Something seems a bit off about the guests in room 403. An older man checked in with a young woman who looked like she could be 18. The entire time they were at the front desk, she only looked down at the ground and seemed a little out of it. They checked in two days ago, posted the “do not disturb sign,” and the young woman hasn’t left the room since; plus, various people have been coming and going at all hours. They have also asked for new towels several times.
On their own, many of these facts could seem innocuous. Perhaps, a father and daughter, straight off an 18-hour flight, accounting for the girl’s demeanor. Or, the reluctance to admit housekeeping could just be an environmentally minded guest or a business traveler who knows they’ll be in and out of the room all day in between conference sessions. Discerning between potentially peculiar guest behavior and a grave, dangerous situation can be difficult without the proper training—but it is essential.
The hospitality industry has a problem—a big one. These signs, collectively, all seem to point to the fact that this woman could be one of the more than 40.3 million victims of human trafficking, as estimated by the International Labour Organization.
And while labor and sex trafficking takes place in all types of industries and locations, the nature of the hotel space—transient, secluded guestrooms, a service culture that respects guest privacy—means hotels are, unfortunately, the ideal environment for traffickers.
“One of the biggest things that hotels offer traffickers is that ability to fly under the radar, to be anonymous, to be able to change locations frequently; you don’t have to rent an apartment where your name goes on a lease,” said Elaine McCartin, corporate partnerships and training manager with Polaris, a nonprofit, nongovernmental organization that works to combat and prevent modern-day slavery and human trafficking.
While human trafficking is an abhorrent occurrence, like many detestable crimes, it’s also one that offers a high return on investment for the perpetrators. “What makes [trafficking]thrive is that it is essentially a low-risk, high-profit crime,” McCartin said. “When it comes to choosing where you are going to conduct this crime, a hotel offers a very low-risk opportunity.”
Consider this: Polaris operates the National Human Trafficking Hotline through a grant from the Department of Health and Human Services, and its Office on Trafficking in Persons. McCartin said that from December 2007 to the end of 2017, the hotline recorded nearly 3,600 cases of human trafficking involving a hotel or motel. And how many cases went unreported?
“A study out of San Diego County found that 77% of the arrests for commercial sexuality activity in the county took place at hotels,” said Mar Brettmann, executive director of Seattle-based Businesses Ending Slavery & Trafficking (BEST), another organization working to fight human trafficking. “That was a really formal, university-level study. We did some more informal research here and found that 63% of cases in the Seattle area involved hotels and motels.”
So what does this all mean? The ability to identify human trafficking and alert the proper authorities is hugely important for hotels. To help in the fight against human trafficking, Polaris and BEST have teamed with hospitality organizations to offer training to workers to recognize the signs of trafficking. “The hotel industry was really one of the first to come together as an industry,” she said. “I know it is a very competitive industry, yet I have seen how they put their differences aside to really come together to try to address this issue.”
Not surprisingly, major lodging associations like the Asian American Hotel Owners Association (AAHOA) and the American Hotel & Lodging Association (AHLA) have led the way. “We have been engaged in this area for almost a decade now, but over the last few years, we have really ramped up our focus,” said Rachel Humphrey, interim president/CEO, AAHOA. “AAHOA’s members are owners—getting messaging to hotel owners is critical in the fight against human trafficking, and that is where AAHOA has an advantage.”
For Jagruti Panwala, AAHOA vice chairwoman and president/CEO of Wealth Protection Strategies, human trafficking is an issue that is of great personal importance to her. “Human trafficking impacts communities across the country, and it’s an issue that the hospitality industry is uniquely positioned to address,” she said. “Because traffickers frequently move locations, they will try to use the frequent guest turnover at hotels to mask their illicit activities. With the right training and education, hoteliers and their employees can learn to identify trafficking situations and respond appropriately.”
Naturally, she has taken AAHOA’s training and has instructed all of her general managers and employees to be trained as well. “Human trafficking can be difficult to spot, but the training we’ve developed with Polaris and BEST are comprehensive and equip hospitality workers with the tools to help end trafficking,” she said.
For Chip Rogers, president/CEO, AHLA, the strategy is twofold: “Hotels can play an important role in fighting human trafficking networks. That’s why our efforts to fight human trafficking have focused on two key pillars: raising awareness and training as many hotel employees as we can to be vigilant… Every year, thousands of employees are trained to spot and help stop trafficking incidences.”
Both organizations have worked with various groups to develop initiatives and training—the Department of Homeland Security’s Blue Campaign, Polaris, BEST and ECPAT-USA, to name a few. “These partnerships help connect these anti-trafficking organizations with our members and educate them on the important role they can play in ending trafficking,” Humphrey said.
AAHOA developed two online programs with Polaris and BEST that are available for free to all AAHOA members and their employees, and available in multiple languages.
“AAHOA regularly emphasizes the need for training at town halls, regional meetings, our annual convention and other AAHOA events, and hosts webinars and other awareness offerings,” said Humphrey. “We have also had members and staff complete a train-the-trainer program to give us greater resources to train at the grassroots level for members of the broader hospitality community who may not be actively engaged with AAHOA. We are also working closely with elected officials at the state and national level to let them know that the hospitality industry is their partner in efforts to combat human trafficking.”
It’s a team effort, one that can’t just be fought on the national level. Local associations, regional groups and individual hotels and staff members have to play their part. Both BEST and Polaris have worked with hotel associations on the state, county and city levels as well.
“HANYC [Hotel Association of New York City] has always supported efforts to combat human trafficking, but since my leadership began two years ago, we got actively engaged on a variety of fronts, including legislative, training with seminars and raising funds for nonprofits engaged in this area,” said Vijay Dandapani, president/CEO, HANYC. “Human trafficking is a growing problem that requires a highly coordinated effort, which involves all affected sectors in the private and public arena. Working with enforcement officials, airlines and nonprofits is an essential part of efforts to bring down the scourge.”
Associations have worked with local governments to strengthen and even create laws to help fight the crime. The California Hotel & Lodging Association recently worked with the government of California to pass SB 970, which requires hotel and motel employers in the state to provide 20 minutes of human trafficking awareness training to all employees who are “likely to interact or come into contact with victims of human trafficking.”
The bill requires employers to give the training by January 1, 2020, to each new employee within six months of their employment in a qualifying role, and then every two years thereafter.
Elvin Lai, principal of G4 Risk Solutions and owner/operator of the 72-room Ocean Park Inn hotel in Pacific Beach, CA, was happy to see the law passed. “We’re already complying with the requirements of the new law and encourage everyone in the industry to follow our lead,” he said. “Even though we have quite enough regulations in California, we’re more than happy to have a requirement on the books so that everyone trains their employees. This can only help our industry eliminate risk and prevent this type of criminal activity.”
For Lai, it is important that the industry step up. “The hospitality industry as a whole stands at the front lines of stopping this criminal practice, and is taking an active role in developing standardized protocols to help eliminate it,” he said. “From luxury to budget accommodations, no property is immune. It’s critical the hospitality industry continues taking action toward the elimination of human trafficking.”
Alex Cabañas, CEO of Benchmark, a global hospitality company, agreed that the crimes can happen at any hotel along the chain scale. “I am glad our industry is paying more attention to it,” he said. “Our business is upper-upscale and luxury, and the perception is that it is something that happens more often in budget or limited-service locations. And while that—in terms of numbers—is probably true, the reality is that it happens at all chain scales in our business. Every operator should be paying attention to the issue.”
While human trafficking doesn’t just happen at lower-end properties, it also doesn’t just happen in larger cities; it can happen anywhere—and to anyone. “We did training for a hotel in a small town way outside of the city and they thought, ‘This is like Mayberry, no trafficking happens here,’” said BEST’s executive director. “But they went ahead and did the training, and within a few months, they identified several cases. One was a young woman. A housekeeper noticed that she was in a room during a school day and started asking questions. She saw some other indicators and called the police. They had been looking for the trafficker, watching the trafficker for some time, so they were able to get the girl separated from the trafficker and she was returned to her family. A couple of weeks later, the mother of the girl called the hotel GM and thanked him.”
While sex trafficking is often thought of most when human trafficking occurs, at hotels, labor trafficking happens as well. “We had a case in Seattle of a young woman who was brought into the U.S. by her uncle with promises of work and school,” said Brettmann. “She didn’t speak English. Her uncle was able to translate for her, get her a job and get fake paperwork so she appeared older than she was. Every time her uncle would pick her up from work, or she would get her paycheck, he would take her to the bank and she would get her ID for a moment. He would cash her paycheck and he would take the ID back. He was taking her paycheck, and he was sexually and physically abusing her in the home.”
She continued, “She didn’t feel like she could leave because she didn’t have any way. It was a coworker in the hotel who noticed that this woman was experiencing abuse and was able to get her connected with detectives who were able to help her.”
Training is crucial
Training is an important way to help fight trafficking—and it can save lives. “We really emphasize the need for training in hotels; when people aren’t being trained, why would they recognize something?” said McCartin. “Either it is ‘not their business’ or they assume that it is just a commercial sex situation and think, ‘I don’t want to get involved’ or ‘These are criminals.’”
Apathy and ignorance are the aids that traffickers depend on.
“When training happens, it really helps to deflect that equation, to take it from low-risk, high-profit to high-risk, low-profit,” she said. “When that safety net is there, and people are trained on what to do and appropriate ways to respond—ways that are trauma-informed and victim-centered—it makes the traffickers have to go elsewhere to conduct their illicit business.”
How can owners and operators make sure their employees are well trained to spot the warning signs? In addition to hotel associations, branded properties can look to their brands for guidance. Aware of the pervasiveness of the problem, hotel companies have set strategies in place.
For example, Marriott International Inc. has trained more than 500,000 of its employees to recognize the signs of human trafficking. “We have a holistic multi-prong approach to addressing human trafficking and modern slavery, which includes raising awareness among associates and guests, leveraging our business to empower vulnerable populations, and investing in strategic partnerships with external expert groups to find and implement solutions that will benefit the industry as a whole,” said Tu Rinsche, global director of social impact, Marriott. “In 2017, we launched new public human rights goals, prioritizing human trafficking awareness raising, prevention efforts and supply-chain accountability as areas where we can be impactful as a business. This year, we have developed some additional educational resources that we hope can further raise awareness among on-property associates, but also guests. We are constantly innovating ways to build upon our learnings as a business to empower vulnerable populations.”
At Lai’s Ocean Park Inn, awareness and education are a priority for all guest-facing team members. “More specifically, it is critically important that our employees understand what human trafficking is, how human trafficking can materialize and, most importantly, feel empowered with the resources needed to prevent suspected activity,” he said. “All our employees, with a focus on front-desk staff and housekeeping, receive training to strengthen their recognition abilities, in addition to learning proper protocols for reporting potential activity.”
Gwen Migita, social impact and inclusion VP/chief sustainability officer, Caesars Entertainment, added, “As part of our stance against human trafficking, we inform and educate our executives, managers and key front-line employees as part of our counter-trafficking program, which encompasses victim-centered training on the risks and manifestations of human trafficking; mandated protocols and procedures to address suspected instances; processes to prevent potential incidents from occurring at our properties; and immediately reporting suspected instances of trafficking to community partners, such as law enforcement. Additionally, we have trained hundreds of managers and security team members across our properties. We have also appointed volunteer Community Engagement Ambassadors (CEAs) as leaders to address sex trafficking and commercial sexual exploitation in 12 properties in Nevada and North Carolina.”
The company works with counter-trafficking expert and consultant Dr. Halleh Seddighzadeh, founder of ARMAN, a human rights agency serving victims of trafficking and violence and providing social impact consultation and training to public and private sectors. “Dr. Halleh helped create a pioneering, multi-year counter-trafficking program for Caesars Entertainment that consists of a customized in-depth training of security team members, along with a comprehensive train-the-trainer program,” she said.
Hilton also makes training mandatory for its hotels. “Whether we can control and direct, influence and empower, or inspire and elevate, we’re committed to driving respect for human rights across our value chain, including combating both forced labor and sexual exploitation,” said Caroline Meledo, head of human rights. “We take action in our operations, supply chain and development activities, and engage with our communities and the industry to tackle modern slavery from all angles.”
Along with its franchisees, Wyndham Hotels & Resorts supports the UN Universal Declaration of Human Rights, End Child Prostitution and Trafficking (ECPAT), and Polaris in a shared mission to combat all forms of human trafficking. “Our partnership with Polaris allows us to act upon our commitment to doing the right thing by educating and preparing our employees and franchisees to identify and help prevent human trafficking,” said Patricia A. Lee, EVP, global training and development/chief social responsibility officer, Wyndham. “In the last year alone, we’ve trained nearly 1,500 team members to identify the signs of human trafficking.”
Supply chain also critical
It’s not just in the hotels that the industry can make a difference. Hotel companies are desirable partners for a lot of vendors—and they can wield that power for good causes, such as this.
At Caesars, new contracted vendors, team members and customers are informed of the company’s stance against human trafficking and are requested to adopt a similar approach. “Caesars regularly conducts due diligence to ensure that there are no instances of human trafficking in our supply chain, following regulations including the California Transparency in Supply Chains Act and the U.K. Modern Slavery Act,” said Migita. “Appropriate action will be taken with a vendor, team member or customer who is proven to be involved in human trafficking violations, which may include termination of our relationship or other necessary measures.”
Hilton has focused on ending trafficking for forced labor in its supply chain. “We require our labor agencies in Europe, Middle East and Africa (EMEA) to conduct a third-party audit to check on their practices,” said Meledo. “We developed training on the risks of modern slavery in labor sourcing, based on best practices from different industries and tailored to hospitality—a first in the industry. The training is mandatory for our managed hotels in EMEA. We’re looking to expand that approach to other regions.”
Hilton has identified risks of modern slavery in the construction phase of hotels. “Given our business structure, we do not own the hotel buildings, and do not appoint or manage any of the contractors that work on the construction sites,” she said. “However, what we can do is to influence and empower our owners to identify and manage those risks in their own supply chain. We are due to enter 35 new countries. We conducted a human rights analysis for all of them, and developed mitigation plans where necessary, which are mandatory to follow for owners.”
A new beginning
Identifying human trafficking and alerting the proper authorities isn’t the only way the industry can offer its aid. Hoteliers can also help victims once they have been removed from the situations. After all, what else is a hotel but a home away from home, a space designed to be a refuge for people?
Polaris’ McCartin said that Wyndham has a program to help victims of human trafficking after they have been taken out of their situations. “[The company] has a fantastic program through Wyndham Rewards, in which both Wyndham and its customers can donate rewards points directly to Polaris through our hotline, and we use those for survivors who call in,” she said, adding that the importance of this can’t be overstated. “This is, literally, a lifesaving service because there is a shortage of shelters around the country, especially shelter for trafficking victims. If a service provider or survivor calls into our hotline and is in need of shelter, and there is not a bed available, the only available option would be for them to go back on the street. However, we have these points from Wyndham, so we work directly with local service providers to help make this possible. Then we can have that extra safety net of a short-term stay in a hotel until a bed opens up.”
There are other ways hotel companies can empower and aid victims on the road to recovery. For instance, at the start of 2019, Caesars created The Shared Future Fund, a new investment model that will be used to create long-term positive change for adult and child victims of human trafficking. The fund will be controlled and managed by ImpactNV, a 501(c)(3) nonprofit in southern Nevada dedicated to mobilizing cross-sector leadership to address pressing social needs and building a better community.
“The Shared Future Fund aims to define a new pathway to achieve philanthropic goals by supporting a holistic, community-centered strategy that emphasizes advocacy and collective impact rather than the traditional approach of contributing financial resources to company-chosen causes,” said Migita. “The initial emphasis of the fund will be to provide support those affected by trauma associated with human trafficking; long-term, the fund will look to solve other social inequality issues, such as homelessness and immigration integration.”
Economic empowerment can also be useful. “We leverage our buying power as a force for good,” said Hilton’s Meledo. “We partner with To The Market, a social enterprise that sells artisan goods made by trafficking survivors. We use their products (e.g., tote bags) for the swag we buy for our internal events, with partners, and promote them to our conference and events clients.”
The hotel companies have also created and supported organizations in the fight against trafficking. “We co-founded the Global Freedom Exchange with Vital Voices, which is a community leader empowerment program focused on female anti-trafficking advocates to develop local solutions to prevent human trafficking,” she said. “We’ve trained 127 women from 50 countries since 2013. Sixteen of them are survivors—they know firsthand what can be done to save others.”
Marriott was the first corporate partner of The Global Fund to End Modern Slavery. “We are going beyond internal training to develop a new program that will provide market-based skills resources for survivors to help them progress along their journey toward self-sufficiency,” said Rinsche. “We will continue to use our business voice to speak out against human trafficking and share our resources to the broader industry and public.”
Many of the brands work with BEST, Polaris, ECPAT-USA and the International Tourism Partnership (ITP), a nonprofit convening hospitality companies to provide a forum for action on environmental and social issues. “There is no competition when it comes to human rights,” said Meledo. “We’re members of the ITP. We supported the launch of the Forced Labor Principles, which helps create a level playing field. We also decided to give our training on modern slavery in labor sourcing” to the ITP. It will be live this month for all ITP members to use for free. This will help accelerate the industry’s ability to tackle modern slavery fast, and at scale. HB”