Identifying Risk
As outlined in more detail across different sections in this Blueprint, hotels can adopt various control measures as part of their initiative to identify and mitigate risk in the short term:

Relationships: Where possible, build and maintain longstanding relationships with local and trusted suppliers, making clear our expectations of business behaviour.

Employment: Where possible, recruit, vet and employ employees directly, following clear company policies and guidelines.

Compliance: Ensure compliance with current legislation and guidelines by embedding both into the day to day of the hotel’s work. This includes relevant human resources provisions in law such as Working Time Regulations, and the National Minimum Wage.

Knowledge: Improve knowledge base by collecting relevant data and improving transparency within the business and down the supply chain.

Feedback: Promote a company culture whereby the reporting of concerns and the protection of informants is encouraged.

Third Party Engagement: Build strategic alliances with independent unions, social advisors and NGOs.

Measurable Change: Develop verifiable KPIs to measure progress.


To carry out a more detailed analysis of risk in the supply chain, four steps have been outlined below.

A more detailed approach for working with suppliers can be found in the Framework for Working with Suppliers: Mitigating Risk of Modern Slavery produced by the Stop Slavery Hotel Industry Network.

Identify the organisations within your supply chain, for the supply of people, services and products, across each department. Depending on the size and complexity of the supply chain there may be a number of levels to reach a primary provider. All levels that practicably can be, should be identified in the analysis, including any agents used by a labour provider to source labour in the UK or abroad.

Hotels should work with their direct suppliers in order to ensure they are taking the same steps to track and manage ethical trade risks within their own supply base. A risk-based approach should be adopted throughout. A summary spreadsheet should be kept of all organisations identified within this initial analysis of the supply chain and can be used to track risk and record progress. The spreadsheet may contain information such as:

  • Company name
  • Address/contact details
  • Key contacts
  • Product/nature of service supplied/sector
  • Position in supply chain

  • Location
  • Dates of current contract
  • Previous relationship
  • Acknowledgement of Supplier Code of Conduct
  • Ethical trade competence

  • Relevant required licences
  • What processes are in place preventing illegal working
  • What health and safety processes are in place
  • Audit dates
  • Improvement Action Plan

This information should be used to assess the potential risk of each supplier in the supply chain based on the nature of their business and the processes they have in place in order to identify and focus on those who represent the greatest risk.
Modern slavery risk for any supply chain can be analysed according to various criteria, such as country, commodity and characteristics of the industry. Outlined below are some ways in which you may start to assess risk with regards to your first tier suppliers. The below information was obtained through the analysis and input of STOP THE TRAFFIK. There are external consultants who can help you with this piece of work should it be required.

  • Contexts such as armed conflict, a weak rule of law, high incidence of corruption, and insufficient safeguarding of human rights and labour standards by the government may all increase the likelihood of workers being exploited in a particular country or region, and therefore increase the risk of exploitation being involved in the production of a particular product which passes through that region or country.
  • Some commodities or commodity derivatives are known to be more or less likely to have been produced using forced labour. This can be closely linked to country risk, but the vulnerability of a specific worker demographic can also be a factor in whether or not products are likely to have been produced using exploitation.
  • The following products and services, which are commonly used within the hotel industry, are considered to have higher risk.

An open discussion should take place with each supplier in the supply chain to establish basic requirements and assess the competence of that business to manage its workforce legally and ethically. The Supplier Code of Conduct can be used as the basis to agree a standard with suppliers. The purpose is not to terminate all relationships when full compliance isn’t immediately met. Instead, having an open discussion about your principles and expectations with your suppliers is what best practice recommends. Allow time for suppliers to engage with your expectations and adapt their business practice accordingly.
Hotels are encouraged to implement appropriate management processes with each of their suppliers to monitor that the standards agreed are being complied with and to establish action plans to improve performance, where necessary. A continuous improvement approach is recommended to promote joint ownership of corrective action plans and the raising of standards. Formal review meetings can be held regularly between hotel and supplier to review progress.


Options for continuing the management process include:

  • Formal review meetings held regularly between hotel and supplier to review progress.

  • Regular compliance tracking of suppliers’ policies, processes and performance against the company’s supply chain expectations.

  • Spot-checks on staff working in your hotel to ensure that the agency employing these workers are acting as agreed in the standard.

  • Spot-checks by a third-party agency.

Auditing: Once due diligence is in place with a supplier, it is recommended that there are regular and ongoing audits that the agreed conditions are being met. See Sedex, which is a global not-for-profit organisation which houses the world’s largest collaborative platform sharing responsible sourcing data on supply chains. Sedex provides an Ethical Trading Audit (SMETA).

Identifying and assessing risk is an ongoing process.

See relevant templates:

Framework for Working with Suppliers

Browse The Blueprint

Public Commitment

Policies and Practices

Procedures and Protocols


Reporting, Monitoring and Evaluation