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Definition of Human Trafficking
Human trafficking is the acquisition of people by improper means such as force, fraud or deception, with the aim of exploiting them. It is a complex problem brought about by inter-related economic, social, cultural, political and personal factors. Those trafficked are exploited into prostitution, forced labour, for the removal of their organs and other emerging forms of trafficking including organised begging, benefit fraud, domestic servitude and forced marriage. In short, it is modern day slavery.
The UN Palermo Protocol definition is globally accepted:
Trafficking in persons shall mean the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs.
Source: United Nations Office on Drugs and Crime (UNODC)
Throughout this Know-How Guide, the term human trafficking refers to trafficking for both sexual and labour exploitation.
Facts and figures
Human trafficking is, by nature, a 'hidden' crime. The statistics below are only an estimate of the size of the problem and thus can vary from organisation to organisation. The attached maps, produced by Maplecroft, show the stark reality of the scale of the problem. In over 50 countries there is an 'extreme risk' of forced labour affecting a business and in over 70 an extreme risk that trafficking, in particular for sexual exploitation taking place. Both of these indices are taken from Maplecroft's annual Human Rights Risk Atlas, and are qualitatively scored against a peer-reviewed methodology using publically available data (using media sources, US Stated Department reports, Human Rights Watch reports etc.).
The Forced or Involuntary Labour Index is based upon research into incidents of forced labour, the severity of these incidents and their duration, as well as the capacity of the state to implement its international human rights obligations to prevent slavery and forced labour (e.g. ILO Convention No. 29). The Human Trafficking Index is based upon similar research, but looking at incidents of trafficking activity. While it is not focused exclusively on trafficking for the purposes of sexual exploitation, a 2009 report by the UN Office on Drugs and Crime (UNODC) estimated that trafficking for these purposes accounts for 79% of all recorded trafficking cases. Of the balance, a proportion will be subjected to sexual exploitation even if the primary purpose of trafficking them was related to other criminal activities. Given this research, we are confident that the map gives a good overview of the international picture.
Figures on the impact on the hotel industry specifically are hard to come by so our maps just show the main reasons human trafficking and forced labour is a risk in some key destinations. However, government and law enforcement agencies pinpoint the hospitality industry as being high risk, and the increasing number of national initiatives in many countries highlights the growing focus on this issue as one which is particularly relevant for hotels. Whether statistics are available or not, there should be no threshold of interest and engagement with this issue - no level of human trafficking is acceptable.
> Women account for 55-60 per cent of all trafficking victims detected globally; women and girls together account for about 75 per cent.
> Twenty-seven per cent of all victims detected globally are children. Of every three child victims, two are girls and one is a boy
> Trafficking for sexual exploitation is more common in Europe, Central Asia and the Americas. Trafficking for forced labour is more frequently detected in Africa and the Middle East, as well as in South and East Asia and the Pacific.
> Trafficking for the purpose of sexual exploitation accounts for 58 per cent of all trafficking cases detected globally, while trafficking for forced labour accounts for 36 per cent. The share of detected cases of trafficking for forced labour has doubled over the past four years.
> Victims of 136 different nationalities were detected in 118 countries worldwide between 2007 and 2010.
> Between 2007 and 2010, almost half of victims detected worldwide were trafficked across borders within their region of origin. Some 24 per cent were trafficked inter-regionally (i.e. to a different region).
> The number of convictions for trafficking in persons is in general very low. Notably, of the 132 countries covered, 16 per cent did not record a single conviction between 2007 and 2010.
Human trafficking and the US hotel industry
The Polaris Project 2015 study of Human Trafficking and the Hotel Industry shows how the issue manifested itself in the United States between December 2007 and February 2015 with cases reported to the National Human Trafficking Resource Centre hotline Polaris BeFree helpline:
> 1,434 cases of trafficking in hotels and motels and 1,867 victims and survivors identified
> The majority of human trafficking was sex trafficking (92%), with 5% labor trafficking and the remainder (2%) both sex and labor trafficking.
> 69% of cases were adults, 45% were minors. Females accounted for 94% of the victims.
The briefing shares trafficking indicators and makes recommendations for the hotel industry so is a good resource for getting a better understanding of what human trafficking can look like in the hotel sector.
Implications for the hotel industry
Human trafficking can impact a hotel in a variety of ways;
There is no evidence to suggest that large chains or smaller independents are more at risk. The risk is higher in properties where there is sub-contracted staff, hiring of migrant workers, lack of policy and enforcement and lack of awareness in staff.
The business case for action
Why the investor community is interested in this particular issue and what difference it would make it a hotel company did not have any policies or activities in this area?
Faith-based and socially responsible shareholders have worked for more than twenty years with leading companies across many sectors on good practice around supply-chain transparency and accountability, and they are stronger and more resilient as a result. As a natural out-growth of this work, investors have engaged the hospitality sector, recognizing that lack of attention to human rights issues poses real risk to companies, including reputational, legislative and regulatory risk. Awareness of these risks and knowledge of the ways that traffickers may use a company's premises, products and services in connection with their trafficking activities can help companies avoid negative publicity, business interruptions, potential law- suits, public protests, and a loss of consumer trust, all of which can impact shareholder value.
Beyond the obvious moral reasons, there is a need for companies to develop a holistic and long term human rights due diligence process, including human trafficking, based on an analysis of company activities and relationships and how these affect people and their rights. Comprehensive assessments of potential exposure to human rights violations are an essential measure of sound governance, help to build trust, and value in the brand. In addition to helping shareholders and consumers make in- vestment and purchasing decisions, many corporations find that their efforts to strengthen global labor standards and to eradicate slavery and human trafficking not only uncover human rights issues that have the potential to impact their position in the marketplace, but also reveal opportunities for improvement.
We call on hospitality companies to not only create and implement comprehensive, transparent, and verifiable human rights policies and systems for their direct operations and supply chains but also to disclose information to stakeholders, including shareholders, about their implementation measures, management processes, goals, and evaluation techniques. As socially responsible shareholders, we view a commitment to transparency and disclosure as evidence of proactive and attentive management and an important aspect of corporate social responsibility that is a critical tool for building trust with investors and the public. It also provides a basis for analysis and allows shareholders to evaluate a company's progress over time and compare company performance to that of its peers. Leadership in transparency and disclosure may enhance a company's public profile with investors, current and future customers, and results in a competitive advantage within the sector.
By Julie Tanner Assistant Director of Socially Responsible Investing Christian Brothers Investment Services, Inc (CBIS).
So what should hotels do?
With such a complex and difficult topic, it is important that the first thing you do is make a plan. When planning, bear in mind the following points;
The following suggested approach will help you build robust policies and activities to reduce risk of exposure to trafficking and forced labour:
Inform yourself. There are many resources available on human trafficking and key sites and documents are listed below in the Further Reading section. Speak to organisations working in this area to understand the issues. Don't be scared - they are likely to be delighted you are engaging with them! Know the law and what is required of you in terms of hiring policy, reporting and your liabilities. For current information on applicable legal instruments and standards, see the International Labour Organisation. As the policy landscape is always changing, it is your duty to keep up to date with local laws.
Identify any key risk areas. Do you use agency staff? Are any staff migrant workers? Are you operating in a region known for sex tourism? Are there large events in your area where there may be an increased risk of trafficking? Studies indicate that mega sporting events such as the Olympics, World Cup and Superbowl etc. could lead to an increase in trafficking due to the need for short-term labour and increased demand for sexual services. The CIBS report on the London Olympics gives an excellent insight into the issues and suggested approach.
Develop and include in policy and governance procedures. Corporate governance should include a human rights policy which is an essential part of any CSR matrix. This will ensure that there is responsible reporting and management of the risks as part of the corporate governance structure. Ensure your human rights policy, hiring policy, supplier code of conduct etc. state your zero-tolerance stance on human trafficking. Best practice is to include the definition of trafficking as laid out in the Palermo Protocol (above) in your policy statement and to reference support of the Guiding Principles outlined in the UN's ―Protect, Respect and Remedy‖ Framework for Business and Human Rights.
Remember, human trafficking is not just about child or sexual exploitation. Ensure that policies and codes governing relations with suppliers of staff, goods and services also define the same stance on human trafficking. Marriott's comprehensive policy documents make excellent reference points for 'model documents'.
Make a statement which reinforces your commitment to human rights and to reduce the risk of trafficking in your business. The ITP Position Statement is a good reference which may be adapted to the individual business.
There are several codes of conduct developed by organisations working in this area. These can be helpful tools for business to help shape policy and activities going forward and to publicly demonstrate a commitment to addressing trafficking. But remember - addressing trafficking is about more than making a statement or signing a code. It needs to be an active programme engaging staff and integrated into core business.
Reporting under the UK Modern Slavery Act, 2015
The full text of the UK Modern Slavery Act 2015 is available here. The Transparency in Supply Chains clause (part 6) requires companies with a turnover of £36m who do business in the UK, regardless of where they are headquartered, to;
Companies are required to report on their global activity, not just their UK operations.
Companies are not required to report on franchisees, though stakeholder strongly recommend that working with franchisees on this issue and report on activity is best practice. There is equal risk to the brand if human trafficking is found in the business or supply chain in owned, managed or franchised properties.
The CBIS Olympic report Corporate Strategies to Address Human Trafficking is helpful here as a clearly detailed example of what investors want to know.
Engage staff. Awareness raising through good training needs to be a key part of your strategy. Given the sensitive nature of the issue of human trafficking and the misconceptions there may be around it, it is recommended to seek advice and expert input before training staff and to ensure the trainer is confident with the subject. Different staff will need different information. For example, security staff will be dealing with different situations to housekeepers, human resources and senior management. Several online training resources on human trafficking are available (see resources section below). Ensure training covers both sexual exploitation and forced labour.
Once awareness is raised, staff are likely to be concerned and will want to know what to do with this knowledge. It is essential that you work out strategies for handling suspected cases of trafficking and your training covers this.
Note that many situations may not be as they seem - how do you know that the child is not a relative of the guest? Challenging a guest directly or calling the police could have very serious consequences. The best approach is usually to cascade issues up to senior management where a decision may be made.
Join local and global networks. In some countries there are groups which share knowledge, information and best practice on trafficking, as well as forming solid networks to work actively against trafficking.
These may have trafficking as their main focus such as the Global Business Coalition Against Human Trafficking, be national awareness campaigns such as the Blue Campaign in the US or address trafficking as part of a broader scheme of work, such as the Institute of Hotel Security Management in the UK, specifically for security staff. As many include government, civil society, law enforcement and business, they can be excellent forums for keeping up to date with the issues.
Report on your activities. Whilst this may take time, it may be worth it in the long run as it provides the information stakeholders, such as investor groups and interest groups need without them having to come and ask for it. It can be useful to track progress and furthermore, reporting can help build profile and brand by demonstrating publicly your commitment to act on human trafficking. According to CBIS, companies should report on;
For more information on best practice for reporting, the CBIS Olympic report gives direction on what investors need. For further guidance on developing a statement and policy framework, see the Athens Ethical Guidelines and the Luxor Protocol suggests to business how to apply the Athens Principles.
The following training presentations and tools are available online and are useful starting points to develop your own training. As human trafficking is a very sensitive and difficult issue, it is preferable to deliver training face to face in order to address concerns and avoid any misunderstandings.
UN GIFT training Comprehensive and authoritative training in three modules: What is human trafficking? Why is human trafficking an issue for business? What can business do to address human trafficking? This is available as an e-learning tool.
Every Child, Everywhere - Child Protection Training in the Travel Industry from ECPAT and the Association of British Travel Agents (ABTA). This interactive, simple to use course consists of 3 modules: Following Child Protection Policies & Procedures, Implementing Child Protection Policies & Procedure and Developing Child Protection Policy and Procedures.
Specific information and resources relating to child sexual exploitation
Child exploitation is probably the most disturbing aspects of human trafficking. Hotels and tourism are not causing child exploitation, but hotels can be used by criminals to carry out their crimes. This is a compelling argument to raise awareness with staff and reduce the risk of this happening in your property.
There are several organisations dedicated specifically to eradicating child exploitation and many with a specific focus on the tourism and hotel industry. The leading organisation in this field is ECPAT - a global network of organisations and individuals working together to eliminate child prostitution, child pornography and the trafficking of children for sexual purposes. ECPAT can in many cases provide training for staff on this sensitive issue. This 2016 report is a thorough overview of sexual exploitation of children in the travel industry with country reports and expert papers for Carlson and Accorhotels.
The Code - an industry driven responsible tourism initiative in collaboration with ECPAT International, funded by UNICEF and supported by the UNWTO - is a helpful code of conduct indicating steps a business should take for the protection of children from sexual exploitation in travel and tourism.
Specific information and resources relating to labour issues
When developing policies and procedures for human resources relating to human trafficking, the SEE Formula from the Staff Wanted initiative is a great place to start. Developed by the institute for Human Rights and Business and Anti Slavery International, SEE provides clear and simple guidance on the steps needed to combat the exploitation of vulnerable workers, trafficking and forced labour.
It is important to check out recruitment agencies before contracting them to provide staff. What checks do they have in place to ensure workers are not being exploited? Check for yourself. Are contracts fair and transparent?
For more detail Verité a US based NGO - hosts a wealth of resources on the Resources for Responsible Recruitment website. This includes sections on auditing the labour supply chain, indicators of human trafficking in the labour supply, strengthening vendor codes of conduct, taking remedial action and multi-stakeholder approaches
The International Labour Organization (ILO) website also holds a wealth of information on forced labour issues. This specialised agency of the United Nations works to promote rights at work, encourage decent employment opportunities, enhance social protection and strengthen dialogue on work-related issues.
For further information on agency staff issues, see the International Confederation of Private Employment Agencies (Ciett) which works to promote the interests of the temporary agency work sector through promoting standards within the staffing industry.
What the hospitality industry is currently doing? Best practice and case studies
There are many examples of businesses - collectively and individually - taking action to tackle trafficking. Here are just a few of them;
International Tourism Partnership (ITP) has a working group dedicated to human trafficking. Through the group, members have been able to discuss the issues and share resources, such as training materials and policy statements, and best practice. ITP has a secure shared platform where members can access key documents and resources. Together the group developed a Position Statement which has helped direct and under- pin members' human trafficking work. ITPs strong net work of contacts in the field ensure members are kept up to date with news and developments relating to trafficking and forced labour.
The hotel group Carlson is a founder member of the Global Business Coalition Against Human Trafficking. GBCAT is a global coalition of corporations committed to eradicating trafficking in supply chains, including forced labour and all sex trafficking, notably child prostitution. GBCAT is a thought leaders' forum to develop and share best practices for addressing the vulnerability of businesses to human trafficking in their operations.
Sharing knowledge and support across industries is hugely important in the fight to eradicate trafficking in supply chains and it is great to see the hotel industry taking the lead.
The Youth Career Initiative (YCI) is leading a pioneering project to integrate the victims of trafficking into its 6 month education programme for vulnerable young people. Since 2010, and thanks to the support of the U.S.
Department of State's Office to Monitor and Combat Trafficking in Persons, YCI started incorporating rehabilitated survivors of human trafficking as part of the target group in selected locations. In Mexico City and Hanoi, 18 young people who came from shelters looking after rescued survivors of trafficking, successfully completed the programme and have started developing careers in hospitality, as well as other business sectors such as retail. This amounts to 20% of the total number of graduates in those markets. By 2015, YCI hopes to expand the work with trafficking survivors to cover four new locations. See Spotlight on Marriott (below) for more information.
ITP and the Staff Wanted Initiative produced this poster to be displayed in hotel staff rooms. It asks 5 simple questions in 10 languages that helps workers understand their rights and points towards resources to help if these rights are at risk. Download here. The Polaris Project has also developed a flyer for hotels to educate employees of the red flags to look out for.
The Institute of Hotel Security Management in the UK is a professional association for security staff. It meets regularly to discuss issues related to hotel security, including trafficking, and has a secure alert system for members.
The global travel technology company Sabre launched its Passport to Freedom initiative in 2012 in order to raise awareness in the global travel industry about human trafficking, advocate for legislation change, and provide opportunities for leaders to collaborate. Sabre is training its employees and encouraging them to share the message and create awareness amongst their customers and suppliers, such as travel agencies, hoteliers, airlines, cruise lines. Sabre hopes to widen the scope of its activities over the coming years.
Whitbread, who own Premier Inn hotels in the UK, have embedded the human trafficking issue in their CR programme: CR Programme Manager Mark Parker comments, 'Trafficking is relatively rare within Whitbread our Team and Community Pillar within our CR Programme 'Good Together' is actively working to ensure that human trafficking does not take place any where within our business. Whitbread commits to operating within the law of the countries we operate in, and ask all of our suppliers to comply with our Responsible Sourcing Policy which provides details of human rights standards.'
Spotlight on Marriott
Marriott International first established its Working Group on human rights back in 2006. Having been approached by various external organisations on the subject of human trafficking, Marriott drew in internal and external experts to inform them on the issues. It soon became clear to them that though the global hotel and tourism industry was not the cause of exploitation, it could be used by criminals to exploit people. As such, it was incumbent on the business to take action. Since then, Marriott has incorporated clauses on human trafficking rights into its Principles of Responsible Business which encompass supply chain, environment, employment and human rights issues. A key factor in this was having buy-in and support at chief executive level to integrate human rights more fully into the business.
Marriott leadership realize it is not just about policies. As Barbara Powell, former Senior Director, International Social Responsibility for Marriott, states; setting policy is the easy part; the difficult part is making it work.‖ Despite the real challenge of raising awareness on a global scale, Marriott has delivered tailored training to its associates and security officers globally. In addition, this training was shared with, and now forms the basis of, the American Hotel & Lodging Association human rights training. The company has also spoken about human rights at a variety of events and is an active member of ITP's Human Trafficking Working Group.
Central to Marriott's strategic approach to human trafficking is the support of the Youth Career Initiative (YCI) programme - a 24 week education and training programme for vulnerable young people in 12 countries. ―YCI helps us address the root cause of human trafficking and give young and potentially vulnerable people legitimate employment opportunities‖ says Barbara. ―We can provide a very tangible solution and get young people into employment, which is directly relevant to our business. This has real traction in helping reduce trafficking, and provides opportunities to rehabilitated victims of trafficking. Marriott International supports YCI by providing hands on training as well as in-kind support to students in the programme.
Marriott properties in nine countries currently participate in the programme. Additionally, the J. Willard & Alice S. Marriott Foundation, a private family foundation, has committed $1,000,000 in grant funding (over 10 years) to support YCI's general operating expenses as well as its strategic vision to grow in countries where it currently operates and to expand into new countries.
Spotlight on Hilton properties in Hanoi
We asked Peter Simson, Cluster General Manager of Hilton Hanoi Opera and Hilton Garden Inn Hanoi, why did you choose to get involved in the YCI programme to support the victims of trafficking?
YCI in terms of act and deed really touches our core Hilton values and crystallized some of the activities that we were already engaged in. At the Hilton Hanoi Opera, we believe in supporting personal and professional growth opportunities. We are strongly committed to helping the communities in which we live and will continue to work to facilitate job creation and economic development and engagement for those that are less fortunate through the thoughtful extension of our time, talent, and assets to help address and support community needs.
Hilton Hanoi Opera's support of the YCI program is also a firm commitment toward Hilton Hotels & Resorts' global community relations program, Bright Blue Futures.
Through Bright Blue Futures, Hilton Hotels & Resorts properties around the world provide hope and stability to young people in communities where we live and work, by engaging, educating and preparing them for careers in hospitality.
Bright Blue Futures supports Travel with Purpose, Hilton Worldwide's commitment to provide shared value to its business and communities around the world. As the driving strategy for Hilton Worldwide's corporate responsibility efforts, Travel with Purpose is built on four areas of focus - creating opportunities for individuals to reach their full potential; strengthening local communities where we live, work and travel; celebrating cultures and the power of travel; and living sustainably through the measurement, analysis and improvement of the use of natural resources.
Resources and further reading on human trafficking
US Department of State - Trafficking In Persons 2016 (TIP) - Report includes links to individual country assessments. This 2015 report by US Department of State and Verité gives a good overview of human trafficking risks in the sector (p.104).
UN.GIFT (the United Nations Global Initiative to Fight Human Trafficking) - UN.GIFT is a multi-stakeholder initiative providing global access to expertise, knowledge and innovative partnerships to combat human trafficking.
There are numerous inter-governmental agencies that are major agencies in trafficking; IOM, UNODC, OSCE, ICMPD and they all have trafficking training manuals and designated, respected staff who are universally recognised.
Verité - Verité is a US-based NGO whose mission is to ensure that people worldwide work under safe, fair, legal conditions. The website hosts a wealth of resources, including the Help Wanted toolkit - a more detailed resource to the Staff Wanted SEE Formula. It includes sections on auditing the labour supply chain, indicators of human trafficking in the labour supply, strengthening vendor codes of conduct, taking remedial action and multi-stakeholder approaches.
International Labour Organization (ILO) - Founded in 1919 and part of the United Nations, the ILO works to promote rights at work, encourage decent employment opportunities, enhance social protection and strengthen, dialogue on work-related issues. The ILO Combating Forced Labour 2008 report provides particularly interesting and relevant content.
Anti Slavery International - Founded in 1839, Anti-Slavery International is the world's oldest international human rights organisation. It works at local, national and international levels to eliminate all forms of slavery around the world by supporting research, raising awareness of slavery governments and intergovernmental agencies to make slavery a priority issue and to develop and implement plans to eliminate slavery.
Polaris Project - Founded in 2002, the Polaris Project is one of the largest anti-trafficking organisations in the US and Japan, running programmes at international, national and local levels. Actions include direct outreach and victim identification, the provision of housing and social services to victims, operation of the National Human Trafficking Resource Center (which serves as the central national hotline on human trafficking), advocacy for stronger anti-trafficking legislation, and community engagement.
Stop the Traffik - STC works in two ways 1) raising awareness of human trafficking and how to deal with it and 2) promoting tools for businesses to implement anti-trafficking legislation / best practice. Includes a section on Business Travellers against Trafficking.
End Human Trafficking Now - Works to engage the private sector / business community in awareness-raising and activities to counter human trafficking.
ECPAT - Global organisation active in research, campaigning and lobbying government to prevent child exploitation and protect children in tourism and child victims of trafficking.
The Code - This Code of Conduct for the Protection of Children from Sexual Exploitation in travel and tourism is an industry driven responsible tourism initiative in collaboration with ECPAT International, funded by UNICEF and supported by the UNWTO.
Global Business Coalition Against Human Trafficking - GBCAT is a global coalition of corporations committed to eradicating trafficking in supply chains, including forced labour and all sex trafficking, notably child prostitution. gBCAT is a thought leaders' forum to develop and share best practices for addressing the vulnerability of businesses to human trafficking in their operations.
The University of Liverpool Heseltine Institute has developed two resources on 'Tackling Exploitation and Forced Labour in the UK Hotel Sector' and a 'UK Hotels Policy Guide: How to protect your business against human trafficking, forced labour and labour exploitation.'
KnowTheChain is a neat website with resources for businesses and investors to understand and address forced labour abuses within their supply chains.
COMBAT Human Trafficking project has developed a toolkit for training corporate, managerial and unit levels of hotel firms.
UK Home Office Modern Slavery: A Briefing for the Hospitality industry.
IHRB have a website dedicated to Mega Sporting Events, and the risks involved. Hotels can support the It's a Penalty campaign to help raise awareness of the issue of human trafficking during mega sporting events.
tions for their help in producing this Know-How Guide: Christian Brothers Investment Services, Inc., Hilton Hanoi Opera | Hilton Garden Inn Ha noi, Institute for Human Rights and Business, Maplecroft, Marriott International, Rankin Associates, The Recruitment and Employment Con federation, Verité.