Human trafficking and the hospitality industry

According to a report from the U.S.-based Polaris, 75% of U.S. based human trafficking survivors report having some contact with a hotel or motel during their trafficking experience. This number stresses the fact that the hospitality industry, which includes hotels and motels, but also business, casinos, amusement parks, cruises and other tourism-related events, is a known sector for both sex and labour trafficking activity. This week’s post looks into some of the reasons why and the solutions that can be put in place to make the hospitality industry a less welcoming option to traffickers.

When it comes to trafficking, hotels, motels & casinos are a favorite location for the facilitation of sex trafficking activity because they provide traffickers a sense of anonymity and privacy. Common tactics used by traffickers to disguise the illicit activity can include selecting larger hotels with busy staff, using third party booking sites, or reserving the room in the victim’s name and paying cash. Although these establishments might have a hard time identifying potential victims, they can nonetheless be held accountable for what happens on their property.

Hotels and other hospitality businesses can be held liable under provisions in the Criminal Code if staff knowingly permit someone under the age of 18 onto their property for the purpose of engaging in commercial sexual activity, i.e. sex trafficking. For instance, in the United States, there have been a number of high-profile civil suits brought by survivors of trafficking who ascertain that the hotels knowingly turned a blind eye to their exploitation and thus, actually profited from their exploitation. While there hasn’t yet been this type of class action in Canada, it is not outside of the realm of possibilities.

Human trafficking can also happen in the hospitality industry in the form of labour trafficking. In 2019, 43 foreign nationals were identified as victims of labour trafficking who had been deceived and forced to work for a cleaning service at hotels across Ontario’s cottage country. In this particular case, the victims were exploited by a third-party sub-contracting business and the hotels in which they worked had no knowledge of the abuse taking place.

Individuals who are exploited in the hospitality industry for forced labour are often brought to Canada under various work visas to fill labour shortages for housekeeping, front of house staff, maintenance and bar and restaurant personnel. If you would like to know more about the inherent risks linked to Temporary Work Visas in Canada, we invite you to read this blog post.

The hospitality industry must therefore do its due diligence when utilizing subcontractors and recruiters to ensure they are not unknowingly contributing to the exploitation of others. Hotels and other hospitality businesses must also be aware of the potential for human trafficking in the supply chain of goods and products they purchase, including coffee, hotel linens and other equipment. Bill S-211, an Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act will come into force on January 1, 2024, and will require certain Canadian businesses to meet reporting and compliance obligations to ensure they are taking the necessary steps to remediate forced labour in their supply chains.

That’s why, for all the above-mentioned reasons, it is so important for the hospitality industry to ensure they are taking steps to deter sex trafficking on their properties and human trafficking in their labour supply chain. Hereunder, we have listed a few suggestions that could help the hospitality sector address human trafficking.

Discover what the hospitality sector can do today to address human trafficking

Below are some practical suggestions for ways that hotels, motels, casino’s and other industry vendors can address this issue:

  • Do yearly education and awareness training for all staff (front and back of house) that goes beyond the key indicators of trafficking, but also provides staff with important contextual information and considerations.
  • Post the Canadian Human Trafficking Hotline number in high traffic places for both employees and guests (i.e. break rooms, lobby restrooms, front desk, elevators and on door hangers).
  • Consult those with lived experience to ensure your establishment adopts public, person-centered polices and procedures that articulate your commitment to this issue and the steps being taken to address it.
  • Ensure you have clear policies and reporting guidelines for employees should they suspect trafficking activity on the business property, within the workforce or in the supply chain.
  • Develop employment skills training programs for survivors which provide pathways to legitimate employment.
  • Make your establishment less trafficking friendly, i.e. have an in-person check-in for all reservations which require identification and a credit card for payment, not cash.
  • Donate rewards points or vouchers to local charities or partner with local anti-trafficking organizations and/or shelters to provide emergency housing when shelters are full.
  • Provincial governments should look to mandate that all employees are properly trained, that establishments keep track of transactions and post the Canadian Human Trafficking Hotline number publicly as a part of their licensing process.