were discursively positioned and how categories such as “risk,” “vulnerability,” and “protection” were linguistically constructed and operationalised. Our concern was less with coding for frequency than with tracing patterns of meaning, contradiction, and tension—moments where procedural logics clashed with relational demands, or where protective intentions simultaneously produced unintended exclusions or silences. Such points of friction were particularly important, as they revealed how ethics review is not only a matter of compliance but also a contested practice of negotiation.

Our analytic process was therefore interpretive, reflexive, and critically attuned. It required us to foreground our own standpoint as researchers and to acknowledge how proximity and distance shaped what we were able to perceive and interpret (cf. Alvesson and Sköldberg, 2017). At the same time, it required attentiveness to the ethical demand carried by the texts themselves, recognising that even routine bureaucratic documents bear traces of lived encounters, contested responsibilities, and the wider institutional conditions under which research is made possible.

As co-authors, we are attentive to our own positionality in this analysis. The first author submitted the ethics applications and conducted the fieldwork as part of a doctoral research project. This proximity means that the documents under analysis are not only institutional artefacts but also lived experiences of negotiation, delay, and re-framing that shaped the trajectory of a researcher working within the traditions of Critical Management Studies (CMS) (cf. Cunliffe, 2003; Alvesson et al., 2009). The experience of repeatedly revising applications, responding to committee queries, and navigating shifting requirements situates these documents as both bureaucratic texts and as markers of personal and intellectual struggle. By contrast, the second and third authors bring greater distance, enabling a more detached reading of the material while also recognising the protective intent underlying the work of ethics committees. This dual positioning allows the analysis to combine insider experience with external critique, holding together empathy for the challenges of review with recognition of its institutional rationalities.

Reflexivity, in this sense, operates on two interconnected levels. First, it is a methodological stance within CDA: acknowledging that analysis is interpretive, situated, and always entangled with the researcher’s standpoint (Fairclough, 2013; Alvesson and Sköldberg, 2017). Our readings are not neutral or mechanical but shaped by our disciplinary commitments and by the personal stakes embedded in the documents themselves. Second, reflexivity is a substantive issue in ethics review. Committees routinely ask researchers to demonstrate reflexivity, often in the form of statements about power relations, potential harm, or positionality. Yet such requirements frequently reduce reflexivity to a procedural checkpoint or self-audit, producing formulaic compliance rather than critical engagement. What is often overlooked is reflexivity as an ongoing practice of ethical responsibility, especially salient in qualitative research and in Global South contexts, where risk is relational and inevitable, and where rigid protocols struggle to accommodate informality, unpredictability, and contingency (Guillemin and Gillam, 2004; Dzhengiz et al., 2025).

Levinas provides a helpful vocabulary for articulating this distinction. Reflexivity is not only a matter of self-awareness but also responsiveness to the Other – a form of responsibility that exceeds what can be captured by documentation or exhausted by compliance. From this perspective, ethics review runs the risk of narrowing reflexivity to a bureaucratic demonstration, overlooking its relational and ethical depth. We therefore position reflexivity simultaneously as a methodological resource and a contested concept within review: a way of grounding our analysis while also offering a lens for interrogating how review processes organise responsibility.

It is from this position that the following analysis proceeds, examining how ethics documents both shape and limit reflexivity, and how Levinasian ethics might help us imagine alternative possibilities for engaging with risk, responsibility, and the demands of research.

Forms warrant close attention because they embody what McLean and Hoskin (1998) call the “forms of the form”: administrative genres that do not merely collect information but inscribe and reproduce institutional logics. Within the context of university ethics review, forms operate as sorting devices that quietly but decisively organise research trajectories. An affirmative response to a question such as “Does your project involve vulnerable participants?” automatically escalates an application into full review, triggering additional fields, stricter scrutiny, and expanded obligations. What appears at first as a benign procedural safeguard in fact reflects the sedimented influence of biomedical ethics, where risk is predefined, measured, and managed through standardised categories that prioritise calculability over contextual nuance.

Exhibit 1 illustrates how these binary categories structure researcher responses in ways that extend far beyond simple disclosure. An affirmative answer does not merely provide information; it generates new layers of obligation, expanding word counts and multiplying requirements until the act of writing itself becomes a performance of ethicality. Exhibit 2 demonstrates this process of textual intensification: acknowledging risk produces further cascades of text, each constrained by fixed character counts that compress complex ethical dynamics into formulaic statements. In this way, forms both demand and delimit the articulation of ethics, creating an illusion of thoroughness while narrowing the space for nuance.

Exhibit 1
A form shows a “Risk Assessment Form” with numbered fields and blank text boxes for project and ethical review details.The form labeled “Risk Assessment Form” begins with “1. Project Title (please limit the response to 25 words)”, followed by a blank text box. It continues with “2. Data collection Start date (The date must be in the future)”. Next is “3. Project Type”. This is followed by “4. Project Summary”, which appears with a blank text box. Then comes “5. Describe the peer review process that has been used to discuss and analyse the ethical issues in this project”, shown with a blank text box. Below it is “6. With whom did you peer review your research”, also shown with a blank text box. After this, “7. Is health and disability ethics committee review required for this research?” appears with the prompt “Select Yes or No”. The form continues with “8. Situations where the researcher may be at a risk of harm. asterisk” followed by “Select Yes or No”. Next is “9. Collection of blood, body fluid, tissue samples or other samples” with “Select Yes or No”. Then appears “10. Any form of exercise regime or deprivation (for example, sleep or dietary)” followed by “Select Yes or No”. Finally, “11. Administration of any drug or medicine” is shown with the prompt “Select Yes or No”.

Risk assessment form

Exhibit 1
A form shows a “Risk Assessment Form” with numbered fields and blank text boxes for project and ethical review details.The form labeled “Risk Assessment Form” begins with “1. Project Title (please limit the response to 25 words)”, followed by a blank text box. It continues with “2. Data collection Start date (The date must be in the future)”. Next is “3. Project Type”. This is followed by “4. Project Summary”, which appears with a blank text box. Then comes “5. Describe the peer review process that has been used to discuss and analyse the ethical issues in this project”, shown with a blank text box. Below it is “6. With whom did you peer review your research”, also shown with a blank text box. After this, “7. Is health and disability ethics committee review required for this research?” appears with the prompt “Select Yes or No”. The form continues with “8. Situations where the researcher may be at a risk of harm. asterisk” followed by “Select Yes or No”. Next is “9. Collection of blood, body fluid, tissue samples or other samples” with “Select Yes or No”. Then appears “10. Any form of exercise regime or deprivation (for example, sleep or dietary)” followed by “Select Yes or No”. Finally, “11. Administration of any drug or medicine” is shown with the prompt “Select Yes or No”.

Risk assessment form

Close Exhibit 1
Exhibit 2
A form shows project detail questions with numbered headings and blank text boxes for written responses.The form shows text on the left side of the page, stating “Application Initial Response”, and includes points “A. Full Application, B. Risk Assessment, C. Project details, D. Participants”, and “Application detail, 3.0 Documentation, 4.0 Submission, and 5.0 Sign off”. On the right side, it shows several headings with blank text boxes. The form begins with “C 1. Aim of the project”, followed by a blank text box. This is followed by “C 2. Background of the project”, with a blank text box below. Next appears “C 3. Outline research or teaching, or evaluation procedures including approach for collecting data and analysis”, shown with a blank text box. Then comes “C 4. To establish trustworthiness, describe the experience of the researcher or supervisor to undertake this project”, followed by a blank text box. Below this is “C 5. Describe the location or setting in which you will collect data?”, with a blank text box. The form continues with “C 6. Is the location overseas? If yes, which countries?”, shown with a blank text box. Finally, “C 6 b. Outline how legal and ethical requirements of overseas countries have been complied with” appears with a blank text box.

Project details form

Exhibit 2
A form shows project detail questions with numbered headings and blank text boxes for written responses.The form shows text on the left side of the page, stating “Application Initial Response”, and includes points “A. Full Application, B. Risk Assessment, C. Project details, D. Participants”, and “Application detail, 3.0 Documentation, 4.0 Submission, and 5.0 Sign off”. On the right side, it shows several headings with blank text boxes. The form begins with “C 1. Aim of the project”, followed by a blank text box. This is followed by “C 2. Background of the project”, with a blank text box below. Next appears “C 3. Outline research or teaching, or evaluation procedures including approach for collecting data and analysis”, shown with a blank text box. Then comes “C 4. To establish trustworthiness, describe the experience of the researcher or supervisor to undertake this project”, followed by a blank text box. Below this is “C 5. Describe the location or setting in which you will collect data?”, with a blank text box. The form continues with “C 6. Is the location overseas? If yes, which countries?”, shown with a blank text box. Finally, “C 6 b. Outline how legal and ethical requirements of overseas countries have been complied with” appears with a blank text box.

Project details form

Close Exhibit 2

Conceptually, then, forms are not mere tools of administration. McLean and Hoskin (1998, p. 520) argue, they function like organisations themselves, institutional spaces constituted by the very practices they mandate. Their analyses stem on Foucauldian understanding of discourse as a key site where power is exercised and institutionalised. In Discipline and Punish, Foucault (1977) shows how bureaucratic procedures materialise disciplinary power through seemingly neutral techniques, while his later work on subjectification (1982) highlights how individuals become governable through prescribed categories and expectations. Ethics review documents reflect these dynamics. They are not passive administrative artefacts but discursive technologies that shape how researchers must describe risk, position themselves, and delimit forms of permissible knowledge. Through the micro-technologies of review—tick-boxes, binary categories, pre-set fields, and word limits—researchers are not simply evaluated but actively produced as subjects. Forms interpellate applicants as compliant, calculative, and risk-aware actors, shaping how they perceive their role, what counts as legitimate knowledge, and how ethicality must be narrated. In this sense, forms are sites of subjectification (Hildebrand-Nilshon et al., 2001), producing “research selves” through the very act of form-filling.

For projects engaging vulnerable groups, minority communities, or politically charged issues such as modern slavery, this subjectifying force carries significant effects. Procedural burdens and anticipated resistance can discourage researchers from pursuing critical inquiry, while the weight of compliance may shift priorities away from substantive engagement with participants. As Jackall (1988, p. 85) observed, managerial ethics often devolves into a logic of “blame time,” where avoiding culpability outweighs enabling meaningful work. In such cases, ethics risks functioning less as a foundation for moral responsibility and more as a mechanism of organisational control, narrowing the scope of what research can be undertaken and how it may be articulated.

Decision letters are more than administrative notices; they actively frame research projects in moral and epistemic terms, shaping how knowledge, risk, and ethical responsibility are understood. Our anonymised rejection letter ( Appendix B) illustrates this dynamic:

The committee is concerned that there may be limited benefit to the participants in comparison to the risks involved in their taking part in the study. The committee agreed that the risks have not been adequately considered.

Here, the committee mobilises a utilitarian calculus derived from biomedical ethics traditions, weighing measurable harms against immediate, tangible benefits to participants. While such a framework may be appropriate in clinical research, it can be misaligned with qualitative organisational inquiry, where benefits are often epistemic, indirect, and long-term—producing critical knowledge about structural injustice or organisational dynamics rather than direct interventions. This tension exemplifies what we term epistemic governance: committees actively set the boundaries of legitimate knowledge by privileging certain forms of value, in this case immediate participant benefit, over broader, more diffuse contributions to understanding.

The same letter also raised concern about the researcher’s embeddedness within NGO networks:

The applicant refers to the NGO throughout the application …. In the terms of this research, the applicant is a researcher first and there is a blurring of the role as a researcher with that as a volunteer.

Here, the committee enforces an expectation of distance and neutrality, echoing positivist assumptions about objectivity and impartiality. Yet for critical, participatory, and ethnographic traditions, proximity is not contamination but a necessary condition for access, trust, and meaningful engagement. Embeddedness enables researchers to observe organisational dynamics, build rapport, and generate nuanced understandings that detached observation cannot capture. Once again, epistemic governance is at work: the committee’s framing positions detached observation as the only legitimate epistemic stance, marginalising approaches that rely on relational engagement.

Decision letters, therefore, do more than convey approval or rejection; they encode assumptions about what constitutes valid research, ethical practice, and acceptable researcher behaviour. They illustrate how ethical oversight is inseparable from epistemic authority, shaping both what can be studied and how it can be studied, and in doing so, they materially influence the production of knowledge in ways that extend far beyond the immediate application process.

Language became a further site of contestation in the ethics review process. The committee repeatedly challenged the use of the term “modern slavery,” recommending what they considered more neutral alternatives, such as “labour dependency.” While the applicant referenced international treaties and conventions recognising debt bondage as a form of slavery ( Appendix A), this justification was largely dismissed. This renaming was not a trivial matter: to describe kiln labour as slavery invokes historical injustice, moral urgency, and obligations for intervention; to reframe it as “dependency” shifts the emphasis toward economic relations, managerial oversight, and risk mitigation. From a Critical Discourse Analysis (CDA) perspective, this represents a shift in interdiscursivity, relocating the project from the moral and human rights discourse to one of development and managerialism, where ethical concern is subordinated to procedural and institutional priorities.

Email correspondence reinforced these dynamics, as discussions repeatedly focused on two central concerns: (1) terminology, where “slavery” was judged provocative and potentially risky, and (2) filming, with video interviews perceived as threatening participant confidentiality and the organisation’s reputation. The committee insisted on substituting neutral phrasing, such as “audio and visual record,” and on the removal of the term “slavery” entirely. Approval was only granted once these changes were implemented, demonstrating how language operates as a site of control, shaping not only how research is described but also how its ethical and moral significance is recognised (or constrained) within institutional processes.

The outcome of the ethics review was not merely procedural approval but a reframing of the project itself. Over a seven-month period, forms, letters, and emails did not simply evaluate the research; they actively reconfigured it. Ethical reflection became a textual performance, requiring articulation in formats and registers that were often at odds with the relational and situated ethics central to the study. Simultaneously, the project’s framing shifted repeatedly to align with institutional discursive boundaries, highlighting how the ethics review process operates as both a gatekeeper and a formative force in research design and conduct.

Across this corpus, three interrelated dynamics stand out.

  1. Textual intensification: Forms expand exponentially as risk is acknowledged, demanding extensive discursive labour that can eclipse relational engagement with participants.

  2. Epistemic governance: Decision letters frame ethicality in utilitarian terms, privileging instrumental benefits and detached researcher roles over broader epistemic contributions or critical inquiry.

  3. Politics of naming: Correspondence and committee feedback often sanitise critical terminology, transforming politically charged language into neutral dependency.

These dynamics are not idiosyncratic to this case but reflect broader institutional logics that shape what research is possible, what knowledge is legitimised, and how ethical responsibility is understood. They highlight the relational, epistemic, and political risks produced when frameworks designed for biomedical research are extended into qualitative and critical traditions. As Dzhengiz et al. (2025) argue, such challenges are particularly acute in Global South contexts, where risk is inherently relational, unpredictable, and unavoidable, and where rigid protocols frequently obscure rather than protect ethical responsibilities.

The intensification of ethics infrastructure cannot be separated from the neoliberalisation of higher education and the rise of audit culture. Universities increasingly function as machine bureaucracies that extend managerial control into domains previously governed by disciplinary autonomy (Nash, 2019). Ethics procedures have expanded into what Boden et al. (2009) describe as a “burgeoning machinery,” reflecting institutional risk aversion and reputational concern more than participant protection. For academic staff accustomed to traditions of discretion, judgement, and expertise, these interventions can appear incoherent, overbearing, or even absurd (Furedi, 2018). Narratives of frustration, identity work, and coping strategies testify to ongoing struggles to resist and navigate this shifting terrain, revealing the laborious, sometimes contradictory, nature of compliance within contemporary research governance.

Taken together, the forms, letters, and correspondence indicate that ethics committees operate as ambivalent organisers. They safeguard participants and researchers but simultaneously reproduce managerial logics that constrain critical inquiry. Ethics, in this sense, becomes a textual practice of compliance, shaping not only what can be studied but also how it may be framed and who researchers are permitted to become within the institutionally sanctioned field of practice. At the heart of this process lies the question of what constitutes acceptable knowledge. Decision letters in our case framed this explicitly in utilitarian terms: benefits to participants must outweigh any potential risks. This calculative framework derives from biomedical traditions, in which measurable harm is weighed against demonstrable therapeutic benefit.

Yet this inheritance is often ill-suited to qualitative research. In social and organisational studies, benefits are frequently indirect, epistemic, and long-term rather than immediate or tangible. They emerge from critical insights into structural dynamics rather than from interventions designed to produce immediate participant advantage. Dingwall (2008) referred to the imposition of biomedical ethical norms on qualitative research as “ethical imperialism,” while Schrag (2011) described them as “silly restrictions,” and Gunsalus et al. (2007) warned of “mission creep,” in which ethics oversight expands beyond its original remit. Fitzgerald (2005) and Hammersley and Traianou (2011) noted that risk-averse moralism can foreclose critical work, and Guta et al. (2013) observed that governance often produces contradiction rather than clarity. Dzhengiz et al. (2025) emphasise that these tensions are particularly pronounced in Global South contexts, where relational risk cannot be eliminated and where rigid protocols, imported from Western institutions, fail to accommodate the informality, unpredictability, and contingency inherent in fieldwork.

For the brick kiln study, this misalignment meant that research designed to illuminate systemic exploitation was evaluated against criteria demanding immediate, demonstrable benefit. The epistemic risk was significant: knowledge about structural injustice—the very knowledge most needed—was marginalised. Levinas’s philosophy helps underscore what is lost in this process. Responsibility to the Other precedes calculation, yet within the ethics framework, responsibility was reduced to bureaucratic arithmetic: forms, templates, and standardised categories constrained ethical engagement to measurable, paperable outcomes.

A second critical dynamic concerns the politics of naming. Across correspondence, the committee insisted that terms such as “modern slavery” and “bondage” be replaced with neutral alternatives like “labour dependency.” Approval was contingent on this sanitisation, illustrating the performative power of language within ethics governance. This was not a mere semantic quibble but a political act with epistemic consequences. Naming practices shape what is recognised and acted upon (Berg and Kearns, 1996). To call kiln labour “slavery” invokes historical injustice, moral urgency, and obligations for intervention; to rename it “dependency” reframes the issue as a manageable economic relationship amenable to procedural oversight. Cooke (2003) observed that management studies has historically erased slavery as an object of analysis, while Crane (2013) argued that modern slavery itself is constituted as a management practice. Christensen et al. (2021) similarly demonstrate how organisational discourse shapes action, displacing uncomfortable realities.

Dzhengiz et al. (2025) argue that this sanitisation reflects a broader disjuncture: committees, motivated by institutional reputational concerns, often depoliticise research in Global South contexts by insisting on neutral terminology. Yet this very neutrality obscures the urgency and historical significance of the issues under study. Levinasian ethics illuminates the stakes: the Other’s demand is not neutral but unsettling. Sanitising politically charged terms in the name of institutional safety risks evading this ethical demand, stripping away precisely the encounter that grounds responsibility (Bauman, 1993; Manderson, 2006).

A third dynamic concerns relational harm, which cannot always be anticipated or captured by forms. The vignette of Surya-bi illustrates this vividly. Informed consent was secured according to procedural requirements, yet harm arose when community norms were disrupted, trust was strained, or expectations of participation were unmet. No static form could have anticipated these emergent, context-dependent outcomes. These relational harms highlight the limitations of review categories designed for biomedical contexts, where risk is conceived as an attribute of individual bodies rather than as relational, contingent, and emergent.

As Austin et al. (2002) note, relational ethics requires attentiveness, responsiveness, and situated judgement—capacities that static categories and templates cannot encode. The SSHSWC (2004) similarly argued that review processes must account for diverse forms of harm, while Gunsalus et al. (2007) and Flick (2022) highlighted the challenge of recognising unpredictable, situated vulnerabilities. Dzhengiz et al. (2025) reinforce that in Global South research, unpredictability and informality are not exceptions but defining conditions of fieldwork. Attempts to pre-empt every harm through form-filling risk shutting down precisely the trust-building encounters on which such research depends.

Levinas’s conception of responsibility clarifies why procedural safeguards are insufficient. Responsibility arises in the immediacy of the face-to-face, not in advance, and is enacted through attentiveness to the Other. Rhodes (2016, 2023) makes a similar point in organisational contexts: responsibility emerges through relational vulnerability rather than codified rules. In Surya-bi’s case, ethical responsibility was lived in the moment of exposure, requiring negotiation and ethical reflection in situ.

If documents risk foreclosing knowledge, sanitising discourse, and neglecting relational encounters, how might researchers respond? Reflexivity offers one path. While committees routinely demand reflexivity, it often risks dilution, reduced to confessional exercises or rhetorical demonstrations of awareness (Pillow, 2003). Robust accounts, by contrast, treat reflexivity as confronting partiality (Holland, 1999), narrating ethical experience (Cunliffe and Ivaldi, 2021), and linking epistemic uncertainty with ethical responsibility (Bell and Willmott, 2020).

In our case, reflexivity functioned as resistance to procedural closure: a tool to interrogate imposed categories, neutralised language, and overlooked relational risks. This resonates with Dzhengiz et al.’s (2025) call to foreground situated reflexivity in Global South fieldwork context, where rigid protocols are least adequate.

Our discussion reinforces existing literature on the contradictions and ambivalences of ethics committees. While it may be tempting to portray them as obstructive “absurdocracies” (Alvesson and Stephens, 2025) or sites of “mission creep” (Haggerty, 2004), our analysis recognises their protective intent. As Shore and Wright (2000) note, accountability systems can be simultaneously coercive and educative. Boden et al. (2009) and Furedi (2018) similarly highlight the duality of control and awareness: committees are protective yet constraining, educative yet bureaucratic.

Recognising this contradiction avoids caricature and opens the possibility of reform. Levinas reminds us that responsibility is asymmetric: committees are accountable to institutions as much as to participants and researchers. The task is not abolition but reconfiguration—supplementing forms with dialogic practices (Tolich and Fitzgerald, 2006; Gillam and Guillemin, 2018) that engage researchers as reflexive ethical agents rather than potential violators. By foregrounding relationality, epistemic diversity, and ethical responsiveness, ethics review can better accommodate qualitative inquiry, complex fieldwork, and the ethical demands inherent in research with vulnerable populations.

Our analysis and discussion show that ethics review is not merely an administrative hurdle but an organising apparatus that produces specific forms of ethical reasoning. Forms, letters, and email correspondence do not simply register ethical dilemmas; they actively constitute the ways in which such dilemmas are defined, categorised, and resolved. In the brick kiln case, three interrelated dynamics were especially evident: textual intensification, epistemic governance, and the politics of naming. These empirically observed dynamics can be reframed conceptually as three dimensions of risk: epistemic, political, and relational. Each dimension underscores how ethics review simultaneously structures research, constrains inquiry, and shapes the ethical responsibilities of researchers.

Textual intensification captures how forms expand exponentially as risk is acknowledged. Questions about vulnerability, risk, or participant protection generate cascading fields, prompts, and word limits, demanding substantial discursive labour from researchers. While forms purport to safeguard participants, the expansion of textual requirements often diverts energy from relational engagement with communities and participants, creating a paradox in which the very tools meant to protect can become obstacles to ethical practice. The second dynamic, epistemic governance, is evident in decision letters that frame ethical reasoning in utilitarian terms, privileging measurable participant benefit and detached researcher roles. This framework derives from biomedical traditions, where harm is defined as quantifiable, and benefit as immediate or instrumental. In qualitative research, however, benefits are frequently epistemic, long-term, and diffuse. Knowledge of structural injustice or social inequality, which is often the core outcome of critical or participatory inquiry, does not always translate neatly into direct, demonstrable benefits for participants. As a result, epistemic governance constrains the scope of what counts as legitimate research and marginalises forms of knowledge that do not conform to pre-defined criteria.

The third dynamic, politics of naming, highlights how language itself becomes a site of governance. Across forms and correspondence, committees repeatedly challenged politically charged terminology, insisting that terms such as “modern slavery” be replaced with neutral alternatives like “labour dependency.” This was not a trivial semantic adjustment but a political act with epistemic consequences. Naming practices shape perception, moral urgency, and intervention. To call kiln labour “slavery” invokes historical injustice and ethical responsibility; to rename it “dependency” recasts the phenomenon as an economic problem amenable to procedural management. Through such interventions, ethics review can sanitise discourse, depoliticise research, and obscure the lived realities of participants, particularly in politically sensitive or Global South contexts where structural inequality and exploitation are deeply embedded.

Taken together, these dynamics highlight the ambivalence of ethics committees. On one hand, review processes draw on a protective legacy—the Nuremberg Code, the Cartwright Inquiry, and other foundational frameworks—to safeguard participants and researchers. Forms, letters, and correspondence encourage researchers to reflect on potential harms, clarify consent processes, and anticipate challenges. On the other hand, when biomedical logics are transposed into qualitative inquiry, they can foreclose knowledge, marginalise critical perspectives, and neglect relational encounters. Dzhengiz et al. (2025) emphasise that this tension is particularly pronounced in Global South contexts, where fieldwork is inherently informal, contingent, and unpredictable. Yet the challenge is not confined to these settings; qualitative research more broadly depends on situated responsiveness, interpretive judgement, and ongoing negotiation—capacities that rigid procedural logics often fail to accommodate.

Levinas helps us articulate what is lost when procedural logics dominate. For Levinas, ethics is “first philosophy”: responsibility to the Other precedes calculation. Narrowing ethics to utilitarian arithmetic – balancing harms and benefits, ticking boxes, or imposing rigid protocols – risks missing the primacy of this ethical demand. When politically charged language is sanitised, the unsettling force of participants’ words and lived realities is evaded. When risk is reduced to binary categories, the unpredictable harms that emerge in relational encounters, such as those experienced by Surya-bi, are overlooked. Levinas reminds us that ethical responsibility arises in encounter, in immediacy, and cannot be fully codified.

How might researchers respond to these constraints? One answer is reflexivity. Committees often require reflexivity as evidence of compliance: a demonstration that the researcher recognises their positionality, privilege, and potential power imbalances. While this is important, such procedural reflexivity risks becoming a self-audit or rhetorical exercise, offering the appearance of ethical awareness without engaging its substance. More robustly understood, reflexivity is an ongoing practice of ethical responsibility: it involves narrating dilemmas, holding questions open, attending to unpredictability, and responding to emergent ethical challenges (Holland, 1999; Pillow, 2003; Cunliffe and Ivaldi, 2021). In our case, reflexivity operated as a form of resistance to procedural closure. By continually questioning imposed categories, documenting relational complexities, and maintaining sensitivity to the ethical implications of research encounters, the researcher could preserve the ethical stakes that forms sought to reduce to compliance. Reflexivity, in this sense, functions as both a methodological and ethical resource.

Recognising this ambivalence is essential for reform. It is tempting to depict ethics review as obstructive bureaucracy—what Alvesson and Stephens (2025) call “absurdocracies,” or what Haggerty (2004) identifies as “mission creep.” Yet our analysis demonstrates that committee documents also perform protective functions: they prompt reflection, highlight risk, clarify consent, and encourage researchers to anticipate potential ethical challenges. As Shore and Wright (2000) note, accountability systems are simultaneously coercive and educative. Similarly, Boden et al. (2009) and Furedi (2018) emphasise the duality of governance: it constrains action while also creating shared standards, awareness, and a baseline of ethical practice. Recognising this duality avoids caricature and opens the way for reform.

Levinasian ethics again informs the path forward. Responsibility is asymmetric: committees are accountable not only to participants but also to institutions, reputations, and regulatory frameworks. The task is therefore not to abolish committees but to reconfigure their practices, creating space for researchers to act as reflexive ethical agents rather than potential violators. Reflexivity can function as a hinge in this reconfiguration: it serves as evidence of competence while simultaneously sustaining ongoing ethical attention.

A more dialogic model of review emerges from this perspective. Instead of relying exclusively on static forms and procedural checklists, committees could incorporate dialogic practices such as structured conversations, ethical reports, iterative feedback, and reflective engagement with situated dilemmas (Tolich and Fitzgerald, 2006; Gillam and Guillemin, 2018). Such mechanisms retain safeguards and accountability but also allow researchers to articulate relational, political, and epistemic complexities. They open a space for ethical reasoning that is responsive, context-sensitive, and attentive to participants’ voices.

In sum, our analysis shows that ethics review functions as an organising apparatus that shapes research, knowledge, and ethical practice. Forms, letters, and correspondence produce textual, epistemic, and political pressures, which can protect but also constrain. Reflexivity emerges as a crucial resource, enabling researchers to navigate these pressures while remaining ethically attentive and critically engaged. Ethics committees, for their part, are ambivalent actors: simultaneously protective and constraining, coercive and educative. By recognising this ambivalence and foregrounding dialogic engagement, ethics review can evolve from a compliance-oriented process to one that fosters reflexive, responsible, and contextually attuned research.

This paper asked how ethics committee documents shape the negotiation of ethical dilemmas in qualitative fieldwork, particularly in contexts of precarity, marginalisation, and unequal power. By analysing forms, decision letters, and email correspondence, we have shown that review processes govern research not only through committee deliberation but through the texts themselves. These documents are not neutral records; they actively enact institutional logics, define what counts as risk, and channel permissible discourse. They function as instruments of oversight and protection, safeguarding both participants and researchers. At the same time, however, they constrain inquiry by foreclosing knowledge that is difficult to categorise, sanitising politically charged or morally urgent language, and overlooking relational harms that emerge in the lived dynamics of fieldwork.

We reframed these dynamics as three interrelated dimensions of risk. Epistemic risk arises when utilitarian logics privilege short-term participant benefit over long-term structural insight, thereby marginalising the production of critical knowledge about systemic exploitation or organisational injustice. Political risk emerges when politically charged terms are sanitised in the name of neutrality, depoliticising contested realities and attenuating the ethical urgency embedded in participants’ experiences. Relational risk follows from the neglect of situated encounters, where ethical responsibility is enacted in immediate, unpredictable interactions rather than pre-coded categories. While these risks are particularly visible in Global South contexts, where informality and unpredictability structure fieldwork (Dzhengiz et al., 2025), they are relevant to qualitative research more broadly, including in organisational studies, where relational nuance and ethical responsiveness remain central to responsible inquiry.

Levinas provides a lens for understanding what is lost when procedural logics dominate. For Levinas, ethics is “first philosophy”: responsibility to the Other precedes calculation or codification. When committees reduce responsibility to formal compliance, they risk evading the ethical demand inherent in participants’ words, behaviours, and vulnerabilities. Yet the solution is not abolition. Ethics committees are ambivalent actors: protective and educative, yet simultaneously bureaucratic and constraining. Recognising this ambivalence is crucial, as it opens the possibility of reform rather than mere critique.

Reflexivity emerges as a hinge for such reform. Too often treated as a procedural checkbox, reflexivity is better understood as substantive ethical labour: narrating dilemmas, acknowledging uncertainty, and remaining responsive to unpredictable and emergent risks. In this sense, reflexivity functions as resistance to procedural closure, allowing researchers to maintain attention to relational and political complexities that forms may obscure. Simultaneously, it offers a bridge to committees, creating a shared ethical orientation grounded in deliberation rather than simple compliance.

From this perspective, we argue for a dialogic model of ethical review. Such a model would retain procedural safeguards rooted in the lessons of Nuremberg and the Cartwright Inquiry, but it would supplement them with dialogic practices: structured conversations, ethical reports, and iterative exchanges that recognise researchers as reflexive ethical agents (Tolich and Fitzgerald, 2006; Gillam and Guillemin, 2018). Rather than reducing ethics to forms, checklists, and sanitized language, this approach would allow for engagement with the relational, political, and epistemic dimensions of research, preserving participant protection while enabling the critical and contextually sensitive scholarship necessary to illuminate organisational life in settings shaped by precarity, marginalisation, and power asymmetries.

For Qualitative Research in Organizations and Management, our contribution is twofold. First, we extend debates on reflexivity by demonstrating how it functions both as resistance to procedural closure and as a bridge to constructive reform within ethics review. Second, we advance scholarship on research governance by analysing ethics documents as organising texts that produce epistemic, political, and relational effects.

Ethics committees emerged to prevent atrocities and remain indispensable. Yet to meet the ethical and epistemic challenges of qualitative research today, they must evolve. A dialogic model offers a pathway that preserves protection, fosters accountability, and enables the reflexive, critical, and ethically engaged scholarship that management and organisational studies urgently require. By reframing ethics review as both a site of oversight and a forum for dialogue, researchers and committees alike can navigate the tensions between protection, compliance, and the generation of knowledge that matters.

Table A1

Slavery treaties and definitions

Slavery treaties or conventionsDefinition of slavery
Slavery Convention 1889Slavery defined as “the status or condition of a person over whom any or all of the powers attaching to the right of ownership are exercised”
Slavery Convention 1926Forced labour included in the definition of slavery:
States should “prevent compulsory or forced labour from developing into conditions analogous to slavery.”
Universal Declaration of Human Rights (1948)Conditions of servitude added:
“No one shall be held in slavery; slavery and the slave-trade in all their forms shall be prohibited” Universal Slavery declaration 1948
Slavery Convention 1956Debt bondage, serfdom and exploitation of labour of young people added: (a) “Debt bondage, that is to say, the status or condition arising from a pledge by a debtor of his personal services or of those of a person under his control as security for a debt, if the value of those services as reasonably assessed is not applied towards the liquidation of the debt or the length and nature of those services are not respectively limited and defined”
(b) “Serfdom, that is to say, the condition or status of a tenant who is by law, custom or agreement bound to live and labour on land belonging to another person and to render some determinate service to such other person, whether for reward or not, and is not free to change his status”
(c) “Any institution or practice whereby a young person under the age of 18 years is delivered by either or both of his natural parents or by his guardian to another person, whether for reward or not, with a view to the exploitation of the child or young person or of his labour” UNHR (resolution, 1956)
International Covenant on Economic, Social and Cultural Rights (ICESCR)Freedom of choice of work and safe and healthy work conditions included:
“The States Parties to the present Covenant recognise the right to work, which includes the right of everyone to the opportunity to gain his living by work which he freely chooses or accepts and will take appropriate steps to safeguard this right.” (UNHR resolution 1976)
Rome Statute of the International Criminal Court (1998)Slavery Redefined:
“Enslavement’ means the exercise of any or all of the powers attaching to the right of ownership over a person and includes the exercise of such power in the course of trafficking in persons, in particular women and children” (ICRC, 1998)

Approval of the application was declined for the following reasons (First Decision Letter):

  • The committee agree that this is an important study area, and the potential vulnerability of participants requires that the researcher thoroughly considers the ethical issues of the study.

  • The committee are concerned that there may be limited benefit to the participants in comparison to the risks involved in their taking part in the study. The committee agreed that the risks have not been adequately considered. There has been considerable study of this group (list of studies).

  • The participants could be considered a vulnerable group in this study. The applicant refers to the group as “underprivileged workers” and the title of the study explores “Modern slavery”. In terms of harm to the researcher it is noted there may be resistance to the applicant being there, but states that as an NGO worker he has “permission to continue”. This is not the same as having permission from the owners of the brick works to be there for the purposes of this research and his presence may well put himself and potentially the participants in a risky situation.

  • There is no information supplied as to how the participants will be identified and recruited.

  • The applicant refers to the NGO throughout the application but supplies no information. In terms of this research, the applicant is a researcher first and there is a blurring of the role as a researcher with that of a volunteer.

  • The researcher has not identified any potential harm to participants as individuals or as a group of workers from taking part in the research although there is a plan to interview workers on their working conditions which has the potential to reflect negatively on the plight of the workers and highlight negative findings about their employers. If workers were known to have co-operated with a study which highlights failings of their employers, it may potentially be a risk factor for those workers.

  • The committee agreed that more thought should be given to the information and consent process and communication with the participant group. The researcher has indicated that the participants will not be able to speak English, but no mention is made of whether they can read the information sheets/consent forms (and whether translated documents will be available to them).

A substantially revised application may be submitted for reconsideration.

Choosing “Yes” on any of these questions means a full ethics approval process is needed.

Does your research include:

  • 1. Situations where the researcher may be at risk of harm

    • a. ○ No

    • b. ○ Yes

  • 2. Use of a questionnaire or interview, whether or not it is anonymous, which might reasonably be expected to cause discomfort, embarrassment or psychological or spiritual harm to the participants.

    • a. ○ No

    • b. ○ Yes

  • 3. Processes that are potentially disadvantageous to a person or group, such as the collection of information which may expose a person/group to discrimination.

    • a. ○ No

    • b. ○ Yes

  • 4. Collection of information of illegal behaviour(s) gained during the research which could place the participants at risk of criminal or civil liability or be damaging to their financial standing, employability, professional or personal relationships.

    • a. ○ No

    • b. ○ Yes

  • 5. Collection of blood, body fluid, tissue samples or other samples.

    • a. ○ No

    • b. ○ Yes

  • 6. Any form of exercise regime, or deprivation (e.g. sleep or dietary).

    • a. ○ No

    • b. ○ Yes

  • 7. Any form of physical examination (e.g. physical, radiation, ultrasound).

    • a. ○ No

    • b. ○ Yes

  • 8. The administration of any form of drug, medicine (other than in the course of standard medical procedure), or placebo.

    • a. ○ No

    • b. ○ Yes

  • 9. Physical pain, beyond mild discomfort.

    • a. ○ No

    • b. ○ Yes

  • 10. Any teaching which involves the participation of students for a demonstration of procedures or phenomena which have potential for harm.

    • a. ○ No

    • b. ○ Yes

  • 11. Participants whose identities are known to the researcher giving oral consent rather than written consent, other than for cultural reasons.

    • a. ○ No

    • b. ○ Yes

  • 12. Participants who are unable to give informed consent.

    • a. ○ No

    • b. ○ Yes

  • 13. Research on your own students/pupils.

    • a. ○ No

    • b. ○ Yes

  • 14. The participation of children (seven (7) years old or younger).

    • a. ○ No

    • b. ○ Yes

  • 15. The participation of children under sixteen (16) years old where active parental consent is not being sought.

    • a. ○ No

    • b. ○ Yes

  • 16. Participants who are in a dependant situation, such as nursing home or prison, or patients highly dependent on medical care.

    • a. ○ No

    • b. ○ Yes

  • 17. Participants who are vulnerable.

    • a. ○ No

    • b. ○ Yes

  • 18. The use of previously collected identifiable personal information or research data for which there was no explicit consent for this research.

    • a. ○ No

    • b. ○ Yes

  • 19. The use of previously collected biological samples for which there was no explicit consent for this research.

    • a. ○ No

    • b. ○ Yes

  • 20. Any evaluation of organisational services or practices where information of a personal nature may be collected and where participants or the organisation may be identified.

    • a. ○ No

    • b. ○ Yes

  • 21. Deception of the participants, including concealment or covert observations.

    • a. ○ No

    • b. ○ Yes

  • 22. Conflict of interest situation for the researcher.

    • a. ○ No

    • b. ○ Yes

  • 23. Payments or other financial inducements (other than reasonable reimbursement of travel expenses or time) to participants.

    • a. ○ No

    • b. ○ Yes

  • 24. A requirement by an outside organisation (e.g. a funding organisation or a journal in which you wish to publish) for approval.

    • a. ○ No

    • b. ○ Yes

Researchers may also choose the full approval route for education and training purposes.

1.

As a result of Nuremberg trials, a set of guidelines called Nuremberg principles were created leading to a formation of set of research ethics for human experimentation.

2.

The Cartwright inquiry was an inquiry held in New Zealand to investigate the failure of National Women’s Hospital (NWH) to treat patients of cervical cancer adequately as a result of experimentation of an ongoing research that failed to recognise the dangers to the patients.

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