The hotel’s commitment to tackle modern slavery should be integrated throughout its policies, practices and decision-making procedures. By incorporating the position statement on modern slavery into each hotel’s vision, mission, value statement and goals, the commitment will be fed down into every policy, hotel and department.
Further detail is provided below on specific policies and practices for each of the four key risk areas. Individual hotels can incorporate these into their internal policies and practices. Hotels should do this in a way that best integrates with their existing processes but adheres to the overall aim of the Blueprint.
- 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 implementation of a hotel use policy is to:
- Share the policy internally with all staff and include it as required reading, either at the beginning of their employment or when the policy is being implemented.
- Ensure that a copy of the policy is accessible to staff on a daily basis, for example in the staff room, in particular to the Sales and Front of House teams, and to those who service guest bedrooms.
- Incorporate the full policy into the hotel’s internal policies and documents, as appropriate, including any policies on sales, check-in/check-out and guest assistance.
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:
- 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, gender reassignment, 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 bonded labour and supporting freedom of association and the right to communicate their voice as an employee.
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.
Recommended implementation of commitments on employment and human rights is to:
- Incorporate the best practice commitments into the hotel’s internal policies and documents, as appropriate, including the staff handbook, HR manual, job descriptions, application packs, and welcome packs.
- Draw employees’ attention to any changes made in policies and documents as a result of their incorporation and ensure such commitments are included as required reading, either at the beginning of staff employment or when the policies are being implemented.
- Ensure that a copy of the relevant policy containing these commitments is accessible to staff on a daily basis, for example in the staff room, in particular to the human resources and recruitment teams.
- Ensure that any indirect and direct employment is carried out in line with the relevant policy containing these commitments.
Reminder: Due to the complex nature of global supply chains, it would be impossible at this stage to monitor or control the working conditions of each and every individual who contributes to supplying a hotel. It is important to do what is possible to bring responsible sourcing practices to all stages of the supply and value chain.
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.
Tip: A company can set out the internal criteria to consider when working with a supplier and determining when it is appropriate to terminate this relationship.
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:
- Share the code of conduct internally with staff members who deal with procurement at any level and include it as required reading, either at the beginning of staff employment or when the code of conduct is being implemented.
- Ensure that a copy of the code of conduct is accessible to relevant staff on a daily basis.
- Follow an approved action plan on how to approach suppliers regarding the code of conduct.
- Provide a copy of the code of conduct to each individual supplier that enters into a contract with the hotel.
- Require each individual supplier that enters into a contract with the hotel to read, acknowledge and/or sign a copy of the code of conduct.
- Carry out a yearly review of the code of conduct with each supplier to ensure the continuous improvement plan is underway and that all relevant documents remain in date.
Recommended implementation of head office guidance is to:
- Share the guidance and the principles of this Blueprint internally with all employees at the executive level;
- Ensure that a copy of the guidance is accessible to employees at the head office on a daily basis;
- Incorporate the principles of the Blueprint in the broader business objectives;
- Follow the guidance and adhere to principles of implementation contained within any other policy on modern slavery.
- Share the guidance and the principles of the Blueprint with any existing or potential business partners;
Reminder: No one can guarantee that all hotel operations are completely free of modern slavery. However they can promote best practice and put processes in place to adhere to it. Likewise, it can’t be guaranteed that all of the practices of subcontractors are modern slavery free, but they can be required to adhere to the principles laid out in the Blueprint.
See relevant templates:Example Head Office Guidance on Modern Slavery