Resource
Stop Slavery Blueprint
Created and compiled by Shiva Foundation
This toolkit is intended for the internal use of hotels and other stakeholders in the industry. It has been created as guidance with recommended action and templates throughout to set up strong processes and protocols to address risk of modern slavery within your business and supply chains. The Blueprint can be adapted by individual managers, department heads and teams as appropriate to better suit the nuances and needs of your organisation.
It is important that senior management be ultimately responsible for any processes or policies put in place and that efforts are regularly monitored for effectiveness. We hope to continue adapting the Blueprint in line with best practice and we welcome feedback, constructive criticism and new partnerships to improve this work.
Introduction
“Slavery and human tracking are illegal. Yet, there are still an estimated 40.3 million people trapped in modern slavery around the world today.”
The global demand for cheap labour fuels the trade in humans and market forces create both the supply and the demand for these people. The hotel and hospitality sector employs 292 million people worldwide (1 in 10 people globally) and contributes 10.2% of the global GDP. Hospitality has been identified as a sector at risk of modern slavery. Hospitality businesses need to take the lead in the fight against modern slavery and human tracking (herein referred to as “modern slavery”).
This Stop Slavery Blueprint (the “Blueprint”) sets out the key principles to be embedded into a hotel as part of its fight against modern slavery. It provides guidance and recommendations in the form of:
- Policies and practices
- Procedures and protocols
- A checklist of suggested actions
These are meant to be adopted across hotels and across departments. The Blueprint provides further specific guidance for individual managers, department heads and teams where appropriate. The guidance focuses on the following key risk areas:
Hotel usage
- Individual sales
- Check-in systems
- Guest monitoring
Employees
- Employment practices
- Use of agencies
- Supplier engagement
Supply Chains
- Food and Beverage
- Maintenance
- Procurement
- Company sales
- Contractors and subcontractors
Executive decision making
- Investments
- Partnerships
- Travel
The Blueprint provides guidance on transparency, reporting, performance measurement, business partner engagement, risk assessment, business authentication, and investigation and remediation. Employees can refer to the relevant sections below for further information or contact their manager to discuss these policies in further detail.
General Managers can familiarise themselves with this Blueprint and associated documents to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for any incidence of modern slavery is prevented.
To demonstrate the organisation’s commitment to implementing the recommendations contained within this Blueprint, a statement can be included in company handbooks and starff reading materials as appropriate. See an example Statement.
Definitions
For the purposes of this Blueprint, the definition of modern slavery, in keeping with the UK Modern Slavery Act 2015, includes:
Human trafficking
The movement of people by means such as force, fraud, coercion or deception with the aim of exploiting them.
Slavery, Servitude and forces or compulory labour
Ownership exercised over a person; or all work or service that is extracted from any person imposed imposed by coercion or under the threat of penalty and for which the employee has not offered themself voluntarily.
Note, throughout this Blueprint, the terms human tracking and modern slavery refer to both sexual exploitation and forced labour.
“I am pleased to see Shiva Foundation taking the lead on tackling modern slavery and human tracking within the hotel sector. This Blueprint is a robust guide for hotels to take action and I hope to see many within that sector taking it up, and other sectors following the leadership this displays to protect vulnerable people from exploitation.”
Kevin Hyland, UK Independent Anti-Slavery Commissioner (2015-2018)
1 – Public Commitment
Having a public commitment to tackle modern slavery throughout a hotel’s operations and supply chain is an important part of addressing the issue. Not only are staff able to see the commitment regularly, guests are aware of the organisation’s efforts to address the problem.
See an example statement: Our Commitment to Tackle Modern Slavery.
RECOMMENDED USE OF THE PUBLIC COMMITMENT IS TO:
SHARE…
the statement internally with all staff and include it as required reading, either at the beginning of their employment or when the statement is being implemented.
INCORPORATE…
the statement into the hotel’s vision, mission, value statement, departmental goals and any other relevant strategic and employment documents, as appropriate.
DISPLAY…
the statement in bedrooms either as part of the printed information packs, on the TV screens or using another appropriate method.
ENSURE…
that a copy of the statement is accessible to staff on a daily basis, for example on the staff room notice boards.
SHARE…
information on the hotel’s stance on modern slavery with prospective staff and new staff joining in their welcome package.
DISPLAY…
the statement publicly in the lobby areas.
Relevant Templates:
Example Statement: Our Commitment to Tackle Modern Slavery
Example Staff Room Poster
2 – Policies & Practice
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.
3 – Procedures & Protocols
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.
4 – 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.
Identifying and Assessing Risk is an Ongoing Process.
Relevant Templates:
Framework for Working With Suppliers
5 – Training
It is important that all employees are trained in order to increase their general awareness of modern slavery and the hotel industry and how to spot the signs. Training can also provide details on how to prevent risk of modern slavery in specific roles. See example Training Powerpoint.
Tip: Modern slavery training sessions should be integrated into each hotel’s training course schedule and training strategy. Regular training updates should be run as should yearly refresher trainings, as agreed with the head office. Training should run alongside Health & Safety.
It is recommended that training sessions be facilitated by experts, in consultation with managers, for individuals and departments throughout the business. This training should be designed to go beyond awareness raising in order to help each employee understand his or her role in tackling this issue. Training should be tailored by role and department to have the most impact and relevance.
Trainings should include:
- Background information on the issue;
- Guidance to support employees with an understanding of expected behaviour (see example Indicator List);
- Explanations of relevant policies and protocols;
- Practical examples and Case Studies; and
- Information on how to reassure staff when they’ve reported something, regardless of the outcome.
- Employees should be encouraged to raise concerns during or after these sessions and should be given a disclaimer at the beginning to pre-empt any emotional triggers. It is important to ensure knowledge is retained after the training is completed and therefore it is recommended to use a Quiz to assess retained knowledge three months after the initial training. Short refreshers can also reinforce learning as and when required.
Senior level staff should also be trained, despite the fact that their roles are not operational. Aside from running a training specifically for them, any refreshers or updates can form part of the yearly AGMs. Where applicable, training of suppliers can also be provided.
It is recommended to send out a general briefing to all staff in advance of a large event as such events can often increase risk of modern slavery.
The case studies used in the example training, which are recommended as part of this Blueprint, are from the COMBAT Toolkit. The complete toolkit, designed for addressing modern slavery in hospitality, can be found here.
Relevant Templates:
Example Training Powerpoint
Example Indicator List
Training Case Studies
Example Knowledge Retention Quiz
6 – Reporting, Monitoring & Evaluation
Hotel executives and management teams should outline specific, measurable and clear KPIs in order to review progress across each area outlined in this Blueprint. These should include monitoring of, among other things:
- Employee training levels and knowledge retention levels (see an example Knowledge Retention Quiz which is recommended to track staff knowledge three months after training).
- Actions taken to strengthen supply chain auditing and verification.
- Steps taken to upskill high risk suppliers, and assessing their ability to detect and mitigate modern slavery risk in supply chains.
- Investigations undertaken into reports of modern slavery and remedial actions taken in response. See an example Reporting Log which can be used at the reception desk to track all reported indicators.
Head office shall also work towards publicly reporting on its policies and procedures, goals and targets, investigations, key risk areas and overall performance related to eradicating modern slavery. A checklist can be useful in ensuring evidence of Blueprint implementation is being tracked. See an example Checklist. It is also helpful having materials displayed so staff can see where implementation is occuring. See example Staff Room Poster.
Relevant templates:
Example incident reporting log
Example checklist
Resource
Stop Slavery Blueprint
Created and compiled by Shiva Foundation
This toolkit is intended for the internal use of hotels and other stakeholders in the industry. It has been created as guidance with recommended action and templates throughout to set up strong processes and protocols to address risk of modern slavery within your business and supply chains. The Blueprint can be adapted by individual managers, department heads and teams as appropriate to better suit the nuances and needs of your organisation.
It is important that senior management be ultimately responsible for any processes or policies put in place and that efforts are regularly monitored for effectiveness. We hope to continue adapting the Blueprint in line with best practice and we welcome feedback, constructive criticism and new partnerships to improve this work.
Introduction
“Slavery and human tracking are illegal. Yet, there are still an estimated 40.3 million people trapped in modern slavery around the world today.”
The global demand for cheap labour fuels the trade in humans and market forces create both the supply and the demand for these people. The hotel and hospitality sector employs 292 million people worldwide (1 in 10 people globally) and contributes 10.2% of the global GDP. Hospitality has been identified as a sector at risk of modern slavery. Hospitality businesses need to take the lead in the fight against modern slavery and human tracking (herein referred to as “modern slavery”).
This Stop Slavery Blueprint (the “Blueprint”) sets out the key principles to be embedded into a hotel as part of its fight against modern slavery. It provides guidance and recommendations in the form of:
- Policies and practices
- Procedures and protocols
- A checklist of suggested actions
These are meant to be adopted across hotels and across departments. The Blueprint provides further specific guidance for individual managers, department heads and teams where appropriate. The guidance focuses on the following key risk areas:
Hotel usage
- Individual sales
- Check-in systems
- Guest monitoring
Employees
- Employment practices
- Use of agencies
- Supplier engagement
Supply Chains
- Food and Beverage
- Maintenance
- Procurement
- Company sales
- Contractors and subcontractors
Executive decision making
- Investments
- Partnerships
- Travel
The Blueprint provides guidance on transparency, reporting, performance measurement, business partner engagement, risk assessment, business authentication, and investigation and remediation. Employees can refer to the relevant sections below for further information or contact their manager to discuss these policies in further detail.
General Managers can familiarise themselves with this Blueprint and associated documents to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for any incidence of modern slavery is prevented.
To demonstrate the organisation’s commitment to implementing the recommendations contained within this Blueprint, a statement can be included in company handbooks and starff reading materials as appropriate. See an example Statement.
Definitions
For the purposes of this Blueprint, the definition of modern slavery, in keeping with the UK Modern Slavery Act 2015, includes:
Human trafficking
The movement of people by means such as force, fraud, coercion or deception with the aim of exploiting them.
Slavery, Servitude and forces or compulory labour
Ownership exercised over a person; or all work or service that is extracted from any person imposed imposed by coercion or under the threat of penalty and for which the employee has not offered themself voluntarily.
Note, throughout this Blueprint, the terms human tracking and modern slavery refer to both sexual exploitation and forced labour.
“I am pleased to see Shiva Foundation taking the lead on tackling modern slavery and human tracking within the hotel sector. This Blueprint is a robust guide for hotels to take action and I hope to see many within that sector taking it up, and other sectors following the leadership this displays to protect vulnerable people from exploitation.”
Kevin Hyland, UK Independent Anti-Slavery Commissioner (2015-2018)
1 – Public Commitment
Having a public commitment to tackle modern slavery throughout a hotel’s operations and supply chain is an important part of addressing the issue. Not only are staff able to see the commitment regularly, guests are aware of the organisation’s efforts to address the problem.
See an example statement: Our Commitment to Tackle Modern Slavery.
RECOMMENDED USE OF THE PUBLIC COMMITMENT IS TO:
SHARE…
the statement internally with all staff and include it as required reading, either at the beginning of their employment or when the statement is being implemented.
INCORPORATE…
the statement into the hotel’s vision, mission, value statement, departmental goals and any other relevant strategic and employment documents, as appropriate.
DISPLAY…
the statement in bedrooms either as part of the printed information packs, on the TV screens or using another appropriate method.
ENSURE…
that a copy of the statement is accessible to staff on a daily basis, for example on the staff room notice boards.
SHARE…
information on the hotel’s stance on modern slavery with prospective staff and new staff joining in their welcome package.
DISPLAY…
the statement publicly in the lobby areas.
Relevant Templates:
Example Statement: Our Commitment to Tackle Modern Slavery
Example Staff Room Poster
2 – Policies & Practice
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.
3 – Procedures & Protocols
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.
4 – 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.
Identifying and Assessing Risk is an Ongoing Process.
Relevant Templates:
Framework for Working With Suppliers
5 – Training
It is important that all employees are trained in order to increase their general awareness of modern slavery and the hotel industry and how to spot the signs. Training can also provide details on how to prevent risk of modern slavery in specific roles. See example Training Powerpoint.
Tip: Modern slavery training sessions should be integrated into each hotel’s training course schedule and training strategy. Regular training updates should be run as should yearly refresher trainings, as agreed with the head office. Training should run alongside Health & Safety.
It is recommended that training sessions be facilitated by experts, in consultation with managers, for individuals and departments throughout the business. This training should be designed to go beyond awareness raising in order to help each employee understand his or her role in tackling this issue. Training should be tailored by role and department to have the most impact and relevance.
Trainings should include:
- Background information on the issue;
- Guidance to support employees with an understanding of expected behaviour (see example Indicator List);
- Explanations of relevant policies and protocols;
- Practical examples and Case Studies; and
- Information on how to reassure staff when they’ve reported something, regardless of the outcome.
- Employees should be encouraged to raise concerns during or after these sessions and should be given a disclaimer at the beginning to pre-empt any emotional triggers. It is important to ensure knowledge is retained after the training is completed and therefore it is recommended to use a Quiz to assess retained knowledge three months after the initial training. Short refreshers can also reinforce learning as and when required.
Senior level staff should also be trained, despite the fact that their roles are not operational. Aside from running a training specifically for them, any refreshers or updates can form part of the yearly AGMs. Where applicable, training of suppliers can also be provided.
It is recommended to send out a general briefing to all staff in advance of a large event as such events can often increase risk of modern slavery.
The case studies used in the example training, which are recommended as part of this Blueprint, are from the COMBAT Toolkit. The complete toolkit, designed for addressing modern slavery in hospitality, can be found here.
Relevant Templates:
Example Training Powerpoint
Example Indicator List
Training Case Studies
Example Knowledge Retention Quiz
6 – Reporting, Monitoring & Evaluation
Hotel executives and management teams should outline specific, measurable and clear KPIs in order to review progress across each area outlined in this Blueprint. These should include monitoring of, among other things:
- Employee training levels and knowledge retention levels (see an example Knowledge Retention Quiz which is recommended to track staff knowledge three months after training).
- Actions taken to strengthen supply chain auditing and verification.
- Steps taken to upskill high risk suppliers, and assessing their ability to detect and mitigate modern slavery risk in supply chains.
- Investigations undertaken into reports of modern slavery and remedial actions taken in response. See an example Reporting Log which can be used at the reception desk to track all reported indicators.
Head office shall also work towards publicly reporting on its policies and procedures, goals and targets, investigations, key risk areas and overall performance related to eradicating modern slavery. A checklist can be useful in ensuring evidence of Blueprint implementation is being tracked. See an example Checklist. It is also helpful having materials displayed so staff can see where implementation is occuring. See example Staff Room Poster.
Relevant templates:
Example incident reporting log
Example checklist