Modern slavery — the act of keeping others against their will, often working for free for their manipulators — is a terror that often can be hidden behind the walls of hotel rooms.
Most hotel companies train staff to be able to alert authorities to suspicious behaviors that are warning signs for human trafficking or modern slavery.
British hotel firm IHG Hotels & Resorts has, as one example, a statement on modern slavery and relevant procedures, which have been updated this year. But such policies and procedures sometimes are complicated across the portfolios of large firms due to the hotels being owned, owner-operated, franchised and/or managed by third parties.
The United Kingdom government passed on July 20 the Illegal Migration Act 2023, which includes standardized guidance on reporting unaccompanied children and victims of slavery or human trafficking.
Critics of the latest bill state it is cruel, backward thinking and liable to drive modern slavery even further into the shadows.
At a July webinar hosted by the Westminster Legal Policy Forum, Julia Mulligan, chairwoman of United Kingdom-based Gangmasters & Labour Abuse Authority, said in the “post-pandemic recovery amongst the business sector, we are seeing all sorts of corners being cut, and [we] have concerns around the use of outsourcing the supply chains in relation to that.”
It is not just hotels that should be on guard, but also the companies that supply, develop and build hotels. That requires firms to regularly update procedures and articles of care.
In the U.K., the Modern Slavery Act, first passed in 2015, was last updated in 2018 to outline the economic and social costs of modern slavery.
A comment from Martin Buttle, better work lead at CCLA Investment Management, outlined the huge spectrum of possible danger points. The investment management firm looks after the Church of England’s investment division, among other charitable organization clients.
“We’ve been engaging with the hospitality sector and the construction sector. And more recently, we’ve also been engaging with supermarkets and firms in the [United Kingdom] agricultural value chain, particularly around the seasonal worker scheme,” he said.
Everyday Exploitation
Buttle said businesses must consider guarding against modern slavery as one of the highest priorities of responsible trading.
“We’re working to try to get better data available to investors on both the salience and incidence prevalence of modern slavery but also on corporate approaches to tackling modern slavery,” he said.
He said too often the business world’s approach to anti-slavery measures is “very tick box.”
“It was probably the last topic to be engaged on after you’ve engaged with companies on their climate-change commitments and other responsibilities, [but] we’ve flipped the dynamics,” Buttle said. “The first question we ask is, have you found more slavery in your supply chains in the past year? If not, why not?”
He said the CCLA is currently devising a “scorecard process where we hope to create a public benchmark of the [London Stock exchange] FTSE 100 and the U.K. construction companies in the FTSE 250 on the degree to which their modern-slavery statements are in compliance with the [Modern Slavery Act].”
He added the initiative should be in play before the end of the year.
Benafsha Delgado, head of social sustainability at the United Nations Global Compact Network United Kingdom, said human trafficking is everyone's concern.
“Global supply chains are extensive networks. They span across countries and continents, and they often involve multiple stakeholders at various stages of production,” Delgado said. “The scope is broad, and there are obscure tiers within the supply chain, which means that unfortunately, modern slavery remains both a pervasive and deeply concerning issue for all industries.”
Mulligan added current economic challenges could result in an upsurge in exploitation of workers.
“The cost-of-living [crisis] might cause issues, [with] people having to pay increased rent, which might lead to higher debts to landlords and more use of umbrella companies,” she said, referring to how people can hide illegally made earnings and make it far more difficult to find the truth behind a situation and to potentially prosecute people.
Rachael Saunders, deputy director at the London-based Institute of Business Ethics, said hotels and other businesses need to develop key building blocks that will elevate concerns about human trafficking to the proper channels via procedures that do not endanger anyone.
These building blocks need to be in place, she said, “in order to have any confidence at all that you’re fit for purpose in tackling issues like modern slavery … to have values that are really powerfully run through the whole of your organization.”
“You as an organization, need to consider your impacts and duty of care to employees, customers, community and environment,” she said. “You also need to be actively listening to your people and your stakeholders.”