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.

RECOMMENDED USE OF HTE PUBLIC COMMITMENT IS TO:

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:

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.

RECOMMENDED IMPLEMENTATION OF COMMITMENTS ON EMPLOYMENTAND HUMAN RIGHTS IS TO:

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.

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.

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.

RECOMMENDED IMPLEMENTATION OF A SUPPLIER CODE OF CONDUCT IS TO:

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.

RECOMMENDED IMPLEMENTATION OF HEAD OFFICE GUIDANCE IS TO:

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.

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.

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.

RECOMMENDED IMPLEMENTATION OF REPORTING PROTOCOLS IS TO:

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:

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.

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.

OPTIONS FOR CONTINUING THE MANAGEMENT PROCESS INCLUDE:

Identifying and assessing risk is an ongoing process.