Building an anti-human trafficking strategy that protects staff, guests, and the hotel itself
By Cathleen Draper
Hotels are meant to be safe havens for guests, but for traffickers, they can be a place of opportunity. Hotels are frequently co-opted for illicit activity, including domestic servitude, sex trafficking, and forced labor.
More than 60 percent of sex-trafficking victims said they were forced into work in hotels and motels, according to a Polaris Survivor Survey. And states and the federal government are increasingly passing legislation mandating hotel owners and their staff to prevent, recognize, and report human trafficking incidents in hotels.
That leaves staff responsible for noticing the warning signs of labor or sex trafficking. When those signs go unrecognized, the consequences extend far beyond reputational damage. Hotels can face lawsuits, loss of property, and even criminal liability tied to trafficking that occurred on their premises.
Violeta Vega, co-director of programs at BEST (Businesses Ending Slavery and Trafficking), a nonprofit organization dedicated to preventing human trafficking, said a comprehensive, multipronged anti-human trafficking strategy is one of the smartest investments a hotel owner can make to help reduce legal exposure and maintain safety.
“It’s essential that everyone who works in hotels knows what to look for and what to do when they see indicators of forced labor or commercial sexual exploitation,” she said. “It ensures the safety of the customers, staff, and the broader community, so that everybody feels safe and welcomed in the premises that they’re visiting.”
Vega, who leads BEST’s work with the hospitality sector, spoke with Today’s Hotelier about what a truly comprehensive anti-human trafficking strategy looks like.
What are the essential elements every hotel’s anti-human trafficking program should include?
Comprehensive anti-human trafficking strategies will include several different items. For one, they’ll feature policies that address both labor and sex trafficking. They’ll also cover training, including who, when, and how people will be trained. These strategies also include reporting protocols – how often should staff report concerns about human trafficking situations? To whom and how will staff in each area report? And how will management track and respond to those reports, as well as ensure that information gets sent to the proper channels afterwards?
Your strategy should also touch upon internal communication: How are you talking to your team internally about anti-human trafficking? And then external communication – how are you talking to the public about your initiatives?
All of these items are not just a compliance feature; they go beyond that. They build a comprehensive anti-human trafficking strategy that ensures the safety of everybody and the success of the business as well.
Many hotels provide some level of trafficking awareness training. What separates a truly effective compliance program from one that simply checks a box?
Often, we see compliance as simply taking on training. Hoteliers think that as long as training is done, then the box is checked. But in our work at BEST, we think about a program that goes beyond compliance and that is understood at all levels of an organization. It has information on policies, training, reporting, communications, and an implementation plan.
We want to make sure that folks understand the importance of countering human trafficking at all levels of an organization – that includes leadership, general managers, front of house staff, janitorial, and security guards. Everyone needs to be integrated into this program and strategy to counter human trafficking.
How should hotels tailor their policies and training for different departments, such as front desk, housekeeping, maintenance, food and beverage, and security?
Policies and training should be pretty consistent throughout hotels because we’re talking about human trafficking as a whole. We’re looking for behaviors that indicate human trafficking, and those don’t change depending on the department.
There may be some specific trafficking indicators that show up in certain departments. For example, housekeeping will see some indicators that front of staff won’t because housekeeping spends more time inside the rooms. On the other hand, front desk and security staff are more likely to see certain indicators in communal spaces of a property.
Policies and training should be standard across the business but can include specific information for certain departments so staff can be more alert in the spaces where trafficking signals are common.
How often should hotel staff undergo training?
How often you should train is frequently decided by legislators. Some say every year, others say every two years. However, human trafficking prevention training should be available and accessible as often as staff need it.
On top of basic training, staff should have supplemental information so they can refresh throughout the year. Even if they’re training once a year, some employees might forget because there are a lot of trainings they have to take.
Have a little pocket card that reminds staff of the indicators – things like that will help make sure the training sticks with them. Human trafficking doesn’t disappear after training ends. We want employees to know what they’re looking out for and do the best they can to keep people safe.
What are some of the key indicators that hotel staff should look for?
Look for behaviors that suggest force, fraud, or coercion. Those behaviors can vary depending on the situation. They could include distress, injury, confusion, fear, or physical signs of abuse. Or somebody else speaking on a person’s behalf or carrying their documents. Even more specific to a hotel, maybe somebody’s staying for a long time but they don’t have any luggage with them.
When we’re thinking about indicators, we’re focusing on behaviors that could signal a potential human trafficking case. We don’t want to confuse anything that may be our own biases of people, so we want to focus on those behaviors that suggest force, fraud, or coercion.
What are some of the most common mistakes or gaps you see in hotel prevention programs?
Relatively few hotels have a comprehensive strategy for countering human trafficking, and not many have done what it takes at all levels of leadership to build a workplace culture that supports staff in reporting the indicators of human trafficking when they observe them.
Building that workplace culture where employees are encouraged to report potential signs of human trafficking is key to making sure that people are actually raising their hands when something feels off. With that, we often don’t see a clear reporting process. That lack of clarity can increase the risk of a hotel being co-opted by a trafficker.
Leadership involvement is essential. Employees need to trust that their reports will be taken seriously.
What should staff include in their reports?
When reporting, specific concerns should be mentioned. Does it look like a minor is involved? Is it possible that a trafficker is present? Does a staff member or manager have the opportunity to talk one on one with a potential victim? And how fast is the situation unfolding? Are there signs of violence or concern of safety for people around the area? Does the hotel have a well-established incident reporting system already, and can this be tied into that in some capacity?
Questions like those are essential for a strong response protocol. In our training, we encourage people to consider a response based on what is happening in that moment. Each of those conditions – a minor involved, signs of violence, etc. – will shape the response.
How should hotel owners and staff respond to a report of human trafficking?
Each hotel owner needs to consider what tools and resources they have available. For example, if there is a potential emergency, do you have emergency numbers at hand? Do you know who you’re calling depending on, for example, if a minor is involved? Or if there is an immediate emergency and somebody is in danger, or vice versa – if it’s not an emergency, are there additional resources you can provide to a potential victim?
In BEST’s training, those are the kind of questions we walk people through. If it’s an emergency, a minor is involved, or a controller is present, call 911 or your local emergency number. If the potential victim is alone and they are an adult, you can ask if they are OK, or if they want you to call the police. If they don’t want you to contact the police, inform them about the National Human Trafficking Hotline or provide them with available local resources.
Many owners have multiple properties in one state or across a number of states. How can hotel owners stay ahead of evolving state regulations on human trafficking prevention?
We encourage owners to create an anti-human trafficking strategy that includes all the elements above. That will ensure consistency across all levels of leadership within the property while still allowing room to tailor here and there based on legislation. So if there’s a specific addition an owner needs to include because of, say, a state-mandated reporting system, then there’s space to update that specifically.
But for the rest of the prevention strategy, where you’re talking about how you communicate internally and externally, how you document internally, how you provide training, all of that will stay relatively the same across properties. “Leadership involvement is essential. Employees need to trust that their reports will be taken seriously.”
Image: andrey_orlov/stock.adobe.com
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