Break the system

As someone who knows the hotel industry, I can tell you that collaborative efforts are the only way we will be able to make any real impact on the risk of modern slavery within our sector.

The industry is vast and multilayered. Shiva Hotels made a public commitment to tackle human trafficking and modern slavery in 2016, after which it rolled out practical training materials and tools across its business, and put in place policies and protocols that sought to cover everything from hiring to remediation.

Yet we know that as just one owner in a complex matrix that includes management companies, brands, recruitment agencies and suppliers, among many others, we cannot tackle it alone.

In November 2016, Shiva Foundation hosted a roundtable discussion in partnership with Thomson Reuters Foundation. We brought together key players within the hotel industry for an open discussion about each of our experiences, the challenges we faced and good practice we were implementing. The conclusion was clear: to tackle this problem we needed to collaborate and facilitate communication between the complex layers of the industry.

As a result of these discussions, the Stop Slavery Hotel Industry Network was founded – the first ever industry-wide body that brings together corporate and operational levels to tackle modern slavery.

We were adamant that the group be action-oriented and practically useful. As an industry that employs one in ten people in the world, we reach almost everyone in one way or another.

For this reason, we are asking all key stakeholders, whether government, business, civil society or consumer, to get involved in this fight. As an industry we are working hard to address the issue, but to truly make an impact, collaboration must extend further.

The UK Government has identified modern slavery as the greatest human rights issue of our time. Fuelled by the demand for cheap labour, the human trafficking market is formed of global networks of criminals that are deeply embedded in the global economy.

The International Labour Organization estimates that there are 40.3 million people trapped in forced labour worldwide. Of those, 21 million are victims of labour exploitation and a quarter of all modern slavery victims are children.

From the very beginning, the network set itself a challenge: can it attempt to tackle this problem collectively, challenging the industry status quo? As a result, a number of recommendations for groups at any stage have been elucidated.

Firstly, know what you don’t know. In name and ethos, collective action is about taking action – and it can be tempting to embark on a collective plan immediately. However, ensuring challenges and context are clear is a critical first step.

Issues that rely on an individual company to make change, such as staff training, don’t require the agreement and cooperation of multiple stakeholders, whereas others, such as dealing with a shared supply chain, might. After prioritising a number of different issues, the group honed in on two key challenges most member companies were individually facing: recruitment and retention of staff, and communicating reputational risk.

The core commonality between both of these is that they deal with the supply of people and goods into hotels, and the risks they bring. With this understanding, addressing slavery in the supply chain became the network’s core focus.

A need for clarity

To address the multilayered, often opaque roles and responsibilities along multiple actors, the network undertook a RACI (responsible, accountable, consulted, and informed) exercise, a tool used to break down complex processes with multiple stakeholders and clarify the roles of each actor, step by step.

We looked at three activities identified as particularly challenging with regard to supply chains: recruiting subcontracted staff through a third-party agency; contracting to construct a new property; and procuring goods.

By understanding when and how to consult and inform each other, the network developed a clearer understanding of how members could better work together to address challenges quickly, or spot global trends or risk indicators. Ensuring that expectations among business partners are clear and that roles in the process of contracting suppliers are defined can go a long way to ensuring risk is minimised throughout the entire process.

Our discussions also highlighted the value of having a safe space where company representatives could come and speak honestly and generally about where their challenges lie. Often professionals focused on modern slavery may be the only person, or one of a small team, working on these issues within a much larger company. There is significant value in learning from others in the industry in a non-judgmental environment. Furthermore, working and taking action collectively can remove the risk of one company going it alone and reduce worries about sharing too much with the competition.

Ten steps for change

One key learning of the network’s first phase was that there is much that collective action can accomplish, but to truly tackle the issue of slavery, action must occur far beyond the walls of a boardroom: government, industry bodies, unions, media, civil society and customers themselves all have a role to play in the fight:

1. Strengthen leadership from industry membership bodies: advocate for change within companies and governments on slavery

When industry bodies marshal the forces of their members to create change, the results can be staggering. The Consumer Goods Forum provides a stellar example of how a group of collaborators and competitors in the same industry can come together to produce simple, strong and forceful standards on slavery that resonate with CEOs and CSR leaders. The network calls on the industry bodies within the hospitality and hotel sector to work towards creating a focused working group on slavery in the industry, particularly one that engages smaller hotel companies and includes their voices. Collective advocacy has already demonstrated its ability to create change in other spaces – it is time to come together and do the same on this critical issue.

2. Stronger, targeted action from labour market regulators

Licensing labour providers has been demonstrated to work in tackling labour abuses in other industries, such as the Gangmasters and Labour Abuse Authority’s licensing scheme for businesses that provide workers for the fresh produce supply chain. Done properly in consultation with the industry and enforced accordingly, regulation can help move progress along more quickly and ensure labour providers are meeting basic guidelines around slavery and trafficking.

3. Engage models that share responsibility across brands, managers and owners

In the network’s RACI exercise, participants identified inherent challenges in the way liability is distributed among the numerous actors in one particular property. For example, when a property or construction project seeks suppliers or contractors, brands are rarely involved. However, when a problem arises, it is usually the brand that faces the greatest public reputational risk. Shared accountability could mitigate this risk, address challenges more quickly or spot global trends.

4. Change the discourse: instead of thinking about the risk involved with addressing slavery head on, consider how it could be an opportunity

Slavery and other human rights issues tend to sit firmly in the risk department of most companies. However, some have found success in tackling the problem head on, and sharing that progress with their clients and customers. Guests in most hotels already see a company’s environmental or sustainability policies on display; why not showcase their work on human rights? Shiva Hotels worked with one of its London properties to develop a commitment that could be shared publicly. “This has acted as a motivator and actually a point of pride for many of the staff and even for guests too,” says Nishma Jethwa, innovation and strategy lead for Shiva Foundation. “We even received a positive review on TripAdvisor noting the messaging as a highlight of the guest’s stay.” Shiva Hotels’ commitment is currently displayed in the lobbies of each of its properties.

5. Make slavery a cross-functional issue and develop a broad approach within a company

Diverse business units including HR, procurement, finance, legal and communications all have roles to play in the fight against slavery – yet it is often a CSR person working on the issue alone. One network member has created a cross-functional working group to come together quarterly to discuss their work and these issues. The group requires senior level membership or support from the highest levels in the company in order for it to be sustainable and effective. Each function should have a clear understanding of its own role in the process and its responsibility to communicate this within its own function. Most companies use crossfunctional committees to manage risks like bribery, corruption and money laundering. Treating slavery as a priority will help spot trends, gaps and create a better working environment.

6. Foster relationships with law enforcement and victim support in advance of an incident, to ensure timely and thoughtful remedy protocols

Local police and victim support providers can be strong allies if an incident occurs. Relationships should be built early and maintained often. These advisors can input into an internal incident reporting protocol, ensuring it is victim-centred, in line with national practice, and is clear and simple to follow.

7. Reframe the conversation about incidents

Incidents of slavery are devastating when they occur; historically, the natural inclination of some companies was to run from them. This is already changing, with many companies shifting to take ownership and responsibility, and working to remedy the situation. Increased reporting of incidents is immediately assumed to be bad – but it doesn’t necessarily mean slavery is increasing. On the contrary, companies can use the fact as reassurance that their policies and processes are working.

8. Put transparency at the forefront – even when it’s not mandatory

One of the network’s first activities was to compile a resource hub featuring standards and best practice guidelines. Drafting the framework meant members had to input on their own policies and practices. We encourage sharing of materials, even among companies who could be considered competitors, as they can be integral towards creating collective solutions. The Modern Slavery Act requires large companies to report on their efforts they are undertaking to address slavery in their supply chains. Smaller companies, even those under the reporting threshold, should also be sharing with their stakeholders how they are working to combat these challenges. By being open and honest with successes and challenges, companies can ensure solutions are shared more quickly, pitfalls are avoided and collectively their efforts are more effective.

9. Leverage and understand the value of purchasing power on creating change in supply chains

Increasingly, large and small companies across industries are coming together to leverage their collective purchasing power to make changes in their supply chain. Some good practice in recent years, spurred on by the reporting requirements of the Modern Slavery Act, has trickled down to suppliers – but these efforts are not happening fast enough. Companies could be doing more to share data on responsible suppliers, rewarding those who address the issues of slavery head on. Beyond the corporate sector, government has a great deal of power to address slavery through its own procurement of hotel rooms and other hospitality needs. With widespread purchasing power in the industry, if the government asked about companies’ responses to modern slavery in its requests for proposals, there could be far-reaching effects throughout its own supply chain.

10. Collaborate: more often, more honestly and with more organisations

Countless networks have been created among peers within industries in the for and not for profit sectors to address many intractable issues, but most have been challenged on moving from discussion to output and action. Bringing together diverse actors with multiple priorities, exceedingly full schedules and different lines of accountability is a significant barrier to creating collective action. Yet this is the only way change can truly be achieved. It is not only the responsibility of companies and civil society to join together. The network has demonstrated that progress can be made in a small group of like-minded companies, but there is much more to be achieved. Government has a leading role to play in bringing key actors together – not just companies, but regulators, civil society, elected officials, unions, media, hospitality colleges and others. By offering to facilitate these conversations, the scale of collective action could be multiplied.