YOUR BUSINESS COULD BE AFFECTED

 

Human trafficking is one of the fastest growing crimes in the world. Awareness is growing that legitimate businesses can be unknowingly affected by this crime,
as criminals place their victims to work within these businesses without the company’s knowledge. 

THE MODERN SLAVERY ACT

 

The Modern Slavery Act 2015 requires that large companies publish details of the actions they are taking to ensure that slavery cannot occur within their businesses or supply chains.

HOTELS ARE AT HIGH RISK

 

Unfortunately, hotels are highly exposed to the risk of child sexual exploitation (CSE) and other forms of human trafficking occurring within their business; through the risk of the misuse of the hotel premises to conduct exploitation or through exploited workers being placed to work within the hotel by their trafficker, sometimes via recruitment agencies.

THE NEED FOR A SOLUTION

Many hotels are very keen to find workable solutions to these problems. 
As responsible companies, they wish to entirely prevent traffickers being able to
mis-use their premises to conduct exploitation. The hotel sector has a culture of respect for customers’ privacy and deference to their needs.  Staff within this sector often need additional training to look out for exploitation and know how to address
a potential trafficking situation if it were to arise within their hotel.

POTENTIAL FOR LITIGATION AND REPUTATIONAL DAMAGE

 

As well as the need to comply with the requirements of the Modern Slavery Act, hotel businesses are keen to the avoid potential litigation and reputational damage that could occur if an incidence of trafficking arose within the business, especially if the hotel were found to have been negligent.   

 

 Large hotels, day/hourly use of rooms, use of automated check in/check out
and high staff turnover make it more difficult for businesses to ensure that trafficking cannot occur.

MSA STATEMENT REQUIREMENTS

All large companies directly affected by the Modern Slavery Act (over £36 million in turnover) have the responsibility to report on the actions they are taking to prevent trafficking within their business and supply chains. Many of these businesses use hotels for staff business travel and will be considering how modern slavery affects hotels. International companies and large corporations are often important customers for hotel businesses and being on their preferred supplier lists can make a big difference to a hotel's business. It is expected that large companies will begin to require evidence of the actions hotels are taking to reduce the risk of trafficking within their businesses.     

 

Many hotel chains also have their own Modern Slavery Act statements to complete, being large companies themselves. 

 
PARTNERSHIP APPROACH

 

Safe and Free will work in partnership with you to ensure your hotel cannot be mis-used by traffickers. We’ve used our extensive experience in the investigation of cases and helping victims of trafficking to develop highly effective counter-measures that hotels can put in place to prevent trafficking.

IDENTIFY KEY RISK AREAS

We will work with you to identify the greatest risks to your business and create realistic plans and timescales for countering these risks. We will help you to effectively communicate your plans to your employees and gain their buy-in. 

SELECT THE RIGHT PRODUCTS FOR YOUR BUSINESS

Safe and Free can offer products designed to help you combat trafficking risks and will ensure their effective delivery and roll-out throughout your business to tackle these risks. We will work with you to ensure minimal business disruption and ensure our services are tailored to your business’ needs. We can also assist with monitoring the effectiveness of your anti-trafficking efforts, as well as providing support for key staff.

 

Safe and Free work hard to match our work very closely to your practical needs, thus ensuring you get the level of service and the products that will work well for your particular business.

EVIDENCE OF PROGRESS

After identifying the greatest risks to your business and the best ways for you to mitigate them, we will work with you to create realistic, staged targets along with providing Modern Slavery Act statement consultancy.

 

As we work with you we will provide regular management reports detailing the evidence of progress.  Safe and Free will also help you to consider longer term plans for the migitation of trafficking through redesign of systems and processes if needed.

 

In this way you, your investors and customers can have full confidence that the actions you’re taking are effective in reducing the business risk you face from trafficking.  

 
HOW SHOULD I CHOOSE A SERVICE?

Safe and Free is the only anti-trafficking service to provide practical, comprehensive support to hotel businesses to protect them from all trafficking threats.

Do you want to be confident that a victim of trafficking could not be exploited
in your hotel?

Safe and Free can help you.  

EXPERIENCED IN THE RESCUE AND SUPPORT OF VICTIMS

Safe and Free is uniquely placed to partner with hotel businesses against trafficking. 


Safe and Free's experience of rescuing victims of trafficking means we know how best to help and support victims, and we know the ways traffickers operate. We have designed our support for hotels to practically tackle all the trafficking scenarios that a hotel might encounter. 

 

We have successfully worked with businesses helping them put into place systems to ensure that victims of trafficking cannot be exploited there.

 
SAFE AND FREE IS INDEPENDENT

This is important if you want to be able to prove to business customers, investors and the Home Office that the improvements you report in your systems for tackling and monitoring trafficking are genuine and reliable. Safe and Free can provide this external verification.

SAFE AND FREE IS EXPERIENCED IN DEALING
WITH TRAFFICKING

You can be sure that the risks of trafficking within the business will be properly identified and that, whatever situation were to arise within the hotel, Safe and Free would be able to support your staff to take the appropriate actions.

SAFE AND FREE'S SERVICE IS CONFIDENTIAL

If you are aware that there is a problem with, or vulnerability to, trafficking within your business, we can advise and work with you in confidence.

SAFE AND FREE IS EXPERIENCED IN DEALING WITH VICTIMS

It is important that victims of trafficking are correctly supported. Safe and Free would help ensure that your staff know the correct actions to take if a case of trafficking occurred within the hotel.

SAFE AND FREE HOTELS UNDERSTAND POLICE INVESTIGATION

We know the procedures and evidence requirements needed for convictions. We have experience of working with the Police and the Gangmasters Licensing Authority (GLA).  Safe and Free Hotels will help ensure that your team work appropriately with any investigating authority, so that their investigations are not compromised.  

SAFE AND FREE WILL PARTNER WITH YOU​

Every hotel business is different.  We want our work with you to be effective in reducing your business risk, which means working in partnership with you to understand your business and its particular needs. You will be able to closely follow the progress of the work without this taking up too much of your time.

 
IS THIS PRIMARILY A LEGAL PROBLEM?

You may be thinking of getting legal help to consider the implications of the Modern Slavery Act on your business. We would suggest considering these points:

  • Do I need a legal opinion on the risks to my business of trafficking or do I need practical risk minimisation strategies? 

  • Do I need to mitigate and minimise legal risks or do I want to know that we’ve taken effective pre-emptive action?

  • Do I need a lawyer to write my MSA statement or do I want to detail the real progress we’ve made in ensuring a vulnerable person couldn’t be exploited within our business?

Most hotels need to implement practical changes to properly protect themselves from the real risks to their business of human trafficking. You may find a legal opinion is helpful, but it will not be the comprehensive solution.   

 
DON'T MISS AN OPPORTUNITY​

It may be momentarily appealing to only publish a very basic statement in response to the Modern Slavery Act, after all, doing the minimum satisfies the requirements.  However, your company would then miss a key opportunity to lead on an important social issue and to prove that you are a responsible business. Choosing to do this could affect customer perception of your brand. Strategically, do you want to miss this opportunity to position your brand as a leader in social responsibility?

Furthermore, now is an excellent time to create the long term plan of how you are going to tackle slavery and the business risks it presents. This plan can be rolled-out strategically over several years, therefore publishing a good first statement need not be onerous or lead to an over-commitment of your resources.  

CORPORATE CUSTOMER REQUIREMENTS

Large companies, directly affected by the Modern Slavery Act, will be requiring their suppliers to report on the anti-slavery actions they’re taking, for inclusion within their own official responses to the legislation. Hotel businesses will want to provide satisfactory and credible reports to these important clients.

Other hotel businesses will soon begin publishing their own Modern Slavery Act statements (large hotel chains) or reports for inclusion within other businesses' Modern Slavery Act statements (smaller hotel businesses). Customers and investors will be interested to compare different companies' responses and progress, which may impact on their future buying decisions.

YOUR BRAND AND REPUTATION

The public are increasingly interested in the ethical stance taken by businesses.  Companies who mis-judge public expectations may lose market share. 

A basic Modern Slavery Act statement will not protect your brand. If the risk of trafficking in your hotel remains unmitigated, it means trafficking could occur. 
If a case of trafficking were to occur within your business, the cost to your reputation could be very much higher than the cost of creating and implementing an effective preventative strategy.  

 
 
YOU CHOOSE THE OUTCOME

What you decide to do now could determine the outcome for the victim if a trafficker tried to use your hotel as a location for exploitation. If your staff know how to spot trafficking and what to do when they have a suspicion, it could mean the difference between freedom and safety or continued exploitation for the victim of trafficking.  For the hotel business, staff taking the right actions can mean the difference between a PR disaster and a ‘good news story’ e.g. “Hotel Staff Praised for Help Given to Victim of Trafficking”.

BE THE DIFFERENCE

 

Your decision to work with Safe and Free increases the chance of your staff doing the right thing in the event of a trafficker attempting to use your hotel as a location for exploitation. By choosing the Safe and Free service and strategically working to prevent the potential mis-use of your business premises by a trafficker, you close-down opportunities for trafficking, thus protecting your staff, business, reputation and victims of trafficking.   

 

Her trafficker used hotels as exploitation locations

JODIE'S STORY

Safe and Free was able to help Jodie, a 17 year old who had been trafficked into the sex industry aged 14 years old. Jodie is now moving on with her life, although still affected by her terrible experience.

Jodie was trafficked by a woman who blackmailed her into forced prostitution. 
Jodie was driven to hotel locations over a 3 year period where she met with men who’d booked her through her trafficker, she would see numerous clients within the hotel room and had no choice regarding how she was treated. The trafficker would take all the money the men paid for sex with Jodie. The appointments and Jodie’s communication with her trafficker were by mobile phone, but there were many missed opportunities for hotel staff to spot that Jodie was being exploited.

  • She’d booked and paid for rooms despite being aged between 14 and 17. 

  • She attended the hotel wearing heavy make up, whilst (in Jodie’s own words) looking 14.

  • She was dressed suggestively.

  • She was regularly receiving phone calls when in reception and could be
    overheard by staff.

  • Hotel staff would have known from what they overheard that Jodie was being instructed by another person. There were also occasions when Jodie would put the trafficker on loudspeaker to speak directly to hotel staff. The trafficker would then speak aggressively to the hotel staff.

  • She met several men in reception who were much older than her.

  • She would request to pay for the hotel room in cash, but would not have enough cash to pay for the room until after her first visitor arrived.

  • Room service staff would have seen condoms and money in her room.

  • She would only leave the room in order to meet men in the reception area.

JODIE SAID,

“No-one ever asked me how old I was or if I was ok, the staff knew what I was doing and I felt so embarrassed that they knew. I sometimes saw other sex workers in the hotels, they knew I was working and would ask me about it. A lot of them were trafficked too and most had very little English. “

 

Safe and Free received a report from a sex worker who was concerned about Jodie and her two friends (also victims of trafficking) and we were able to help Jodie to escape from her trafficker, speak to her parents about her ordeal, contact the police and begin the journey of dealing with her traumatic experiences.        

 

Please get in touch to start protecting your hotel from trafficking:

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