Combatting Human Trafficking in the Hospitality Industry
By John Welty Practice Leader, SUITELIFE, Venture Insurance Programs | July 07, 2019
The films in the series Taken, starring Liam Neeson, paint a frightening picture of human trafficking. While traveling to Paris with her friend, Neeson's character's teenage daughter is abducted from the room in which she is staying by sex traffickers. In the movie, Neeson- conveniently an ex-CIA agent-was able to use his "very particular set of skills" to hunt down the criminals who took his daughter and her friend.
Though Neeson's character (spoiler alert) saves his daughter in the film, outside of Hollywood, human trafficking cases don't always have a happy ending. Fortunately, the hotel industry is working to be a part of the solution to modern-day slavery.
As we all know, Hollywood tends to incorporate drama and special effects to increase entertainment value, but the reality is trafficking is a problem in the real world, not just on the silver screen. Human trafficking is a danger for vulnerable groups all over the world, young people and immigrants. Hotels are often incorporated in the trafficking process for the privacy they offer–serving as private venues from which criminals can operate, temporarily reside or transport victims.
The Hard Facts
The non-profit group the Polaris Project works to put an end to human trafficking around the world. Research on Human Trafficking and the Hotel Industry, based on calls to the National Human Trafficking Resource Center and texts to the Polaris BeFree helpline, show the involvement of the hotel industry in human trafficking in the United States between December 2007 through December 2017. Polaris reported 3,596 cases of trafficking in hotels and motels in the U.S. and found that 75 percent of all trafficking victims reported coming in contact with a hotel at some point during their abduction.
Survivors reported that their abductors mostly used the hotels for commercial sex (80 percent). However, others said the hotels were used for travel (69 percent), to provide shelter for victims while exiting a trafficking situation (47 percent), or by traffickers to house victims (20 percent).
Additionally, Polaris reported that 86 percent of trafficking victims in the U.S. were female. Twenty-three percent were foreign nationals and 77 percent were U.S. citizens or permanent residents. Victims became involved in trafficking at a frighteningly young age, according to the research. Tragically, 17 percent of victims are between the ages of 0-11, 18 percent are between the ages of 12-17, and 18 percent are between the ages of 18-23.
This human trafficking issue is in every town and city. No one is immune from these crimes.
In March 2019, three Philadelphia hotels were named in a lawsuit filed in the Philadelphia Court of Common Pleas for failure to take steps to prevent trafficking, according to the Philadelphia Inquirer.
The lawsuit was filed by two teenagers who were sold as prostitutes within the hotel, until they were freed by the FBI at the ages of 15 and 16. The complaint said that the victims were drugged and forced into having sex with paying customers of the hotels for a period of several months. This is the second time one of the three hotels has been named in a sex trafficking lawsuit. The lawsuit is seeking to hold the owners and parent companies of these three hotels responsible.
Similar lawsuits were filed in Texas in April 2018 by sex trafficking victims who claim they were shuttled from truck stops to hotels in the Houston area and seen numerous times by hotel staff who failed to report suspicious behavior, according to NBC Washington.
"Like you pass valet, you pass the concierge desk, you pass maids in the hallway and nobody says anything," one of the plaintiffs said in the lawsuit.
In the Philadelphia Inquirer article, the owner of the hotel named in the suit says, "We just rent the room and that's all we can do… if we think a lot of people are having a party in the room, we kick them out."
But, that's not all that hotel owners can do. Hoteliers have a moral obligation to keep an eye out for and report suspicious behavior. Further, if it is found that they operate a business that permits human trafficking, the hotel operator could find themselves under a heap of legal and financial issues–not to mention reputational damage.
While insurance can protect the business should a hotel become involved in a trafficking incident, a hotelier's general liability policy would primarily provide defense coverage only if the hotel was not aware of the crime. If a hotel is found to have had knowledge and permitted human trafficking, this would be deemed a criminal offense with no coverage offered. A knowledgeable insurance partner in the hospitality space can help hotels understand their coverages, as well as connect hoteliers with resources that can help with staff training and education to mitigate their risk of involvement.
In some states, a hotel owner may have more than a moral obligation to be vigilant when it comes to reporting signs of human trafficking under their roof, as new laws bring attention to the issue.
Unpacking Human Trafficking, a new report by ECPAT-US, a nonprofit anti-child trafficking organization, reviewed the different anti-human trafficking laws in the U.S. and provides some insight on each.
The report found that some states require signage alerting employees to be aware of human trafficking within the hotel and report it, while others go so far as to require human trafficking awareness training for hotel staff.
Fifteen states have laws addressing human trafficking awareness training for hotel employees. California, Connecticut, Minnesota and New Jersey mandate such training. Additionally, 13 states mandate awareness signage for human trafficking within hotels including: California, Connecticut, Georgia, Louisiana, Maine, Minnesota, New Jersey, New Mexico, New York, North Carolina, South Carolina, Texas and West Virginia. Another seven states require signage at hotels previously cited as a public nuisance– Alabama, Arkansas, Maryland, Michigan, Missouri, Pennsylvania and Rhode Island.
ECPAT-US offers posters and sample language to comply with each state's legal requirements on their website. The signage encourages readers to report any sign of human trafficking by calling a toll-free hotline or texting the National Human Trafficking Resource Center.
Education Is Key to Prevention
The hospitality industry is seeing more and more human trafficking reported on a regular basis. Human trafficking comes in many forms such as sex trafficking, forced labor or domestic servitude.
Education, training and more education and more training are the keys for a hotel to try to stay ahead of this issue. Twelve to 18 months ago, industry leaders were training hotels on the broad issue of human trafficking. The focus now is moving toward how various departments within the hotel can identify inappropriate or suspicious behavior. For example, the front desk could see certain behaviors, like customers paying only in cash and bringing in different guests, while housekeeping can observe "do not disturb" signs on doors for days on end or suspicious paraphernalia in a guest's room.
Aside from specific training programs offered at major hotel chains and what is required by various state laws, Polaris provides recommendations for hotel training to prevent human trafficking. The recommendations include the following:
- Implement an anti-trafficking policy that demonstrates the hotel's commitment to prevent trafficking of all kinds down to the franchisee level.
- Consider a policy to allow rewards points to be donated to support survivor lodging.
- Train staff of all levels as new hires and regularly throughout their tenure to identify suspicious activity and establish a response plan.
Additionally, the Department of Homeland Security provides a Hospitality Toolkit, Awareness Training and many more tools addressing human trafficking. DHS suggests that staff look for the following signs:
- Fearful or anxious individuals
- Signs of physical abuse
- Malnourished individuals or those with poor hygiene
- Individuals with no personal items or bags
- A significant age difference between companions
- Individuals dressed inappropriately for their age
- Individuals who do not have possession of their own ID
- Tattoos on individuals in similar locations that could signify branding by a specific trafficker
- Multiple computers or cell phones in a room
- Large quantities of cash
- Evidence of pornography
Human trafficking is a threat for hotels of any stature in a variety of locations around the world, which is why many in the industry are taking action on their own. For example, Wyndam Hotels and Resorts has partnered with Polaris to allow guests to donate their reward points to Polaris to use for victims in need of emergency shelter. Further, Marriott International launched a program requiring human trafficking awareness training for staff and created a program in conjunction with the Global Fund to End Modern Slavery to help human trafficking survivors find jobs in the hospitality industry.
Human trafficking is a horrendous crime and more must be done to prevent it. Hotels can and should play a key role in prevention, as they may already be inadvertently acting as enablers to this illicit activity. By educating their staff to identify and report suspicious activity, hotel operators can ensure they are not allowing illegal activity within the business, while saving lives.
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