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.