Created and compiled by Shiva Foundation.


This toolkit is intended for the internal use of hotels and other stakeholders in the industry. It has been created as guidance with recommended action and templates throughout to set up strong processes and protocols to address risk of modern slavery within your business and supply chains. The Blueprint can be adapted by individual managers, department heads and teams as appropriate to better suit the nuances and needs of your organisation.

It is important that senior management be ultimately responsible for any processes or policies put in place and that efforts are regularly monitored for effectiveness. We hope to continue adapting the Blueprint in line with best practice and we welcome feedback, constructive criticism and new partnerships to improve this work.

Download the Full Stop Slavery Blueprint

“Slavery and human tracking are illegal. Yet, there are still an estimated 40.3 million people trapped in modern slavery around the world today.”

The global demand for cheap labour fuels the trade in humans and market forces create both the supply and the demand for these people. The hotel and hospitality sector employs 292 million people worldwide (1 in 10 people globally) and contributes 10.2% of the global GDP. Hospitality has been identified as a sector at risk of modern slavery. Hospitality businesses need to take the lead in the fight against modern slavery and human tracking (herein referred to as “modern slavery”).

This Stop Slavery Blueprint (the “Blueprint”) sets out the key principles to be embedded into a hotel as part of its fight against modern slavery. It provides guidance and recommendations in the form of:

• Policies and practices     • Procedures and protocols     • A checklist of suggested actions

These are meant to be adopted across hotels and across departments. The Blueprint provides further specific guidance for individual managers, department heads and teams where appropriate. The guidance focuses on the following key risk areas:



Individual sales

Check-in systems

Guest monitoring



Employment practices

Use of agencies

Supplier engagement



Food and Beverage



Company sales

Contractors and subcontractors






The Blueprint provides guidance on transparency, reporting, performance measurement, business partner engagement, risk assessment, business authentication, and investigation and remediation. Employees can refer to the relevant sections below for further information or contact their manager to discuss these policies in further detail.

General Managers can familiarise themselves with this Blueprint and associated documents to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for any incidence of modern slavery is prevented.

To demonstrate the organisation’s commitment to implementing the recommendations contained within this Blueprint, a statement can be included in company handbooks and starff reading materials as appropriate. See an example Statement.

For the purposes of this Blueprint, the definition of modern slavery, in keeping with the UK Modern Slavery Act 2015, includes:


The movement of people by means such as force, fraud, coercion or deception with the aim of exploiting them.


Ownership exercised over a person; or all work or service that is extracted from any person imposed imposed by coercion or under the threat of penalty and for which the employee has not offered themself voluntarily.

Note, throughout this Blueprint, the terms human tracking and modern slavery refer to both sexual exploitation and forced labour.

“I am pleased to see Shiva Foundation taking the lead on tackling modern slavery and human tracking within the hotel sector. This Blueprint is a robust guide for hotels to take action and I hope to see many within that sector taking it up, and other sectors following the leadership this displays to protect vulnerable people from exploitation.”

Kevin Hyland, UK Independent Anti-Slavery Commissioner (2015-2018)

Having a public commitment to tackle modern slavery throughout a hotel’s operations and supply chain is an important part of addressing the issue. Not only are staff able to see the commitment regularly, guests are aware of the organisation’s efforts to address the problem.

See an example statement: Our Commitment to Tackle Modern Slavery.



the statement internally with all staff and include it as required reading, either at the beginning of their employment or when the statement is being implemented.


the statement into the hotel’s vision, mission, value statement, departmental goals and any other relevant strategic and employment documents, as appropriate.


the statement in bedrooms either as part of the printed information packs, on the TV screens or using another appropriate method.


that a copy of the statement is accessible to staff on a daily basis, for example on the staff room notice boards.


information on the hotel’s stance on modern slavery with prospective staff and new staff joining in their welcome package.


the statement publicly in the lobby areas.

The hotel’s commitment to tackle modern slavery should be integrated throughout its policies, practices and decision-making procedures. By incorporating the position statement on modern slavery into each hotel’s vision, mission, value statement and goals, the commitment will be fed down into every policy, hotel and department.

Further detail is provided below on specific policies and practices for each of the four key risk areas. Individual hotels can incorporate these into their internal policies and practices. Hotels should do this in a way that best integrates with their existing processes but adheres to the overall aim of the Blueprint.

Hotels can be subject to a particular risk of modern slavery when it comes to use of facilities. Specifically:

• Hotels may be used for sex trafficking where victims are compelled to provide commercial sex to paying customers.

• Victims may be forced to stay at a hotel where customers come to them (in-call), or they are required to go to rooms rented out
by the customers (out-call).

• Victims may stay in hotels with their traffickers while moving to locations.


An example Hotel Use Policy to tackle such risks can be found here. This sets out guidance on how employees can ensure that property and services are appropriately used by others. Adhering to these principles helps maintain the respect and confidence of business partners and customers.




the policy internally with all staff and include it as required reading, either at the beginning of their employment or when the policy is being implemented.


the statement into the hotel’s vision, mission, value statement, departmental goals and any other relevant strategic and employment documents, as appropriate.


the full policy into the hotel’s internal policies and documents, as appropriate, including any policies on sales, check-in/check-out and guest assistance.

All employees deserve basic human rights and employment rights, to be treated with dignity and respect, and to be provided a safe and healthy work environment. In addition to formal guidance, a culture that supports the well-being and inclusion of all employees and is committed to encouraging a positive working environment is key.

Incidence of labour exploitation can occur in hotels, notably as the employment structure of the industry is fragmented, and often includes labour providers for casual or outsourced workers for such services as housekeeping and cleaning. The industry relies heavily on low-skilled, migrant and outsourced workers, particularly for temporary and seasonal labour – these demographics are at particular risk of exploitation.

Five key risks to worker welfare in labour sourcing and recruitment include:



Large recruitment fees, whether for recruitment itself, travel, visa or administration costs, can leave workers in situations of debt bondage. Lower-skilled migrant workers tend to pay a higher percentage of job-matching fees than high-skilled non workers.



Labour agencies may not provide written contracts of employment or may provide a contract to workers in a language other than their native language. Workers may find themselves in a different job or with a significantly lower salary than they were promised.



Current factors of labour exploitation include withholding of wages (notably if contract is terminated early), unreasonable pay deductions, wages not paid on time, worker bank accounts controlled by employer, and in-kind payments (e.g. bonds, manufactured goods, etc.).


Retention of ID documents

Workers can be effectively bound to a job or employer when personal documents (e.g. passports) or any other  valuables (e.g. wedding rings), are confiscated, destroyed, withheld, or otherwise denied to the worker, technically preventing them from leaving their job.


Worker living accommodation

If the employer provides accommodation for workers to live, the housing must be safe, clean, and offered at a reasonable price. For migrant workers, there may be no other options of a place to live. As workers become more reliant upon the labour provider, risk of exploitation can increase.

Employee Protections:

• In the case of migrant workers, legal status could be used as grounds for discrimination; any worker who is the victim of a crime
will have the same right to report their abuse freely.

• Likewise women can be particularly vulnerable to modern slavery; it is important to encourage equality and eliminate unlawful
discrimination on the basis of gender.

• Employees should be recruited without regard to race, sex, pregnancy and maternity, civil partnership status, genderreassignment, disability, religion or beliefs, union organisation, age, sexual orientation or any other characteristic protected by law.

• Of particular importance is working towards the elimination of forced labour, prison labour, indentured labour or exploited

Specific examples of employee protections are contained in the Best Practice Commitment on Employment and Human Rights  and the Guidelines for Establishing Terms and Conditions with Recruitment Agencies.

Subcontracted employees can also be vulnerable to exploitation and therefore employment agencies should be made familiar with the Supplier Code of Conduct. bonded labour and supporting freedom of association and the right to communicate their voice as an employee.

An example Hotel Use Policy to tackle such risks can be found here. This sets out guidance on how employees can ensure that property and services are appropriately used by others. Adhering to these principles helps maintain the respect and confidence of business partners and customers.



the best practice commitments into the hotel’s internal policies and documents, as appropriate, including the staff handbook, HR manual, job descriptions, application packs, and
welcome packs.


employees’ attention to any changes made in policies and documents as a result of their incorporation and ensure such commitments are included as required reading, either at the beginning of staff employment or when the policies are being implemented.


that a copy of the relevant policy containing these commitments is accessible to staff on a daily basis, for example in the staff room, in particular to the human resources and recruitment teams.


that any indirect and direct employment is carried out in line with the relevant policy containing these commitments.

It is the hotel’s responsibility to ensure sound social and ethical practices within its own operations and supply chains. Every individual supplying goods or services to the hotel deserves the right to live in dignity and in a safe environment. Moreover, when individuals are treated with respect, both they and their companies benefit from increased commitment and productivity. A method to address this, is to create a Supplier Code of Conduct which sets out a company’s minimum standards and basic principles of cooperation that they expect from all suppliers.

Reminder: Due to the complex nature of global supply chains, it would be impossible at this stage to monitor or control the working conditions of each and every individual who contributes to supplying a hotel. It is important to do what is possible to bring responsible sourcing practices to all stages of the supply and value chain.

Working with Suppliers

Improving social and ethical standards in the supply chain is a challenging process that requires the cooperation of employees, suppliers, business partners and other stakeholders. These example Principles of Implementation recognise this challenge and set out a process of continuous improvement with the ultimate objective of achieving compliance. Similar principles can be added to your Supplier Code of Conduct. It is also important to demonstrate the senior level commitment in your engagement with suppliers. The Message from the Director is an example of how that commitment can be communicated.

Tip: A company can set out the internal criteria to consider when working with a supplier and determining when it is appropriate to terminate this relationship.

During engagement with suppliers, it is recommended to get formal acknowledgment of your principles and expectations. Further, it is good practice to invite the supplier to demonstrate their alignment with those principles by sharing their own policies and best practice. A constructive engagement around the sharing of best practice can be a good foundation for an open dialogue to identify potential risks and collaborate on continuous improvement throughout the course of the business relationship.






the code of conduct internally with staff members who deal with procurement at any level and include it as required reading, either at the beginning of staff employment or when the code of conduct is being implemented.


that a copy of the code of conduct is accessible to relevant staff on a daily basis.


an approved action plan on how to approach suppliers regarding the code of conduct.


a copy of the code of conduct to each individual supplier that enters into a contract with the hotel.


each individual supplier that enters into a contract with the hotel to read, acknowledge and/or sign a copy of the code of conduct.


a yearly review of the code of conduct with each supplier to ensure the continuous improvement plan is underway and that all relevant documents remain in date.

It is important to align the business objectives with a hotel’s commitment to preventing modern slavery within its work. One way of achieving this is by ensuring the head office team, when making broader strategic decisions, complies with Head Office Guidance on Modern Slavery.




the guidance and the principles of this Blueprint internally with all employees at the executive level;


that a copy of the guidance is accessible to employees at the head office on a daily basis;


the principles of the Blueprint in the broader business objectives;


the guidance and adhere to principles of implementation contained within any other policy on modern slavery.


the guidance and the principles of the Blueprint with any existing or potential business partners;

Having clear and straightforward protocols for when an incident is discovered is crucial to ensure that victims get appropriate support. Where employees identify a potential victim, they can follow a specific internal procedure in order to protect the safety of that individual.

There are structural changes hotels can make to ensure staff are aware of any relevant reporting protocols and that modern slavery prevention is considered on a regular basis.

Anti-Slavery Champions: A hotel should appoint someone who can take on the role of monitoring areas of risk (as set out in the Blueprint) on a regular basis in line with the guidelines provided and report anything unusual to the Anti-Slavery Committee (see below) as appropriate via incident reporting protocols and regular meetings. General Managers are recommended for this position. Anti-Slavery Champions should be encouraged to take a proactive approach, in consultation with head office, to take corrective actions in order to mitigate any risks or broader impacts.

Anti-Slavery Committee: A cross-functional group consisting of key representatives from head office should be set up to meet regularly (i.e. twice a year) in order to report any ongoing challenges, patterns or concerns. Representatives from a relevant NGO or service provider should be an integral part of this committee. The committee should review the hotel reports on a case by case basis and determine if there are actions that can be taken to prevent similar cases from occuring in the future. They should also review industry benchmarks to recommend changes and improvements. General Managers and/or Anti-Slavery Champions should feed into the Anti-Slavery Committee through regular internal meetings.

In order for protocols to be effective, it is vital that all employees become familiar with them.

As part of a culture of openness, honesty and integrity, concerns from any employee regarding the guidance set out in this Blueprint, and documents referenced herein, or the law, must be raised with the directors at the earliest opportunity. It is important to establish reporting protocols for employees who suspect a situation of modern slavery. The following are helpful considerations when devising your incident reporting protocols:

• Consider common indicators that staff should be aware of (see an example Indicator List). Not all indicators will necessarily come with the same weight in terms of severity and therefore it’s important to determine the threshold that must be met for an indicator to become an incident that requires action. The example Indicator List has a 3-indicator threshold.

• Establish relationships with key stakeholders before an incident is ever reported. This includes the police to link up reporting protocols and a local victim’s service provider to ensure the response is victim-centred. Other relationships, such as with a professional interpreting service for victims who don’t have English as a first language, can be made as well.

• Be aware that victims might disclose their own exploitation. This is not likely to happen often in hotels, but if it were to staff should be confident on how to respond. See Guidelines for Supporting at Risk Individuals.
Ensure reporting protocols are not overly complex as that can confuse those meant to be implementing them. It is recommended that there is one person who all staff can report concerns to (i.e. the Anti-Slavery Champion) and that s/he has one clear line of reporting (i.e. to the police, hotline or victims service provider). A hotel might want to include modern slavery incidents on their standard Health & Safety reporting forms (see example Incident Report).

• If a victim is identified, their safety should be of primary concern. Consider establishing relationships with nearby sister hotels where victims can be taken during an investigation to keep them out of harm’s way.

• Implement the reporting protocols with a training package to ensure staff fully understand and can retain the information. Classroom style training that covers the indicators, reporting protocols and example case studies is recommended. See Training for further information.


See example Incident Reporting Protocols. If something less detailed is required and crisis management protocols are already in place, see an example Crisis Management Flowchart.

Guests who stay in hotels may want to report something suspicious as well. It is recommended the key contact or Anti-Slavery Champion be listed on the Public Statement in lobbies.

After an incident has been reported, remedy involves three key steps which are outlined below.

Investigation: Any investigation beyond the initial report should be performed by local police and victim service providers, with the full support of head office and the Anti-Slavery Champion, in order to protect the victim(s), employee(s), and the business. It is recommended that an investigation of a report made about staff be done in conjunction with the internal disciplinary procedure. For example, confidentiality should be maintained and the staff may be suspended while the report is being investigated.

Tip: It is important to establish links with the police and other key contacts that might be required before an incident takes place. Other contacts may include a professional interpreter service for translation and victim service providers.

Victim Services: If an investigation confirms probable incidents of slavery, Anti-Slavery Champions should work in cooperation with a local specialist victim service provider to ensure that the victim is protected and aware of all options for access to remedy (judicial and non-judicial). The hotel should work to ensure that victims of modern slavery can continue employment at the hotel where possible.

Tip: The police may not always be the first port of call for a variety of reasons. If the victim does not want the police to be called, there are confidential 24/7 options. It is recommended that the hotel establish a relationship with the reputable victim support provider in the area before an incident takes place. Advisable contacts for victim support in the UK are the Salvation Army (0300 303 8151) and the Modern Slavery Helpline (08000 121 700). It is important confidential numbers are made aware to staff in case they would like to make reports outside of the agreed reporting structure (i.e. if s/he is at risk or suspects a colleague is).

Root Cause Analysis: A root cause analysis for the incident can help determine why the incident involved the business, a supplier or employees. If applicable, and depending upon the severity of the incident, written warning notice or notice of termination may be given to the employee, supplier, contractor, or subcontractor that has violated the policy. If applicable, aim to make improvements that will prevent future incidents. The Anti-Slavery Committee should consider these cases and determine the best approach going forward. Where an incident is reported by a supplier, hotels are encouraged to have a plan in place to address the root cause within a certain timeframe. The plan may include having a meeting with the relevant supplier making clear what steps should be taken to rectify any outstanding concerns. See example Principles of Implementation  which can accompany a Supplier Code of Conduct and set out provisions for reporting incidents.




the details of the protocols internally with all staff and include it as required reading, either at the beginning of their employment or when the protocols are being implemented.


that a copy of these protocols is accessible to staff on a daily basis, for example on the staff room notice boards.


the protocols into the hotel’s existing procedures and documents (such as crisis management policies, emergency policies, health and safety policies, job descriptions, staff handbook) as appropriate.

As outlined in more detail across different sections in this Blueprint, hotels can adopt various control measures as part of their initiative to identify and mitigate risk in the short term:

Relationships: Where possible, build and maintain longstanding relationships with local and trusted suppliers, making clear our expectations of business behaviour.

Employment: Where possible, recruit, vet and employ employees directly, following clear company policies and guidelines.

Compliance: Ensure compliance with current legislation and guidelines by embedding both into the day to day of the hotel’s work. This includes relevant human resources provisions in law such as Working Time Regulations, and the National Minimum Wage.

Knowledge: Improve knowledge base by collecting relevant data and improving transparency within the business and down the supply chain.

Feedback: Promote a company culture whereby the reporting of concerns and the protection of informants is encouraged.

Third Party Engagement: Build strategic alliances with independent unions, social advisors and NGOs.

Measurable Change: Develop verifiable KPIs to measure progress.


To carry out a more detailed analysis of risk in the supply chain, four steps have been outlined below. 

A more detailed approach for working with suppliers can be found in the Framework for Working with Suppliers: Mitigating Risk of Modern Slavery produced by the Stop Slavery Hotel Industry Network.

Identify the organisations within your supply chain, for the supply of people, services and products, across each department. Depending on the size and complexity of the supply chain there may be a number of levels to reach a primary provider. All levels that practicably can be, should be identified in the analysis, including any agents used by a labour provider to source labour in the UK or abroad.

Hotels should work with their direct suppliers in order to ensure they are taking the same steps to track and manage ethical trade risks within their own supply base. A risk-based approach should be adopted throughout. A summary spreadsheet should be kept of all organisations identified within this initial analysis of the supply chain and can be used to track risk and record progress. The spreadsheet may contain information such as:

• Company name
• Address/contact details
• Key contacts
• Product/nature of service supplied/sector
• Position in supply chain

• Location
• Dates of current contract
• Previous relationship
• Acknowledgement of Supplier Code of Conduct
• Ethical trade competence

• Relevant required licences
• What processes are in place preventing illegal working
• What health and safety processes are in place
• Audit dates
• Improvement Action Plan

This information should be used to assess the potential risk of each supplier in the supply chain based on the nature of their business and the processes they have in place in order to identify and focus on those who represent the greatest risk.

Modern slavery risk for any supply chain can be analysed according to various criteria, such as country, commodity and characteristics of the industry. Outlined below are some ways in which you may start to assess risk with regards to your first tier suppliers. The below information was obtained through the analysis and input of STOP THE TRAFFIK. There are external consultants who can help you with this piece of work should it be required.

• Contexts such as armed conflict, a weak rule of law, high incidence of corruption, and insufficient safeguarding of human rights and labour standards by the government may all increase the likelihood of workers being exploited in a particular country or region, and therefore increase the risk of exploitation being involved in the production of a particular product which passes through that region or country.

• Some commodities or commodity derivatives are known to be more or less likely to have been produced using forced labour. This can be closely linked to country risk, but the vulnerability of a specific worker demographic can also be a factor in whether or not products are likely to have been produced using exploitation.

• The following products and services, which are commonly used within the hotel industry, are considered to have higher risk.


Food and beverage

Agricultural work can involve a low skilled migrant workforce that work in often hazardous conditions and may be vulnerable to exploitation by labour contractors or unscrupulous employers.


Housekeeping, cleaning and laundry

The cleaning sector employs a high number of agency workers and subcontracted labour involving intermediaries which increases the risk of exploitation.


Uniform and bedding

The garment industry is high risk for modern slavery due to its long and complex supply chains which operate in countries where exploitative working conditions are prevalent.


Agency staff

Risk of modern slavery incidence arising with the employment of seasonal agency workers can depend on the type of agency and its practices.

An open discussion should take place with each supplier in the supply chain to establish basic requirements and assess the competence of that business to manage its workforce legally and ethically. The Supplier Code of Conduct can be used as the basis to agree a standard with suppliers. The purpose is not to terminate all relationships when full compliance isn’t immediately met. Instead, having an open discussion about your principles and expectations with your suppliers is what best practice recommends. Allow time for suppliers to engage with your expectations and adapt their business practice accordingly.

Hotels are encouraged to implement appropriate management processes with each of their suppliers to monitor that the standards agreed are being complied with and to establish action plans to improve performance, where necessary. A continuous improvement approach is recommended to promote joint ownership of corrective action plans and the raising of standards. Formal review meetings can be held regularly between hotel and supplier to review progress.



Formal review meetings...

held regularly between hotel and supplier to review progress.

Regular compliance tracking...

of suppliers’ policies, processes and performance against the company’s supply chain expectations.


on staff working in your hotel to ensure that the agency employing these workers are acting as agreed in the standard.


by a third-party agency.


Once due diligence is in place with a supplier, it is recommended that there are regular and ongoing audits that the agreed conditions are being met. See Sedex, which is a global not-for-profit organisation which houses the world’s largest collaborative platform sharing responsible sourcing data on supply chains. Sedex provides an Ethical Trading Audit (SMETA).

Identifying and assessing risk is an ongoing process.

It is important that all employees are trained in order to increase their general awareness of modern slavery and the hotel industry and how to spot the signs. Training can also provide details on how to prevent risk of modern slavery in specific roles. See example Training Powerpoint.

Tip: Modern slavery training sessions should be integrated into each hotel’s training course schedule and training strategy. Regular training updates should be run as should yearly refresher trainings, as agreed with the head office. Training should run alongside Health & Safety.

It is recommended that training sessions be facilitated by experts, in consultation with managers, for individuals and departments throughout the business. This training should be designed to go beyond awareness raising in order to help each employee understand his or her role in tackling this issue. Training should be tailored by role and department to have the most impact and relevance.

Trainings should include:

• Background information on the issue;
• Guidance to support employees with an understanding of expected behaviour (see example Indicator List);
• Explanations of relevant policies and protocols;
• Practical examples and Case Studies; and
• Information on how to reassure staff when they’ve reported something, regardless of the outcome.
• Employees should be encouraged to raise concerns during or after these sessions and should be given a disclaimer at the beginning to pre-empt any emotional triggers. It is important to ensure knowledge is retained after the training is completed and therefore it is recommended to use a Quiz to assess retained knowledge three months after the initial training. Short refreshers can also reinforce learning as and when required.


Senior level staff should also be trained, despite the fact that their roles are not operational. Aside from running a training specifically for them, any refreshers or updates can form part of the yearly AGMs. Where applicable, training of suppliers can also be provided.

It is recommended to send out a general briefing to all staff in advance of a large event as such events can often increase risk of modern slavery.

The case studies used in the example training, which are recommended as part of this Blueprint, are from the COMBAT Toolkit. The complete toolkit, designed for addressing modern slavery in hospitality, can be found here.

Hotel executives and management teams should outline specific, measurable and clear KPIs in order to review progress across each area outlined in this Blueprint. These should include monitoring of, among other things:

• Employee training levels and knowledge retention levels (see an example Knowledge Retention Quiz which is recommended to track staff knowledge three months after training).
• Actions taken to strengthen supply chain auditing and verification.
• Steps taken to upskill high risk suppliers, and assessing their ability to detect and mitigate modern slavery risk in supply chains.
• Investigations undertaken into reports of modern slavery and remedial actions taken in response. See an example Reporting Log which can be used at the reception desk to track all reported indicators.


Head office shall also work towards publicly reporting on its policies and procedures, goals and targets, investigations, key risk areas and overall performance related to eradicating modern slavery. A checklist can be useful in ensuring evidence of Blueprint implementation is being tracked. See an example Checklist. It is also helpful having materials displayed so staff can see where implementation is occuring. See example Staff Room Poster.


Looking for help?

If you are looking for help, want to report a suspicion or are seeking advice,
call the Modern Slavery Helpline on

08000 121 700

If its an emergency and you believe someone is in imminent danger, call