Having clear and straightforward protocols for when an incident is discovered is crucial to ensure that victims get appropriate support. Where employees identify a potential victim, they can follow a specific internal procedure in order to protect the safety of that individual.
Anti-Slavery Champions: A hotel should appoint someone who can take on the role of monitoring areas of risk (as set out in the Blueprint) on a regular basis in line with the guidelines provided and report anything unusual to the Anti-Slavery Committee (see below) as appropriate via incident reporting protocols and regular meetings. General Managers are recommended for this position. Anti-Slavery Champions should be encouraged to take a proactive approach, in consultation with head office, to take corrective actions in order to mitigate any risks or broader impacts.
Anti-Slavery Committee: A cross-functional group consisting of key representatives from head office should be set up to meet regularly (i.e. twice a year) in order to report any ongoing challenges, patterns or concerns. Representatives from a relevant NGO or service provider should be an integral part of this committee. The committee should review the hotel reports on a case by case basis and determine if there are actions that can be taken to prevent similar cases from occuring in the future. They should also review industry benchmarks to recommend changes and improvements. General Managers and/or Anti-Slavery Champions should feed into the Anti-Slavery Committee through regular internal meetings.
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.
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.
Investigation: Any investigation beyond the initial report should be performed by local police and victim service providers, with the full support of head office and the Anti-Slavery Champion, in order to protect the victim(s), employee(s), and the business. It is recommended that an investigation of a report made about staff be done in conjunction with the internal disciplinary procedure. For example, confidentiality should be maintained and the staff may be suspended while the report is being investigated.
TIP: It is important to establish links with the police and other key contacts that might be required before an incident takes place. Other contacts may include a professional interpreter service for translation and victim service providers.
Victim Services: If an investigation confirms probable incidents of slavery, Anti-Slavery Champions should work in cooperation with a local specialist victim service provider to ensure that the victim is protected and aware of all options for access to remedy (judicial and non-judicial). The hotel should work to ensure that victims of modern slavery can continue employment at the hotel where possible.
TIP: The police may not always be the first port of call for a variety of reasons. If the victim does not want the police to be called, there are confidential 24/7 options. It is recommended that the hotel establish a relationship with the reputable victim support provider in the area before an incident takes place. Advisable contacts for victim support in the UK are the Salvation Army (0300 303 8151) and the Modern Slavery Helpline (08000 121 700). It is important confidential numbers are made aware to staff in case they would like to make reports outside of the agreed reporting structure (i.e. if s/he is at risk or suspects a colleague is).
Root Cause Analysis: A root cause analysis for the incident can help determine why the incident involved the business, a supplier or employees. If applicable, and depending upon the severity of the incident, written warning notice or notice of termination may be given to the employee, supplier, contractor, or subcontractor that has violated the policy. If applicable, aim to make improvements that will prevent future incidents. The Anti-Slavery Committee should consider these cases and determine the best approach going forward. Where an incident is reported by a supplier, hotels are encouraged to have a plan in place to address the root cause within a certain timeframe. The plan may include having a meeting with the relevant supplier making clear what steps should be taken to rectify any outstanding concerns. See example Principles of Implementation which can accompany a Supplier Code of Conduct and set out provisions for reporting incidents.
PLEASE NOTE: The General Manager and/or Anti-Slavery Champion can monitor the progress of reports made and follow up where needed. However, it is not uncommon for a hotel to find out no further information about a report once it has been reported to the police.
Recommended implementation of reporting protocols is to:
- Share the details of the protocols internally with all staff and include it as required reading, either at the beginning of their employment or when the protocols are being implemented.
- Ensure that a copy of these protocols is accessible to staff on a daily basis, for example on the staff room notice boards.
- Incorporate the protocols into the hotel’s existing procedures and documents (such as crisis management policies, emergency policies, health and safety policies, job descriptions, staff handbook) as appropriate.