It is estimated that anywhere from 20 to 40 million people are trapped in modern slavery worldwide. The fragmented, transient and relatively anonymous nature of hotels has made them critical sites for the trafficking of humans — typically for forced labor or sexual exploitation. But the hospitality industry has taken steps to combat human trafficking. Marriott International (No. 2 on DiversityInc 2019 Top 50 Companies for Diversity) and Hilton (No. 4) are two of the largest hotel chains worldwide. Both have made a series of moves to identify and fight modern slavery from their supply chains to their locations.
In 2015, Hilton conducted a global human rights assessment and identified human trafficking as one of the most pressing issues that affects its value chain.
The crisis of human trafficking applies to many areas of the hotel industry. There’s the potential for forced labor in construction and various elements of the value chain, including goods the hotels use and offer guests. There is also the potential for traffickers to move victims through hotels or operate out of them in cases of sexual exploitation. Hilton identified these areas — the supply chain, goods and operations — as the three levels of its business human trafficking affects.
Caroline Meledo, Hilton’s director for corporate responsibility and human rights, told DiversityInc that Hilton’s code of conduct clearly calls out the risks and condemns human trafficking.
“It’s very important to us that it is in our code of conduct because it means that it is elevated at the same level as anticorruption or business ethics or diversity and inclusion. So, this is really part of the cornerstone of our company,” she said.
However, a policy only has power in practice. Hilton and Marriott’s ethics codes both condemn the use of their products or locations in the exploitation of humans, but it is the training both companies have implemented that has made tangible change.
In 2016, Marriott partnered with anti-sex trafficking organizations Polaris and ECPAT-USA to develop a training that educates workers on recognizing the signs of human trafficking and how to respond. In 2017, Marriott made that training mandatory in both its managed and franchised properties, across its 30 brands. Marriott spokesperson Barbara Delollis told DiversityInc that as of 2020, more than 700,000 hotel workers have been trained using this resource. To ensure that the training is accessible to workers around the world, it has been translated from English into 16 other languages.
It also breaks down what signs may appear to workers in various positions. For example, a front desk clerk may notice a customer with someone who has no luggage. A housekeeper my notice a “Do not disturb” sign hanging constantly on that patron’s door. Usually, no one sign alone can automatically point to trafficking. This training teaches employees to look at situations holistically and cross-reference the information about suspicious activity they observe among different teams.
Experts like anti-child sex trafficking organization ECPAT-USA say signs of human trafficking in hotels can include a number of red flags. In the case of children being trafficked, a child may be with an adult that does not look like their parent or guardian. A trafficking victim of any age may be dressed inappropriately for the weather, have no luggage with them or appear malnourished, afraid or disheveled. A patron may pay for a room in cash, request a room by an exit, not allow housekeeping into their room, or frequently request new sheets and towels. Hotel employees may notice heavy foot traffic of people entering and leaving the room.
The way companies have addressed these issues is not without its controversies. When Marriott announced its training to combat sex trafficking, advocates for protecting those engaged in consensual sex work criticized it, saying the training could lead to profiling and targeting of willful sex workers, transgender women, people of color, immigrants and others.
A customer paying in cash or wearing a short skirt in the middle of winter are not in and of themselves telltale signs of trafficking. Hotels must balance caution with the privacy and freedom of their guests.
“There are just a range of things that we work with staff to look for, and we make it clear that trafficking happens among all race, religion, gender, sexual identity, skin color, socio-economic group. We work really closely with teams to make sure there is no profiling going on,” Lori Cohen, executive director of ECPAT-USA told DiversityInc.
ECPAT-USA also helped Hilton develop and roll out a similar training, which is also mandatory for key team members to take annually.
“Whether you are the concierge, whether you’re the housekeeper, whether you’re a security team member or in the food and beverage outlet in our hotel … all of our team members are trained to identify the signs and to report them to the managers,” Meledo said. “The managers and ultimately the hotel leadership would then review the situation and all the signs and decide what next step to take. What’s important to note is that a single sign does not necessarily mean human trafficking.”
ECPAT-USA works to end child sexual exploitation through legislation, education and partnerships with private sector companies. The third area is where its work with hotels like Hilton and Marriott comes in.
“We’re looking to the private sector and saying, government has a role, schools have a role, families have a role, but really private industry has the opportunity to make a huge difference in ensuring the safety of children,” Cohen said.
Marriott was ECPAT-USA’s first private sector partner.
ECPAT-USA has a Tourism Child-Protection Code of Conduct — a list of six business principles companies must endorse to be regarded as signatories of the Code. Marriott signed the Code in 2018, and Hilton became a signatory in 2011.
The tenets include
- Establish a policy and procedures against sexual exploitation of children.
- Train employees in children’s rights, the prevention of sexual exploitation and how to report suspected cases.
- Include a clause in contracts throughout the value chain stating a common repudiation and zero tolerance policy of sexual exploitation of children.
- Provide information to travelers on children’s rights, the prevention of sexual exploitation of children and how to report suspected cases.
- Support, collaborate and engage stakeholders in the prevention of sexual exploitation of children.
- Report annually on their implementation of Code related activities.
There have been several instances where hotel employees’ training has paid off and traffickers have been caught. In 2018, Marriott CEO Arne Sorenson wrote an op-ed in USA Today about a March 2017 instance in New Orleans. A hotel employee noticed a 12-year-old boy with two men who were buying snacks. An associate heard one man say to the other, “I may take this one home.” Based on her training, the employee alerted her supervisor who called the police.
The associate’s suspicion ended up being justified. The boy had been missing for three days. This case ended with the child being rescued.
“The training is working. The story from New Orleans ends the way it does because our associate knew what to do,” Sorenson wrote.
Supply Chain and Goods
The International Tourism Partnership (ITP) is a platform with which hotel companies collaborate and share information on advancing the hospitality industry toward human rights and environmental goals. ITP works with hotels to mitigate the risk of forced labor in hotels’ supply chains and offers resources for hotels on ethical recruitment policies.
“We know that the issue is a very, very complex one, so we look at partnering and partnering across the value chain and with other stakeholders from other industries,” Madhu Rajesh, executive director of ITP, told DiversityInc.
Forced labor is a pressing problem for hotels. Because many hotels operate franchises — which means the company operates out of the facility but does not own the building — it can be difficult to control where property owners source construction labor.
Meledo said Hilton completes a human rights risk assessment for every country it enters and comes up with mitigation plans for hotel owners to follow. These plans can require hotel owners and contractors to complete certain human rights training. The company works toward mitigating the risk at this stage of the supply chain by requiring that the owner of the property it operates within takes steps to prevent forced labor. Although a property owner is essentially a hotel brand’s client, Meledo said Hilton still leverages its power as a brand to make sure property owners adhere to the standards of the company.
Hilton also developed a “Risk of Modern Slavery in Labour Sourcing” training that it donated to ITP in 2019 so that companies can access it for free. The training covers issues of awareness and response and follows the guidelines of ITP’s Principles on Forced Labour launched in 2018.
These principles include that no worker should have to pay to be employed, no worker should be denied freedom of movement and no worker should be indebted or forced to work. Rajesh said embedding human rights into hotels’ corporate governance is one of ITP’s goals.
When it comes to other products — like textiles — hotels use, Meledo said Hilton also audits the companies that supply it.
Complexities and Controversies
The goal of anti-trafficking policies and training is to protect victims and stop perpetrators, but because trafficking is such a fraught issue, addressing it can be equally difficult.
“In this space, you never get it fully right,” Meledo said. “You’re never done. So, it’s very much continuous improvement and a work in progress but we’re at least really embracing that that aspect and trying to do our best.”
Because the sex trade also includes people who are involved in it willfully, the issue of decriminalizing willful sex work has been on many legislative dockets — and picket signs — recently. The issue of whether or not decriminalizing prostitution would help curb sex trafficking is deeply divisive.
Also deeply divisive is the issue of immigration, considering in some cases, those being trafficked for sex or labor may be undocumented. In 2019, Hilton faced backlash after a location in New York displayed Department of Homeland Security Blue Campaign business cards that encouraged guests to report suspected human trafficking to the Immigration Customs Enforcement (ICE).
The Pacific Standard reported on the issue saying these cards were being displayed in Hiltons across the country, however, Meledo said only the one New York location had the cards — which Hilton did not approve.
“There is the one and only number that we ever, ever share, which is the National Human Trafficking Hotline number,” Meledo said. “Now, we cannot control whether our franchise hotels may be using other materials that is not Hilton-approved or Hilton-branded … We have never and never will showcase the ICE number.”
Ultimately, hotel companies are not legislators or community advocates, but their power affords them responsibility to address the issue of human trafficking. The affect they have on jobs and economies also puts them in a position to hire vulnerable individuals. ITP is piloting a program in India and Vietnam to train survivors of trafficking to work in the hospitality industry.
“That will be a model for the industry to take positive action and to provide opportunities so that people don’t fall back into the trap,” Rajesh said.
Meledo said Hilton also works to invest in the communities it operates in from a grassroots perspective, through partnering with local organizations that educate and organize against human trafficking.
“That’s why a lot of the work we do as well, we also invest in the residents of the communities where we operate to try and reduce the vulnerability of the individuals who may be falling prey to traffickers,” she said.