Risk UK, a monthly magazine specifically aimed at security and risk management, loss prevention, business continuity and fire safety professionals operating in the UK‘s largest commercial organizations, dedicated their February cover to human trafficking, under the headline “Slavery in the Modern Age − Human Trafficking and the ‘Invisible Risk'”.
COMBAT team member Alexandros Paraskevas, Professor of Strategic Risk Management at the London School of Hospitality and Tourism, University of West London, addressed the issue in a two-page article, describing the risk of modern slavery −focusing on the hospitality industry−, and the remedies brought by a project such as COMBAT.
The nature and necessities of modern slavery, namely the requirement for continuous movement, temporary accommodation and supply of low cost products and services, put hospitality businesses (hotels, restaurants, catering companies, etc.) in a high level of exposure but at the same time in a unique position to identify and combat this criminal activity. These businesses are often accused for ‘turning a blind eye’ to human traffickers by outsourcing their cleaning and catering services to dubious sub-contractors; allowing sexual trafficking in their premises; employing migrant workers without appropriate due diligence, buying products produced by forced or bonded labour, labour exploitation or violation of labour rights; or by simply ‘not noticing’. The reported numbers of modern slavery victims in the sector appear to be low. In 2013, in the UK, 1% (7 victims) of forced labour victims referred to services came from the restaurant or bar sector, and 41% of victims were trafficked for sexual exploitation, with 4% (44 people) sexually exploited in hotels. But it is a common ‘secret’ that traffickers merely take advantage of the privacy and anonymity offered by these businesses and they are able to operate through them at low risk.
Taking a more risk-based approach, a consortium led by Oxford Brookes University with the collaboration of the London School of Hospitality and Tourism at the University of West London, the Ratiu Foundation for Democracy in Romania and the Lapland University of Applied Sciences in Finland was funded by the European Commission to develop a training toolkit to help the the hospitality and wider tourism sector to combat human trafficking. The consortium is supported by an advisory board consisting of personalities nationally and internationally renowned for their expertise and activity against human trafficking.
This two-year development project started last October and, broadly based on the “Three-Lines of Defence” principle, aims at a toolkit that will provide training and guidance at three different levels: operational (on the field), tactical (management support) and strategic (board-level policies and practices). The training will not be only about awareness and detecting signals of human trafficking but also about action that will take into consideration the business perspective as much as the law enforcement and the victims’ perspectives. So, at operational level, say in a hotel, it will move from detection to verification with the help of experts and reporting (not only through management structures but also through anonymous disclosure line), evidence collection and/or preservation for effective prosecution by law enforcement and immediate (as well as possible long-term) victim treatment – before police and social workers arrive. At tactical (management support) level, the training will include proposals on developing company-wide policies and procedures as well as support mechanisms (e.g., anonymous disclosure from units, as there is a possibility that individual managers or even owners are involved in trafficking) that go beyond everyday operations also in the the supply chain (e.g., vetting agents providing outsourced cleaning crews, key suppliers of linen or fresh food products, etc.) and to victims’ rehabilitation through CR programmes. Finally, at board strategic level on policy statements, advocacy and participation on global networks, third party certification, systems auditing procedures, etc.