BEYOND COMPLIANCE
IN THE HOTEL SECTOR:A REVIEW OF UK MODERN SLAVERY ACT STATEMENTS

Minderoo Foundation’s Walk Free Initiative
WikiRate
Business & Human Rights Resource Centre
Australian National University
2019About this report

ABOUT THIS REPORT
Documenting the impact of new legislative acts, and company
responses to them, is an indispensable tool for improving theeffectiveness of legislation and advancing business practice. This is
why Minderoo Foundation’s Walk Free Initiative and WikiRate partneredin 2016 to assess the modern slavery statements produced under the2015 UK Modern Slavery Act. In 2018, we launched the project’s initial
findings to move beyond compliance by providing an analysis of thecontent of the statements being produced, as well as drawing attention
to promising, and less promising, business practice. In doing so, we
aimed to unlock the content of these statements and share the metrics
we developed to assess business activities to combat modern slavery.
The report is available here.
Since January 2019, we have shifted our approach to focusing
on specific sectors. With an estimated 12,000-17,000 UK-based
companies having to publish statements per annum, a sectorspecific approach allows us to provide a more tailored analysis of thestatements and their quality, and to develop recommendations of what
constitutes a strong statement and good business practice. This is thefirst report since we adopted this approach and it focuses on the hotels
sector. The statements assessed in this report are available on theBusiness & Human Rights Resource Centre registry.
Walk Free, WikiRate Australian National University and Business &Human Rights Resource Centre conducted this analysis. Special thanks
goes to Hayley Blyth, Carly-Ann Selby-James, and Daniel Wei-En Kang,
student members of the ANU-Walk Free-WikiRate Modern Slavery
Reporting Project and their supervisor Jolyon Ford, as well as Sydney
Strelau, a WikiRate volunteer. Your engagement and contributions were
essential to this study.

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Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Contents

CONTENTSABOUT THIS REPORT............................................................................... ii
EXECUTIVE SUMMARY.............................................................................2
RISKS OF MODERN SLAVERY IN THE HOTEL SECTOR............................... 8
METHODOLOGY...................................................................................... 13
HOW MANY STATEMENTS?.................................................................... 15
MINIMUM REQUIREMENTS..................................................................... 17
STRUCTURE, BUSINESS & SUPPLY CHAIN DISCLOSURE......................... 18
MODERN SLAVERY POLICIES................................................................. 20
DUE DILIGENCE PROCESSES.................................................................. 22
RISK ASSESSMENT AND MANAGEMENT................................................ 26
EFFECTIVENESS OF THE MODERN SLAVERY RESPONSE......................... 28
TRAINING.............................................................................................. 30
CONCLUSION......................................................................................... 32
APPENDIX 1: LIST OF METRICS.............................................................. 34
APPENDIX 2: HOTELS AND STATEMENTS INCLUDEDIN THIS ANALYSIS............................................................................ 35
ENDNOTES............................................................................................ 39
ABOUT THE AUTHORS............................................................................ 41

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

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Executive summary

EXECUTIVE SUMMARY
The travel and tourism industry continues to see
uninterrupted growth, with more people than everbefore travelling for work or leisure to a broader
range of destinations. Yet this growth brings withit a greater risk of modern slavery.
There is a high-risk of exploitation within the hotel sector due to its
vulnerable workforce, complex supply chains with little transparency,
and limited oversight from brands and multinational hotel companies
as a result of extensive franchising. In the franchising model, hotel
brands lend their name and customer care standards to third parties,
but usually stipulate far less about the standards they expect for theemployment of workers, even in countries where abuse is endemic.
To assess how the hotel sector is responding to these risks, thisreport reviews the statements produced by 71 hotel companies
under the UK Modern Slavery Act, which requires companies with aturnover of £36 million to release annual statements on their antislavery efforts. We looked at whether the statements meet the Act’s
minimum requirements, but also if they go “beyond compliance”
with effective responses to modern slavery risks — including sexual
exploitation, forced labour, and the poor treatment of migrant workers.
This report finds that reporting by hotels demonstrates they are
failing to address the risks of modern slavery in their direct
operations and supply chains. Four years into the Act, we would
expect that hotels, operating in a high-risk sector, would produce moredetailed disclosure and demonstrate a much better understandingof the well-publicised risks in the sector. However, the findings show
a disappointing lack of effort to protect against labour and sexual
exploitation. Tellingly, only a small number of companies explicitly state
the Act has resulted in activities to combat modern slavery. (See Key
Findings).

The hotel
industry as awhole shouldreflect on thespecific risksfacing the sector
and strengthen
partnerships
to share goodpractice

These failures can be explained by a lack of commitment by hotel
companies to prioritise the elimination of modern slavery, and theweakness of the legislation to change corporate behaviour and holdlaggard companies to account.
The hotel industry as a whole should reflect on the specific risks facing
the sector and strengthen partnerships to share good practice. Hotelcompanies should strengthen their due diligence processes to more
effectively identify and mitigate risks to prevent severe exploitation.
They should be more transparent and disclose incidents or risks ofmodern slavery and the steps taken to remedy these.
The UK Government should show greater leadership by strengthening
their requirements for corporate transparency, and holding companies
to account that fail to comply with the law. It should release to the
public a list of those who are required to report in order to facilitate
analysis and enforce the Act against non-compliant companies.

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Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Executive summary

Housekeeping staff are aparticularly vulnerable group
to modern slavery. In 2015,a Guardian investigation
found that when outsourced,
housekeeping staff working
at a London hotel had theircontract taken over byanother company and became
vulnerable to exploitative
working conditions. Theirquotas were changed frombeing paid £6.50 per hour
to clean 13 rooms withineight hours to cleaning 15-17
bedrooms in seven and a half
hours a day. Other workers
were paid piecemeal amountsof between £2.30 and £3.75 toclean each room. Photo credit:
Motortion/Adobe Stock

As mandatory reporting requirements, such as the AustralianModern Slavery Act, and mandatory human rights due diligence areestablished in other countries, it is important that existing legislationis strengthened and enforced. The UK should reform the Act, its
implementation, and enforcement to ensure it regains leadership in theelimination of modern slavery. Without effective implementation anda renewed commitment from business to combat modern slavery,
the estimated 16 million people in forced labour in the private
economy remain at risk.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

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Executive summary

KEY FINDINGSHOTEL COMPANIES ARE FAILING TO ADDRESS THE SPECIFIC RISKS OF
MODERN SLAVERY IN THEIR DIRECT OPERATIONS AND SUPPLY CHAINS.
FEW COMPANIES ARE TACKLING THE SPECIFICRISKS TO MIGRANT WORKERS.
Only 6/71 assessed companies (8%) reported thatworkers do not pay recruitment fees and related costs,
so reducing their vulnerability to debt bondage.

SUPPLY CHAINS IN THE HOTEL SECTOR REMAIN OPAQUE
AND WORKERS IN THEM VULNERABLE.

76%

35%

DID NOT DISCLOSE
SUPPLY CHAIN
INFORMATON

Companies that did neither include
Apex Hotels, Firmdale Hotels, and Parkdean.

DID NOT DESCRIBEDUE DILIGENCE
PROCESSES

EXPLOITED AND VULNERABLE WORKERS ARE NOT
BEING SUPPORTED.
None of the companies’ statements described
remediation plans for exploited workers.

18%

IDENTIFY MIGRANT/AGENCY
WORKERS AS A SPECIFIC RISKFEW HOTELS ARE TACKLING THE RISK OF SEXUAL
EXPLOITATION ON THEIR PREMISES.
ONLY
4

14%

of statements (n=10) reported specificapproaches to dealing with the risk of sexual
exploitation in their operations and supply chains.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Executive summary

ENT

No statement described taking clear and concrete
steps to address all the criteria as set out by the
UK Modern Slavery Act and the accompanying UK
Home Office guidance.

A

K OF COMM
C
A
L
I

TM

THE FAILURE TO ADDRESS RISKS REVEALS ALACK OF COMMITMENT BY HOTEL COMPANIESAND THE FAILURE OF THE LEGISLATION TO
DRIVE CHANGE IN CORPORATE BEHAVIOUROR HOLD COMPANIES TO ACCOUNT.

T

OC

HANGE

NO STATEMENTS COULD BE FOUND FOR
SEVEN COMPANIES, NOR WERE THEY
CLEARLY OR EXPLICITLY INCLUDED IN
A GROUP STATEMENT:
Accor UK Business Leisure Hotels Limited,
Capital Hill Hotels Group London Ltd, Four
Seasons Hotels and Resorts, Indian Hotel
Company, Jumeirah Group, Mandarin Oriental
Hyde Park Ltd, and Sir Richard Sutton Limited.
This is as of 15th November 2019.

The minimum requirements of the Act are thatthe statement was signed by a Director or similarsenior authority, approved by the Board, andplaced on a prominent place on the homepageof the company’s website.

25%

ONLY

OF STATEMENTS METMINIMUM REQUIREMENTS

SIGNED .............................................

ONLY

50%

OF COMPANIES HAVE PRODUCEDMULTIPLE STATEMENTS

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Executive summary

RECOMMENDATIONS FOR HOTEL COMPANIES PRODUCINGSTATEMENTS
Implement due diligence with a focus on sector
specific risks• The hotel sector would benefit from reflecting on the specific risks

associated with:–– Franchising as opposed to risks for managed or owned hotels,–– Migrant workers — including discrimination, barriers to justice,inability to form or join unions, recruitment fees and withholding ofpassports,–– Sex trafficking — especially use of hotels as a site of exploitation,–– Sexual harassment of female employees in hotels, and–– Inadequate national labour laws of many countries that do notenshrine international standards set out in the UN Guiding
Principles on Business and Human Rights.

• Establish due diligence processes that demonstrate duty of care forvulnerable workers to:–– Vet suppliers before entering into contractual relationships,–– Drive continuous improvement with suppliers and third-party
property owners,–– Implement and monitor corrective action plans to address andremedy non-compliance, and–– Engage directly with workers and trade unions, to empower
workers, and learn from their insights on modern slavery in the
supply chain.

Engage in pre-competitive collaboration with peers• Engage with peers to drive higher common standards in operations

and supply chains, such as the International Tourism Partnership andtheir Principles on Forced Labour, the Stop Slavery Hotel Industry
Network, ECPAT’s Code of Conduct, Shiva Foundation’s Blueprint,
and the developing Gangmasters and Labour Abuse Authority’s
hospitality protocol.
Sharegood practice and reflect the likely reality that modern slavery•
affects their hotels and supply chains.

Improve transparency• Disclose specific incidents of modern slavery and steps taken to

remedy these.
• Facilitate analysis of their statements by stakeholders by:–– Clearly stating which legal entities and brands their statement
applies to,–– Including the financial year to which it refers and the date stampof when the statement was produced, and–– Providing historic records of their statements to facilitate yearon-year review.

• Review the UK Home Office guidance and requirements of the Act toensure they are meeting the minimum requirements.

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Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Executive summary

RECOMMENDATIONS FOR UK GOVERNMENT• Publish a list of companies required to report under the UK Modern

Phuket, Thailand, 23rd
August 2014. A migrant
worker carrying somecushions at a hotel in
Phuket. Every year
hundreds of tourists
come to Thailand.
But in the shadow ofmass tourism, there
is a different reality.
Reporters have foundserious grievancesamong migrant workers
in hotels used by tourists.
Photo credit: Jonas
Gratzer/LightRocket via
Getty Images.

Slavery Act.
• Create or nominate a body to monitor corporate compliance with
the UK Modern Slavery Act similar to the business engagement unit
created by the Australia Modern Slavery Act to:–– Assist companies on how to undertake robust due diligence, and–– Produce better disclosure and higher quality statements.
• Bring the Registry of corporate compliance statements into the UK
Home Office, or similar government department.
• Implement its principles for nations to tackle modern slavery insupply chains (developed alongside the US, Australia, New Zealandand Canada) and encourage business by:–– Setting clear expectation for the private sector on their
responsibility to conduct appropriate due diligence,–– Provide tools and incentives to the private sector to encourage
meaningful action and public reporting of their efforts including
through programmes, policies or legislation, and–– Publish sector-specific guidance that addresses risks by region
and workforce.

• Enforce the Act against non-compliant companies through the

injunction mechanism set forth in the Act and consider financial
penalties as recommended by the Independent Review.

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Risks of modern slavery in the hotel sector

RISKS OF MODERN SLAVERY IN THE
HOTEL SECTOR
The travel and tourism industry continues to grow.
International tourist arrivals have shown
uninterrupted growth from 25 million in 1950 to a
predicted 1.8 billion by 2030.1 The industry is
becoming increasingly important for socio-economic
development, particularly for emerging markets, due
to the increasing diversification in the places tourists
visit.2 The hotel and hospitality sector employs 292
million people worldwide (one in 10 people globally)
and contributes 10.2 percent of global GDP.3
Given this growth, it is vital that the industry, and specifically the hotel
sector, address the risks of modern slavery. In 2016, there were an
estimated 40.3 million people in modern slavery. Of these individuals,
16 million were in modern slavery in the private sector,4 some of whomare exploited in hotels directly or in the production of goods andservices in hotel supply chains.
There are three risk factors 5 which make the hotel industry susceptible
to modern slavery:

1. Staff employed directly or indirectly becoming victims of forced orHotels are at
risk of modern
slavery due toa vulnerable
workforce,complex supply
chains, andlimited brandoversight

bonded labour
Hotels employ those who experience more structural disadvantages
to accessing the market — women, young people, rural populations,and migrant workers,6 and, in some countries, members of minority
communities — who are also the groups at risk of exploitation andmodern slavery. These risks include charging of recruitment fees,
contract deception, withholding or reduced wages and benefits,retention of identification documents, and poor worker living
accommodation.7 A recent media report in Australia found that workers
at a luxury hotel group were threatened with legal action and fines ifthey spoke to the media following revelations that migrant workers
were being charged overpriced rents, with no option to find their own
accommodation, and working up to 12 hours a week as unpaid overtime. 8
Similar reports were found in Scotland, where Bangladeshi workers
were trafficked with promise of a new life and high salaries working inrestaurants, but ended up exploited in a remote hotel, 9 while a studyof reported trafficking cases identified in the US hotel sector foundinstances of wage and working hour abuse, contract fraud, wrongfultermination, discrimination, unsafe or unsanitary working conditions,and verbal abuse.10

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Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Risks of modern slavery in the hotel sector

HOTELS MUST
ADDRESS THE SPECIFICRISKS FACING THE
SECTOR AND THE UK
GOVERNMENT MUST
ENFORCE THE MODERNSLAVERY ACT AGAINSTNON-COMPLIANT
COMPANIES

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

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Risks of modern slavery in the hotel sector

Those working in small and medium-sized enterprises, in particular,
experience low union density, low wages, low levels of skill
requirements, shift and night work, and seasonality. These individuals
are often women, representing some 50 to 70 percent of workers inthe sector, who are additionally subject to poor working conditions,inequality, stress, and sexual harassment.11
Beyond direct employees, hotels are associated with taxi andbus drivers, restaurant suppliers, tourist guides, and cleaning andhousekeeping staff, among others. Many of these jobs are characterisedby challenges such as long working hours, comparatively low pay,
informality, and increased competition. For example, in 2015, a Guardianinvestigation found that when outsourced, housekeeping staff working
at a London hotel had their contract taken over by another company
and became vulnerable to exploitative working conditions. Their quotas
were changed from being paid £6.50 per hour to clean 13 rooms withineight hours to cleaning 15-17 bedrooms in seven and a half hours a day.
Other workers were paid piecemeal amounts of between £2.30 and£3.75 to clean each room.12 As a result, workers were under pressure to
do more work in less time for less pay, while the hotel they were cleaning
was not held responsible for these exploitative conditions.

2. Use of hotel premises for forced sexual exploitation of adults andchildren.
Hotels can also be the venue or transit location for forced sexual
exploitation of adults and children. In the US, there are reports of third
parties renting rooms, “selling” victims, forcing victims into sexual acts
for financial gain, or having victims meet potential clients in hotels.13
A 2015 report by Polaris identified 1,434 cases of trafficking in hotels
and motels in the US between December 2007 and February 2015.
From these cases, 1,867 victims were identified, 92 percent of whom
had experienced sex trafficking, five percent labour trafficking, andtwo percent had experienced both. Ninety-four percent were female.14

3. Products and services used by hotels being produced by forced orbonded labour, labour exploitation, or unethical labour practices.
Hotels have complex supply chains, which, like all supply chains, arevulnerable to forced labour. Larger hotel chains often have centralised
procurement processes to negotiate global agreements for certain
products, which are provided to all markets where the hotel brandoperates. These products tend to be those with long shelf-lives, andthose that can be shipped or manufactured worldwide and in highvolume. Regional or local arrangements are made for perishable
goods and low volume or one-off products.15 Informal relationships
between suppliers and hotels at the local level may not be subject tocontracts, but are more ad hoc, temporary, or seasonal arrangements.
Outsourced services, such as cleaning, housekeeping, and agency
labour also tend to be negotiated locally. A heightened level of due
diligence is needed to monitor and enforce high labour standards given
the complex web of supplier relationships.

10

In the US, there
are reports ofthird parties
renting rooms,“selling” victims,
forcing victims
into sexual acts
for financial gain,or having victims
meet potential
clients in hotels

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Risks of modern slavery in the hotel sector

A DIVERSE AND FRAGMENTED SECTOR
There has been a shift away from owned and operated hotels in recent
years (see figure 1); increasingly, brands operate fee-based businessmodels through management contracts and franchising, with estimatesthat less than 10 percent of hotels are owner-operated.16 Eighty percent
of hotels in the top 10 multinationals are franchises, which has led tolarge brand hotels becoming “marketing companies” and distanced
from the hotel supply chain. This fragmented nature exacerbates
known risks, making it difficult to determine who is responsible forrespecting the rights of workers, with overlapping responsibility
between hotel companies, third-party property owners, and suppliers.17
This does not however diminish their responsibility to prevent
exploitation of workers; the largest companies include portfolios that
contain more than 6,000 hotels each and employ more than 150,000
employees in up to 100 countries.18
Figure 1: Four types of hotel ownership and risks 19

Type

Description

Risk

Owned and
operated

Gives the multinational hotel greatest level of control
over the business. Brand owner makes decisions
on staff, operational structure, and growth, andnegotiates all supplier agreements and contracts.

• The multinational is directly responsible

Leasedproperties

Similar to owned and operated, but the hotel building
is leased from someone else, often on a long lease.
Exposure to modern slavery is similar to owned andoperated types.

• The multinational is directly responsible

Managedproperties

Hotel continues to be privately owned, but themultinational lends its brand name and takes over
the overall operations, becoming the managementcompany. Suppliers are negotiated by the
management company, but contracts rest with owner.

• Level of direct risk is theoretically reduced.
• However, the multinational has limited

Privately owned and usually operated by hotel
owner or representative. Hotel pays an upfront fee
to purchase the brand franchise and pays ongoingroyalties.

• Level of direct risk to the brand isFranchisedfor ensuring that modern slavery does notoccur in operations, at the hotel or in supply
chains.
• Greatest direct exposure of the brand tomodern slavery.
for ensuring that modern slavery does notoccur in operations, at the hotel or in supply
chains.
• Greatest direct exposure of the brand tomodern slavery.

oversight over contracts, which could leadto increased risk.

theoretically reduced.
• Establishing responsibility is complicated.
• Regardless of responsibility, hotel brandrisk could be increased due to contradiction
between hotel brand and owner ethics, ordue to limited oversight.

The level of risk of modern slavery is high in the franchise model.
It can be difficult for the franchisor to ensure that no modern slavery is
occurring in the supply chains of their franchisee. 20 Franchisees may
not share or implement the franchisor’s ethical standards and practices
and/or be based in regions where the rule of law is weak or modern
slavery is more prevalent. There are difficulties in sharing risk andresponsibility for labour abuses in a franchisees’ operations and supply
chain. For example, a franchisor may not wish to exert control over a
franchisee so that it becomes liable for what occurs in the franchisees’
operations.

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Risks of modern slavery in the hotel sector

The UK Home Office guidance explicitly states that it is the annual
revenue of a franchisor that determines whether it meets the criteria
to publish a modern slavery statement under Section 54 of the UK
Modern Slavery Act and that the turnover of franchisees should not
be used to calculate the franchisor’s revenue. Contrast this with theapplicability of the Act to parent companies, whereby turnover iscalculated through the sum of all subsidiaries’ revenue. By not coming
within the scope of the legislation, hotel companies may be incentivised
to franchise. However, taking this “arms-length” approach can increase
the risk of modern slavery occurring. This distinction can also become
meaningless when instances of modern slavery occur in a franchisethat are automatically associated with the franchisor and its brand,causing reputational damage, regardless of their legal liability. 21
The hotel sector in specific regions is particularly vulnerable to modern
slavery. A recent report by Business & Human Rights Resource Centre(the Resource Centre) highlights how international hotel companies
operating in Qatar and the United Arab Emirates are underprepared
to prevent and remediate the human rights risks migrant workers face.
This is further complicated by the Kafala (sponsorship) system, whichleaves migrants workers tied to potentially unscrupulous employers. 22
In the report, 70 percent of the hotels in the assessed international
companies’ portfolios that responded to the Resource Centre survey
operated as managed hotels, with employment contracts governedby third-party hotel owners. Therefore, responsibility for the rights of
subcontracted workers in these properties were fragmented, making
it more difficult to apply companies’ human rights policies. The reportfound that migrants working in hotels were vulnerable to labour
abuses including the payment of exorbitant recruitment fees leading
to debt bondage, restrictions on freedom of movement, and lack ofovertime payments. 23 Despite reforms to the Kafala system, and anannouncement in October 2019 that the system will be abolished, 24 areport by the Guardian revealed migrant workers at a luxury hotel in
Qatar paid high recruitment fees, worked three or four months withouta day off, faced fines for falling asleep while on duty, and were paid
below minimum wage. Security guards endured 12 hour shifts outdoors
in temperatures that can reach 45 degrees Celsius but earned little
more than £8 per day. 25

The distinction
betweenfranchisor andfranchisee
can become
meaninglesswhen instancesof modernslavery occur

In sum, the risks of modern slavery are high within the hotel sector due toa number of factors including vast, diverse and complex supply chains,
the fragmented nature of franchising, the use of localised, informalpurchasing agreements, seasonal and temporary working arrangements,and limited brand oversight. Despite these challenges, a strong caseremains for action against modern slavery by the hotels sector beyond
the moral obligation of preventing the exploitation of 40.3 million people
in modern slavery. Investor groups are increasingly asking questionsof a company’s anti-slavery activities. Adopting ethical practices canbuild staff morale and operational efficiency, while strong prevention
and mitigation efforts could alleviate very serious consequences for acompany’s reputation and business when cases of modern slavery are
uncovered. 26 Governments are also increasingly legislating on modern
slavery, such as the UK Modern Slavery Act, 27 and the Australian Modern
Slavery Act, 28 which require businesses to disclose how they respond to
the risk of modern slavery. There are multiple incentives for the hotels
sector to take action to tackle the serious risks of modern slavery in theirdirect operations and supply chains.

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Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Methodology

METHODOLOGY
WHAT IS THE UK MODERN SLAVERY ACT?
Under Section 54 of the 2015 UK Modern Slavery Act, a commercialorganisation that has an annual turnover of over £36 million and with
operations in the UK must publish a slavery and human trafficking
statement each financial year. The statement should set out the steps
the company has taken to ensure there is no slavery or trafficking in
its supply chains and its own business, or state that it has taken nosuch steps.
The legislation does not prescribe what these statements should
include, but provides suggestions that the statement describe businessstructure and supply chains, relevant policies, due diligence processes,
risk assessment and risk management mechanisms, training programs,
and the means by which the company measure the effectiveness ofthese approaches. Guidance issued by the UK Home Office provides
additional support for companies.

The project
employs a
citizen science
approach,working with
universities
around the world,
to review andassess over
900 statements

HOW IT WORKS
Using the suggested content under Section 54(5) of the legislation andthe accompanying UK Home Office guidance, Walk Free and WikiRate
developed 18 metrics (see Appendix 1) through which non-expert
researchers could assess not only whether the statements meet theminimum requirements of the Act, but also if they detail policies andactions that go “beyond compliance” and enable businesses to improvetheir responses to modern slavery. After some initial testing and refining
in collaboration with the University of Columbia, the project employed acitizen science approach to review and assess over 900 statements.
This report reviews statements produced by the hotel sector, which wereassessed by students at Australian National University and the WikiRate
volunteer community. Beyond the 18 metrics, the project included
tailored metrics to assess disclosures specific to the hotel sector, forexample, assessing company responses to the risk of sexual exploitation.
We partnered with the Resource Centre who have extensive experience
analysing modern slavery reporting and who provided sector-specificinput related to the treatment of migrant workers.
To ensure the integrity of the data, every metric answer was reviewed
by two ANU researchers. These researchers had the ability to request
expert reviews of any ambiguous data, which were subsequently
checked by the WikiRate team. All data gathered under the minimum
requirements metrics and over a third of all other data were validated by
WikiRate and Walk Free to ensure at least 90 percent data accuracy. 29
Using WikiRate’s export functionality, the data set was then analysedto establish disclosure patterns. This analysis and its methodology areavailable online: https://wikirate.org/Source_000089615.

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Methodology

WHICH STATEMENTS WERE IN SCOPE?
A total of 78 companies and 128 unique statements were reviewed
covering the reporting period of 2016 to 2019. Seven of the 78 companies
reviewed did not produce any statement at all.
Shifting to a sector-specific approach to analysing the statements
required that we define the companies in scope of this project.

Figure 2: Criteria used to identify companies and statements• A minimum of five letting bedrooms.
• A dining room, restaurant or similar eating area serving evening meals at least five days a week (but hotels that do notoffer dinner and are located within easy walking distance of a choice of places to eat dinner, can also be rated under
the hotel scheme as a metro or town house hotel, as long as this is made clear to all prospective guests in all marketing
and all other hotel requirements are met).
• Hotel generally open seven days a week during its operating season.
• Proprietor and or staff available during the day and evening to receive guests and provide information, services suchas hot drinks and light refreshments.
• A clearly designated reception facility.
• Meeting all the current statutory obligations and providing Public Liability insurance cover.
• Servicing of rooms seven days a week (this includes linen/towel change, removal of rubbish and cleaning).
Types of hotels included:• Inn.
• Holiday Park.
• Resort.
• B&B.

The starting point was the statements housed on the Modern Slavery
Registry and tagged as hotels, restaurants, and leisure. Any non-hotels
were removed from this list after a review of their websites to ensure
they met the selection criteria.
We periodically checked for statements for the seven hotels which we
believe should have produced a statement and have yet to do so. The
cut-off date was 15th November 2019, when statements had still notbeen found. While we have tried to be comprehensive, the fragmented
nature of the hotel sector means that inevitably there may be some
hotels that were in scope that we have missed. We welcome any hotels
that should be included to share their statement with the Modern
Slavery Registry.

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Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

How many statements?

HOW MANY STATEMENTS?
The legislation states that companies should releasea statement for each financial year.30 However,
40 percent of the companies assessed (n=31)
published only one statement over the 2016-2019
period.

Figure 3: Number of statements by
year (/128)
60

55
50

40

34
30

25
20

14
10

0

2016

2017

2018

2019*

Number of statements* The reduction in 2019 likely relates to publication lag as thisanalysis was complete as of August 2019.

Figure 4: Number of companies
producing multiple statements since2016 (/128)
7
17

Company income fluctuates over time so companies may not havereleased a statement because in certain years they did not meet the£36 million p.a. threshold, rather than not being compliant with thelegislation. Where there are gaps in reporting, it is not currently possible
to distinguish between non-compliance or not meeting the threshold.
While the UK Modern Slavery Act defines which companies have to
produce a statement, the UK Government has not published a list ofcompanies caught by the Act, leaving companies to determine if thelegislation applies to them. The UK Home Office does have a list ofcompanies in scope of the legislation, but it is not currently public. 31
Encouragingly, the number of statements produced by the hotel sector
has increased each year since 2016, which was the first reporting year
for companies under the Act. These statements have been tagged byyear according to the following logic: either the year that the statement
applies to is specified in the statement, or the tagged year refers to theyear in which the statement is found.
Over 50 percent of companies (n=40) reviewed have produced two or
more statements since 2016. InterContinental Hotels Group, Millennium
Copthorne Hotels, Shearings Leisure Group Limited, and VUR Village
Trading No 1 Limited have released three statements to date. However,nearly 10 percent (n=7) of companies which meet the requirementsof the Act had not released a statement at the time of this analysis orwere not clearly or explicitly included in a group statement: Accor UK
Business Leisure Hotels Limited, 32 Capital Hill Hotels Group London
Ltd, 33 Four Seasons Hotels and Resorts, 34 Indian Hotel Company, 35
Jumeirah Group, 36 Mandarin Oriental Hyde Park Ltd, 37 and Sir Richard
Sutton Limited. 38

31
23

0 statements
1 statements
2 statements
3 statements

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

15

How many statements?

CHANGE OVER TIME
Measuring a company’s progress over time is an important part ofmeasuring the impact of the legislation, and we did hope to showchange over time by comparing the action taken by the sector as awhole in 2019 as compared to 2016. However, this was made impossibleby the multiple factors listed below.
In order to compare company reporting fairly, we have only reviewed
a company’s most recent statement, bringing the total number ofstatements reviewed in this analysis to 71. A full list of the reviewed
companies and URLs to the statements can be found in Appendix 2.

1. Companies are not reporting on the same time period. Section

54 of the UK Modern Slavery Act states that the annual statement
should cover each financial year for the organisation. However, thereporting period differs per company, with some reporting for April
to April and others reporting per calendar year. It is therefore notpossible to directly compare the content of the statements.

2. Companies do not specify which financial year their statement

applies to within the statement. Guidance by the UK Government
says statements should include the date of the company’s financial
year end, yet they often do not include dates and merely say thestatement applies to the current financial year. This makes it
impossible to know if this is the current statement or an out-dated
version that has not yet been updated. Examples of this included thestatements produced by The Celtic Manor Resort, Grange Hotels,
Harbour Hotels, Dorchester Hotel Limited, and The Goodwood
Estate Company Limited.

It is not currently
possible to showchange overtime for thesestatements

3. Statements contain contradictory dates. One statement may referto different years and reporting periods within the same statement.
Examples included statements produced by Shearings LeisureGroup Limited, Soho House Holdings Limited, and Travelodge.

4. Historic statements could not be found. Often as statements are

released, they replace previous versions online. The number ofavailable historic statements is minimal, despite UK Home Officeguidance that companies make statements from previous years
available online. 39 Only seven companies have a historic archive of
their statements on their website, namely Center Parcs Limited,
Greene King, Hilton, InterContinental Hotels, Millennium Copthorne
Hotels, Shiva Hotels, and TUI.

5. Statements covering different years report the same information.
Statements covering differing years appear to be the same, but withan updated date. Others appear to be the same, but have removed
dates from later versions of the same statements. It is therefore
unclear if the statement is still relevant. Arora Hotels is one example
that has almost identical statements covering multiple years.

6. Multiple statements are available for the same year. Some companies
make edits to their statements after it is published. A statementfrom the same year can have multiple versions, which means that theassessment differs based on when in that year it is reviewed.

7. Statements can cover future financial years. There were

instances when statements stated that they covered the next one or
two years. While companies are encouraged to include their plans
for the future, the legislation requires they report on the steps taken
during the previous financial year. J D Wetherspoons states that
their statement published in July 2018 covers the period 2018/2019.

16

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Minimum requirements

MINIMUM REQUIREMENTS
Sections 54(4)(6) and (7) describe the minimum
requirements for the UK Modern Slavery Act
statements. According to the type of organisation,
the statement must be signed by a Director or similarsenior authority, and must be approved by the Board.
If the organisation has a website, a link to thestatement must be placed in a prominent place on
the website homepage. 40

Figure 5: Number of statements thatmeet minimum requirements (/71)

18

53

Of the 71 statements assessed, only 25 percent (n=18) met minimum
requirements. Although additional guidance was published in March
2019 stating that the statement did not have to be physically signed,
we have applied the standard as outlined in the Home Office guidance.
This low level of compliance is similar to other reports reviewing thestatements.41 Current compliance on the Modern Slavery Registry
is 23 percent.42

Yes
No

We would expect to see a much higher rate four years after the
Act came into force. Placing the statement on the homepage of acompany’s website was the most commonly executed component of
the legislation, followed by signature by senior authority and explicit
approval by the Board.

Figure 6: Number of statements
describing components of legal
compliance
80

70

71

RECOMMENDATIONS
60

To meet the minimum requirements of the Act, the hotels sector mustensure the statements are:• Signed by a Director or similar senior authority,• Explicitly approved by the Board, and• Made public by placing it on the company website and linking to it ona prominent place on the website homepage.

50

46
40

36
30

20

29
18

10

0

Total
Home
numberpageof statements link*

Signed* Approval* All threecomponents(homepage, signed,
approval)*Not mutually exclusive – statements could include more than one
component of legal compliance

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

17Structure, business & supply chain disclosure

STRUCTURE, BUSINESS & SUPPLY CHAINDISCLOSURE
The Act suggests that organisations disclose theirstructure, business, and supply chains.43 This is an
important area as it allows those assessing thestatements to understand the boundaries of thestatement and to support the identification of risk
based on sector, organisational structure and grouprelationships, business model, the location ofoperations and supply chains, sourced goods andservices, and relationships with suppliers and others,
including trade unions.
Statements should include an explicit list of the brands, companies,
or subsidiaries covered by the statement, which is critical given thecomplexity of hotels’ ownership, management, and franchised models.
Around 50 percent of the 71 statements (n=35) did not disclose any
information on their business structure. The level of detail in theremaining statements ranged from a full list of subsidiaries, as shownin the Greene King plc statement, through to a brief description;
InterContinental Hotels Group simply stated that: “IHG is one of theworld’s leading hotel groups, with more than 5,500 hotels in over 100
countries, and a diverse portfolio of 15 hotel brands.”

Around50 percent of
the statements
did not disclose
any informationon their businessstructure

A large part of the workforce within the hotel sector is comprised ofvulnerable workers who have difficulty accessing safe and decent
work. They are at a high risk of exploitation and therefore demographic
information on such workers should be included in modern slavery
statements. Only a third of statements (n=21) assessed disclosed
information related to workforce. Much of this disclosure was aboutprocesses to monitor recruitment agencies, implying but not explicitly
revealing awareness of risks using outsourced labour.
Several companies reported having systems in place to check workers’
eligibility to work in the UK to avoid employment of persons working
against their will. However, this was limited to UK-based operations anddid not consider workers in operations or supply chains outside the UK.

18

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Structure, business & supply chain disclosure

Three quarters of the statements assessed did not disclose any
information on their supply chains. Where information was provided,
it was generally poor and lacking in detail, such as providing thegeographic region where the suppliers are based, or goods are sourced.
This lack of transparency on such a key reporting area fundamentally
undermines the spirit of the Act.
Details on supply chains were limited in the statements. For
example, the statement produced by D and D London Ltd stated:“We source food and non-food products from the UK and abroad. We
currently buy from around 250 first tier suppliers who are material to
our business and who in turn source their own ingredients, products
and components in the UK and internationally.” Hoburne Limited
included: “Our main suppliers are all UK registered and many have along history with us.”Figure 7: Number of statements that
disclose information on their supply
chains (/71)

1
16

54

Few companies name their suppliers. VUR Village Trading No 1 Limited
disclosed more information than others, providing some details on thediversity of its business relationships including suppliers, contractors,
and the franchised nature of the company. But it remains general anddoes not provide specific details: “We procure goods and services
directly from over 1000 first tier UK based suppliers… We subcontract
general maintenance and construction works services to a number ofsmall providers… We employ the majority of our workforce directly; wehave a small number of independent agents working for Village… We
have two franchise arrangements operating within Village....”

RECOMMENDATIONS
Yes – facility/supplier
Yes – geographic
No

To improve business and supply chain disclosure, statements producedby the hotel sector should:• Explicitly name the subsidiaries and brands to which the statement
applies,• Publish the names of their tier 1 suppliers, at a minimum,• Disclose what goods and services they source and from where so
stakeholders can identify likely risks, and• Provide full disclosure of the make up of their workforce and theirtrade union representation.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

19Modern slavery policies

MODERN SLAVERY POLICIESSection 54(5) of the legislation suggests thatstatements may include information on policies inrelation to slavery and human trafficking. These
policies “shape the environment and set the tone ofan organisation in assessing, preventing andmitigating the risk of and working to influence andremedy modern slavery in their supply chains andorganisation.”44
The vast majority of statements reviewed (87 percent or n=62)
included some mention of a policy related to tackling modern slavery intheir business operations and supply chains.
One of the most commonly identified policies were those wherecompanies stated that suppliers were requested to comply with
relevant international and local laws. These policies are inherently
weak as suppliers may be operating in locations where laws protecting
human rights laws do not exist or are not enforced by authorities.
Further, it places no responsibility on the hotel or supplier to implement
internal policies or practices to protect workers. Another policy
common among the hotels explicitly prohibited the use of forced labour
by suppliers. However, for such a policy to be effective, hotels mustmonitor compliance and put in place corrective action plans when
they are violated. Furthermore, policies must be supported with due
diligence that involves continuous engagement with suppliers.
Concerningly, given the complexity of hotel supply chains and thefragmented nature of the hotel sector, of those statements that did
disclose modern slavery policies, only 23 percent stated that thesepolicies applied to beyond tier 1 suppliers (n=16) as opposed to theirdirect or tier 1 suppliers (65 percent or n=46).

Figure 8: Number of statements
mentioning any policy related tomodern slavery (/71)

5

4

62

Any modern slavery policy
No mention of policy
Describes plans to develop policies

Likewise, few companies (n=6) referred to the Employer Pays Principle
in their modern slavery statement. Reflecting Principle 1 of the Dhaka
Principles for Migration with Dignity, the Employer Pays Principle is acommitment that no worker should pay for a job, including fees charged
to migrant workers. This is to reduce vulnerability to debt bondage andforced labour.

20

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Modern slavery policies

Figure 9: Number of statements describing specific modern slavery policies
45
40

40
71

35

34

30
25

23

22

20
15

11

10

7

5

5
0

9
4

6

3
1

0
Suppliers
comply withlaws andcompany's
policies*

Prohibit use
of forced
labour*Code ofconduct
includesclauses onslavery*

Contracts
includeclauses on
forcedlabour*Direct/tier 1

6

3
Suppliers
producetheir own
statement*

Suppliers
respect
labourrights*1
Prohibitcharging ofrecruitment
fees toemployee*

Prohibit useof child
labour*Beyond tier 1*Not mutually exclusive – statements could include more than one policy

There were some examples of good practice regarding the specificvulnerabilities of agency labour to modern slavery. The Hilton
Worldwide Holdings and Strand Palace Hotel and Restaurants Ltd
statements outlined policies that prohibit recruitment fees, while theRezidor group stated that:• “Every employee has a worker contract• No employee is forced to work
• No employee is forced to hand over government issued
identification, passports, work permits or bank cards• No employee is required to pay any worker fees to receive work
• No excessive deductions are made from employees’ wages
These expectations include the practices of labor agencies and foroutsourced labor suppliers.”

RECOMMENDATIONS
To target policies to the specific vulnerabilities of the hotel sector, thehotel sector should:• Have a policy on migrant workers,• Have a policy on employer pays principle,• Have a policy on use of ethical labour recruiters,
And include details on these policies in their modern slavery statements.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

21

Due diligence processes

DUE DILIGENCE PROCESSESThe Act recommends that statements include
information on due diligence processes. Humanrights due diligence is a key concept in the UN
Guiding Principles on Business and Human Rights(UNGPs). Due diligence processes should include“assessing actual and potential human rights
impacts, integrating and acting upon the findings,
tracking responses, and communicating how
impacts are addressed.” 45 These processes are notjust assessing initial risk through questionnaires or
having policies in place, but monitoring andresponding to this risk through continuous
engagement with suppliers.
The hotels’ statements were assessed on whether they continuously
engage with suppliers, conduct audits and on-site visits, and put inplace improvement plans or corrective action plans and remediation
processes.
Figure 10: Number of statements describing due diligence processes

30

27
25

25

25

20

15

11
10

8
5

5

3
0

Audits*On-site visits*

Cancelcontracts

Corrective
action plans

Self reporting

Involvementof seniormanagement

No duediligence

Independent*Not mutually exclusive – statements could include more than one due diligence process

22

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Due diligence processes

Figure 11: Number of statements
disclosing whistleblowing mechanisms
50

46
40

30

27

20

17
14
10

0

Any
Hotline*whistleblowing
mechanism

Focal
point*

Whistleblower
protection**Not mutually exclusive – statements could include more than one
way to deal with incidents

Beyond this, we also reviewed statements for any whistleblowing
mechanisms and any recent incidents of modern slavery. Given that therisk of forced labour may continuously evolve, each of these processes
is critical to responding to risk and reducing the vulnerability of direct
employees and workers in hotel supply chains.
The results on due diligence were disappointing. Many hotels either did
not report any current due diligence processes (n=25 or 35 percent),
described cancelling contracts (n= 27 or 38 percent), or provided
information on self-reporting or independent audit practices (n=27 or
38 percent).
Cancelling contracts when a risk or incidence is identified should
be a last resort — simply cutting ties with a factory or supplier
could increase the risk that workers are exposed to forced labour.
The aim should be continuous engagement with suppliers, with theuse and monitoring of action plans. For example, Shiva Hotels Plc
describes the aim of their engagement plan as, “being communication,
capacity building, and termination of relationship if criminal activity
is in question.” The statement released by Merlin Entertainment Plc
described monitoring the plans, but also included information on
terminating the business relationship if there was no improvement inline with the action plan.
Audits and compliance-driven approaches are unlikely to identify
instances of forced labour by themselves. The UK Home Officeguidance advises that “businesses seek to investigate working
conditions with support from expert independent, third parties and civilsociety stakeholders, and hear from workers themselves about theirworking conditions.”46 Few statements included information on worker
involvement in due diligence processes. Marston’s, for example, audits
agencies supplying staff to production and distribution sites twice ayear. The audit includes making direct contact with a random sample ofagency staff; however, this is for the limited purpose of confirming theirterms of employment. No hotel disclosed that they actively engage
directly with workers, trade unions, worker representatives or local
NGOs, which would be best placed to raise awareness of labour issues
faced by workers.
Sixty-five percent of statements (n=46) described having awhistleblowing mechanism, but no statement identified any incidents
of modern slavery or related forms of exploitation. This does notmean that abuse is not happening. Most companies, including thosein the hotel sector, will have experienced labour exploitation andforced labour either in their direct operations or supply chains. By
not disclosing this information, companies are either not conducting
thorough due diligence, and must review the effectiveness of theirmechanisms, or are potentially hiding reports that have been madeabout these forms of exploitation.
Hotels should ensure their grievance mechanisms are accessible
to workers. If many of the workers in the hotel sector are vulnerable
groups, they must be able to easily access a mechanism and feel they
can report abuse without fear of retaliation or questioning of theirlegal or work status. This may require the hotel to establish a numberof mechanisms for different types of workforce that take into accountobstacles for workers such as language barriers.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

23

Risk assessment and management

Few statements address the risk of sexual exploitation in hotels.
Just eight percent of statements (n=6) disclosed they support thereporting of forced sexual exploitation to police. These hotels were
Travelodge, Great Eagle Hotels UK Ltd, Hyatt Hotels Corporation, andShiva Hotels Group LLP. Ten percent of statements (n=7) mentioned
participation in partnerships directed at combatting sexual exploitationand trafficking, such as partnering with the National Society for thePrevention of Cruelty to Children (NSPCC), End Child Prostitution, Child
Pornography and Trafficking of Children for Sexual Purposes (ECPAT),
and Businesses Ending Slavery and Trafficking (BEST). Five hotels(Hilton, Hyatt, Marriott, TUI, and Accor) disclosed they have signed
ECPAT’s Code of Conduct to combat child sexual exploitation in thetravel industry.
Industry and trade associations can provide companies with aplatform to share challenges and experiences, guidance and bestpractice on how to address modern slavery. Six hotels (Hilton, Hyatt,
InterContinental, Marriott, The Rezidor Hotel Group, and Whitbread)
disclosed they are part of the International Tourism Partnership (ITP),an industry association that supports the principles outlined in the UN
Declaration of Human Rights and the UNGPs. The ITP has developeda Human Trafficking Position Statement, a Know How Guide, andGuidelines for Checking Recruitment Agencies.47 More recently the ITP
has developed three key Principles on Forced Labour: that every worker
should have freedom of movement, no worker should pay for a job, andno worker should be indebted or coerced to work.48 The Gangmasters
and Labour Abuse Authority is also in the process of establishing ahospitality protocol in collaboration with Shiva Foundation.

RECOMMENDATIONSTo improve due diligence processes, hotels should:• Go beyond auditing to manage risks and integrate site visits,• Engage directly with workers, trade unions, worker representatives
and local organisations who have expertise on labour issues on the
ground both in the development due diligence processes and whenaddressing modern slavery incidents,• Ensure their grievance mechanisms meet the criteria set out in the
UNGPs, particularly that they are accessible, and workers are awareof them,• Develop specific processes to support those who may be sexually
exploited or transited for sexual exploitation on hotel premises,• Join existing partnerships to share good practice,
And include information on these processes in their statements.

24

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Risk assessment and management

FEW STATEMENTS
ADDRESS THE RISK OFSEXUAL EXPLOITATIONTHAT CAN OCCUR IN
HOTELS

Lima, Peru, 27th September
2019. Police officers standguard outside a hotel
where minors are forced
into commercial sexual
exploitation. The Special
Operation ‘Los Bastardos deCeres’ involved three raids, thedetention of Narciso Chacon
Zavala (34) and Abner Bryan
Rojas Borja (20) and the rescueof a girl of 16. Photo credit:
Manuel Medir/Getty Images.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

25

Risk assessment and management

RISK ASSESSMENT AND MANAGEMENT
Beyond responding to risks and incidents,
companies should take action to prevent forced
labour from occurring. The UK Home Officeguidance states that assessing the nature and extent
of exposure to risk will enable more targeted action
to find it, remedy it, and prevent it from occurring in
the future.49
A disappointing 55 percent of the statements (n=39) did not describe
currently using any risk assessment tool. Undertaking a risk assessment
is the first step to identify risks and then prioritise how to address these;
without tools and resources in place, any risk management strategies
will be ineffective.
Company disclosure should be clear about the tools that are used toassess operations and supply chains to identify risks and whether thetools have been effective. Only 21 percent of the 71 statements (n=15)
described both using a risk assessment tool and identifying a specificrisk as a result of using that tool. For example, Whitbread disclosed thatas a result of their risk assessment, including using SEDEX software,risk-based questionnaires, and conducting research, they identified
high-risk industries, such as construction and food and beverage
manufacturing. In some cases, it is not clear whether the risk is identified
as a result of implementing the tool. For instance, Hand Picked Hotels,stated that they conduct “regular review of suppliers, their policies andby monitoring their online and media reputations,” but did not link this to
its disclosure that “risks arise from the use of foreign and migrant labour,and from supply chains both in the UK and overseas.”

Figure 13: Number of statements
identifying specific risks
50

48

40

30

20

13
10

10

4
0

6

Geographic* Industry* Workforce* Resource*

No risk
identified*Not mutually exclusive – statements could identify more than
one type of risk

Where specific risks were identified these were described in very
general terms, with limited detail. For example, of the three statements
disclosing risks related to geographic locations, only Hilton identified
the risks associated with the specific location of their hotels, statingthat their priority should be “analysing our leased and managed hotels
in Europe, Middle East and Africa (EMEA) with respect to human rights
risks in labour outsourcing.”
As examples of broad description of risks, Bannatyne Group Plc
stated that higher risk suppliers would be those, “where clothesor textiles are produced abroad,” or Grange Hotels which statedthat “products or services sourced from outside the UK or EU arepotentially more at risk of slavery or human trafficking issues.”

26

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statementEffectiveness of the modern slavery response

We would expect to see more companies disclose risks related toworkforce. Only 18 percent (n=13) of statements explicitly identified
certain types of workforce as being high-risk. The statement producedby Maybourne Hotel Group is one of the few examples that identifies
the risks associated with the use of foreign and migrant labour in supply
chains in the UK and overseas.

Figure 12: Number of statements
describing a risk assessment tool
40

39

35

30

25

20

15

21
16

10

7
5

0

Conducting Risk-based Use of risk
research* question- management
naires*software*No current
tool
described

Of the 71 statements assessed, 24 percent (n=17) identified sexual
exploitation as a specific risk that hotels may face. Some businesses
merely identified sexual exploitation as a potential form of modern
slavery which may occur in their business or supply chains, such as
Aprirose Limited and RBH Hotels. Only 14 percent of statements(n=10) reported specific approaches to dealing with the risk of sexual
exploitation in their operations and supply chains. Hyatt Hotels andInterContinental, for example, acknowledged that the risk of sexual
exploitation was increased as a result of international sporting eventsand that they had taken steps to create heightened awareness ofhuman trafficking at such events.
Few hotels recognised the specific risks associated with thefragmented nature of the hotel sector. Millennium, for example, while
not providing much detail, was explicit that the risks they face differ
based on the model of operation, with the most control exercisedover owned and managed hotels, where the company relies on “ourRelevant Policies and related training and procedures to help manage
the risks of slavery and human trafficking.” With regard to franchising,management of hotels through joint ventures, and ownership of hotels
which are managed by third-party operators, the statement disclosedthat the company “may have very limited control or influence over ourbusiness partners.”*Not mutually exclusive – statements could include more than
one way to deal with incidents

RECOMMENDATIONS
To better target resources and respond to potential instances ofmodern slavery in their supply chains, hotels should:• Map their supply chains to gain better visibility of their lower tiers inorder to identify risks,• Understand that risks will differ from region-to-region,• Understand that risks will fluctuate based on events and seasonality,• Focus on the vulnerability of their workforce when assessing risk,
And disclose this and the risks that have been identified in their modern
slavery statements.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

27

Effectiveness of the modern slavery response

EFFECTIVENESS OF THE MODERN SLAVERYRESPONSE
Two types of key performance indicators (KPIs) arerecommended by the UK Home Office guidance.
First, business performance indicators, which areimportant in driving business and shaping the way it
operates. These indicators may influence and createa modern slavery risk if not managed carefully; forexample, finding the lowest price for agencies toclean rooms in a hotel might lead to exploitation ofhousekeepers. Secondly, businesses should alsoestablish their own indicators to track progress of
their modern slavery response,50 referred to below
as “modern slavery performance indicators.”
Reporting on business KPIs which may increase the risk of modern
slavery is non-existent. No company described how their business
KPIs might increase risk of modern slavery, however Shiva Hotels did
recognise that overtime and underpayment can occur if “productivity
rates for housekeeping contracts are ill-advised.” To combat this,the hotel is trialling a “time-in-motion” approach that allows for areasonable time for housekeeping staff to clean a room, which in turnallows for a “high quality service.”
Across most assessments of statements produced under the Act,
effectiveness is the worst performing reporting area. The Resource
Centre’s analysis of reporting by the FTSE 100 companies found thisto be the case three years in a row. In the 2018 analysis, an increased
number of companies reported having modern slavery performanceindicators, but these tended to be very similar, such as the numberof employees trained on modern slavery or the number of suppliers
audited. The same is true of the statements produced by the hotels
sector. For example, Hand Picked Hotels Limited, Bannatyne GroupPlc, Grosvenor Group, InterContinental, Macdonald Hotels Limited,
Mitchells and Butlers, Shiva Hotels, and Soho House & Co all describedsimilar KPIs to track the effectiveness of their anti-slavery response.

28

Figure 14: Number of statements
describing modern slavery andbusiness performance indicators
12

11
10

8

6

4

2

0

0
Modernslavery
performanceindicators*

Business
performanceindicators**Not mutually exclusive – statements could identify bothtypes of KPIs

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statementEffectiveness of the modern slavery response

Few hotels, such as Hilton and TUI, reported on their progress against
these KPIs. Hilton, for example, has the KPI: “100% operating hotels andpipeline countries mapped against human rights risks and information
embedded in operations and development processes” and disclosed
it has: “Mapped 100% operating hotels and pipeline countries against
11 human rights risk indices; Integrated Human Rights criteria in ourannual internal Global Enterprise Risk Survey; Embedded human rights
in the new country development due diligence process.”
D and D London tracks the number of modern slavery incidents
reported as a KPI. The company stated that they will know that thesteps they are taking are effective if no incidents of modern slavery
are reported. This is not accurate, however, as it only reveals that no
incidents have been reported, not that they do not exist. The failure of
a company to receive any incidents or complaints related to modern
slavery simply suggests they must continue to review and revise theirprocesses so that they better identify instances of modern slavery.

RECOMMENDATIONS
To measure effectiveness and that business practices do not increaserisk of exploitation, hotels should:• Review current business KPIs (for example downward pressure on
cost-price or entering new markets and production countries) to see
if they increase or decrease the risk of modern slavery occurring intheir operations and supply chains. These KPIs should be amended ifthey are found to increase risk,• Establish specific KPIs related to their modern slavery policies anddue diligence, and• Report on their progress towards KPIs that track the progressof their modern slavery efforts in their UK Modern Slavery Act
statement.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

29

Training

TRAINING
Training allows relevant staff within companies andbusiness partners to understand, firstly, theimportance and relevance of modern slavery in its
operations and supply chains, and secondly, what theyneed to do to identify and prevent risks, and how towork together if they encounter incidents. The UK
Home Office guidance states that training can betargeted to different groups either inside or outside
the core business and may take many forms ranging
from raising awareness to detailed training programs.51
For the hotel sector, training is critical for many different groups,
including management level, Human Resources and recruitment
teams, suppliers, and procurement specialists. These groups should betrained on the risks related to the various industries from which goods
and services are sourced including agriculture, garment, cleaning,
construction and many others. Some hotels also provide training tofrontline staff to identify instances of modern slavery at operational
level; general managers, for example, are particularly well-placed tocoordinate training for all staff who work regularly within the hotel, suchas those on reception.
Figure 15: Number of statements disclosing training and recipient of the training
30

25

25

20

20

15

20

14
12

10

5

4
2

0 Leadership*Suppliers*

Recruitment/HR*

Procure- Employees
ment/(all)*
purchasing*Training
provided
but not
specified who
received it*Notraining*Not mutually exclusive – statements could identify multiple trainings

30

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

TrainingThis training may cover how to spot the use of hotels as a venue forsexual exploitation or transit location for trafficking, or how to identify
when outsourced staff recruited by a labour provider may be exploited.52
Over 28 percent (n=20) of statements did not describe any current
training programmes. Club La Costa’s statement, for example,
demonstrated a lack of awareness on risks inherent in the sector,“[G]iven the wide ranging nature of our training programmes and our
low risk activities we do not feel we have to have a specific module
dedicated to anti-slavery and human trafficking.”
Some statements described providing training to all staff, including thosein owned, managed, and franchised hotels. For example, Wyndham
Worldwide provided training or education materials on child labour andhuman trafficking to all managed and owned hotels in the US, managed
hotel properties in Asia Pacific, Europe, Middle East, Africa and Latin
America, their franchised operations, and suppliers. Marriott provided
training in 17 languages and required all on-property associates inmanaged and franchised properties to complete the training.

While it isencouraging tosee companies
providingtraining to all
staff, the content
of the training
was either notdescribed, or
was quite broad
and referred
to as “raisingawareness” ofmodern slavery

While it is encouraging to see companies providing training to all staff,
the content of the training was either not described, or was quite broad
and referred to as “raising awareness” of modern slavery. Hotels mustalso provide bespoke training to educate relevant staff members
on specific risks regarding the employment of migrant workers, useof agency labour, and supply chain risks. There were some goodpractice examples; Meininger reports its training will cover “purchasing
practices, which influence supply chain conditions and which should
therefore be designed to prevent purchases at unrealistically low
prices, the use of labour engaged on unrealistically low wages or wages
below a country’s national minimum wage, or the provision of products
by an unrealistic deadline”. However, we would expect the level oftraining provided to HR/ recruitment and procurement specialists to
be much higher than the six percent (n=4) and 17 percent (n=12) ofstatements respectively.
Although the potential for hotels to be used as a venue or transit point
for forced sexual exploitation has long been recognised, companies arestill failing to provide relevant training for their frontline staff — thosemost likely to identify incidents. Just 10 percent of statements (n=7)
provided such details; Travelodge, for example, conducted training on
preventing child sexual exploitation for all hotel employees.

RECOMMENDATIONS
To be able to better understand and respond to modern slavery, hotels
should:• Develop specific training programs targeted to different direct
employees and suppliers, including on the risks associated with
migrant workers and hotels as a venue for forced sexual exploitation,• Measure the effectiveness of these training programs by reviewing
employee knowledge and action after receiving the training,
And disclose this training in their modern slavery statements.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

31

Conclusion

CONCLUSION
Across many sectors, statements produced under
the UK Modern Slavery Act are failing to meet therequirements of the Act and the accompanying UK
Home Office guidance. The hotel sector is no
exception. The 71 statements we assessedconsistently failed to address sector-specific risks:complex supply chains, the fragmented nature of
franchising, the use of localised and informalpurchasing agreements, seasonal and temporary
working arrangements, and limited brand oversight.
Now, four years on from the passage of the Act, we would expect to see
statements that not only demonstrate business’ awareness of modern
slavery but disclose the company’s responses to these risks as they
pertain specifically to their industry. Yet, significant gaps remain.
The running of just one hotel depends upon a collection of disparate
companies — owners, management companies, brands and labour
providers — that all have different roles and provide different services.
The fragmented nature of the sector makes it difficult to havevisibility into supply chains and it will always be challenging to allocate
responsibility for workers’ welfare and mitigating modern slavery risk
among the complex network of business partners.
This does not offer a loophole for non-compliance, rather, it potentially
increases the risk of modern slavery and its impact on business
operations and brand name, as each company relies on the others
to “take the fall” if cases of modern slavery are found. Regardless oflegal liability, hotel companies themselves ultimately have a moral
responsibility to protect workers at risk of exploitation in their direct
operations and supply chains.

On reporting,hotels are fallingat the firsthurdle, failing tomeet even thebasic steps of
the Act and toprovide sufficient
disclosure on
their operations
and supply
chainsOn reporting, hotels are falling at the first hurdle, failing to meet eventhe basic steps of the Act and to provide sufficient disclosure on
their operations and supply chains. Alarmingly, some hotels are still
not reporting at all and those that do have made it difficult to assesschange over time. Only a few have implemented measures known tohelp prevent exploitation, such as the “employer pays” principle, into
their operations. Concerningly, over a third of statements (35 percent
or n=25) did not disclose due diligence processes and those that did
defined this narrowly as audits and compliance-driven approaches.
These are unlikely to identify instances of forced labour by themselves.

32

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Conclusion

Use of risk assessments are limited and identification of risks are verybroad as to become almost meaningless. It is clear that statements
merely disclose risks associated with other sectors and are not
the result of an assessment developed with hotel operations andsupply chains in mind. Statements describing methods to measureeffectiveness are few and far between, while training does not target
those who would benefit most from receiving it.
Despite companies’ failure to demonstrate meaningful efforts totackle the risks endemic in this sector, a strong case remains foraction against modern slavery by the hotel sector, an approach thatcan only benefit from collective action between owners, managementcompanies, brands and labour providers. Sector-specific initiatives
facilitate engagement between peers, capitalise on business
partnerships to share good practice or streamline protective measuresagainst modern slavery.

Getsemani, Colombia.
Bilingual sign prohibiting
sex tourism at the hotel.
Hotels can be used
as a venue for forced
sexual exploitation oras a transit point for
those forced into the sex
industry. Photo credit:
Jeffrey Greenbery/
Universal Images Group
via Getty Images.

Beyond collaborative action, hotels must commit to review their due
diligence processes and disclose any incidents of modern slavery
and the steps taken to remedy these. To encourage a move beyond
compliance, the UK Government should release a list of those who are
required to report to facilitate analysis and enforce the Act against
non-compliant companies.
As mandatory reporting requirements and mandatory human rights
due diligence are established in other countries it is important that any
business and human rights legislation is strengthened and enforced.
Without effective implementation by governments and a renewed
commitment by business to combat exploitation, vulnerable individuals
in hotel operations and supply chains remain at risk of modern slavery.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

33

Appendix 1: List of metrics

APPENDIX 1: LIST OF METRICS• Modern Slavery Act (MSA) statement: Did the company produce a statement in relation to the UK’s
Modern Slavery Act?

• MSA statement homepage link: Does the company’s homepage link to their Modern Slavery Act
statement?

• MSA historic record: Does the company provide links to their modern slavery statements fromprevious years?

• MSA statement signed: Was the company’s Modern Slavery Act statement signed by an appropriate
person?

• MSA statement approval: Was the company’s Modern Slavery Act statement explicitly approved by
the board of directors (or equivalent management body)?

• MSA ownership disclosure: Does the company disclose the ownership structure(s) and/or businessmodel(s) of each of its brands, subsidiaries, and other businesses?

• MSA supply chain disclosure: Does the company’s statement identify the suppliers in their supply
chain and/or the geographic regions where their supply chain operates?

• MSA policy: Does the company’s statement detail specific, organisational policies or actions to combat
slavery in their supply chain?

• MSA risk assessment: How does the company assess the risks of modern slavery and trafficking intheir supply chain?

• MSA identification of risks: Does the company’s statement identify specific countries, regions orindustries where the risk of modern slavery is the greatest?

• MSA risk management: Does the company continuously monitor suppliers to ensure that they comply
with the company’s policies and local laws?

• MSA incidents identified: Did the company identify any specific incidents related to modern slavery
that require(d) remediation?

• MSA incidents remediation: Did the company explain the corrective steps it has taken (or would take)in response to modern slavery incidents with suppliers?

• MSA whistleblowing mechanism: Does the company have a grievance mechanism in place to facilitate
whistleblowing or the reporting of suspected incidents of slavery or trafficking?

• MSA training: Does the statement describe training for staff that is specifically geared towards
detecting signs of slavery or trafficking?

• MSA performance indicators: Does the company define performance indicators for assessing theeffectiveness of their efforts to combat slavery and trafficking?

• MSA business performance indicators: Has the company reviewed business KPIs to ensure they are
not increasing risk of modern slavery?

• MSA impact on company behaviour: Does the company’s statement describe a change in their policythat occurred as a direct result of the UK Modern Slavery Act 2015?

34

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Appendix 2: Hotels and statements included in this analysis

APPENDIX 2: HOTELS AND STATEMENTS INCLUDED IN THIS ANALYSIS
Company

Year ofstatement
being
assessed

Do they havea UK Modern
Slavery Act
statement?

Accor UK Business Leisure Hotels
Limited2018

No

Accor UK Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406024/20707281.pdf

Alfa Leisureplex Group

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5398629/20687858.pdf

Apex Hotels

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5406050/20707321.pdf

Aprirose Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5306674/20475677.pdf

Arora Hotels

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5406063/20707359.pdf

Awaze

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5403931/20700898.pdf

Bannatyne Group Plc

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5398645/20687917.pdf

Beds and Bars Group Ltd

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5342154/20556408.pdf

Belmond Ltd

2017

Yes

https://wikirate.s3.amazonaws.com/
files/5291940/20435700.pdf

Capital Hill Hotels Limited

2018

No

Center Parcs Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5291949/20435709.pdf

Club La Costa Plc

2016

Yes

https://wikirate.s3.amazonaws.com/
files/5291958/20435718.pdf

D&D London Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5291976/20435736.pdf

Daniel Thwaites plc

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5291967/20435727.pdf

Dorchester Hotel Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5397248/20684551.pdf

English Lakes Hotels Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5291994/20435754.pdf

Exclusive Hotels and Venues

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406090/20707415.pdf

Firmdale Hotels

2017

Yes

https://wikirate.s3.amazonaws.com/
files/5306691/20475742.pdf

Four Seasons

2019

No

Fuller Smith and Turner plc

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5406104/20707431.pdf

Geronimo Inns Limited

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5398896/20688743.pdf

Gleneagles Hotels

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406117/20707446.pdf

GLH Hotels Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5397117/20684256.pdf

URL on WikiRate platform

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

35

Appendix 2: Hotels and statements included in this analysis

36

Company

Year ofstatement
being
assessed

Do they havea UK Modern
Slavery Act
statement?

URL on WikiRate platform

Grange Hotels

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5293839/20440102.pdf

Great Eagle Hotels UK Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406179/20707524.pdf

Greene King

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292030/20435790.pdf

Hallmark Hotels Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5296508/20446938.pdf

Hand Picked Hotels Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5398914/20688823.pdf

Hapimag AG

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292038/20440179.pdf

Harbour Hotels

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5406130/20707462.pdf

Hastings Hotels

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406152/20707488.pdf

Hilton Worldwide Holdings

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5323468/20504757.pdf

Hoburne Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5440251/20770990.pdf

HPI UK Holding Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292073/20435833.pdf

Hyatt Hotels Corporation

2016

Yes

https://wikirate.s3.amazonaws.com/
files/5449056/20838074.pdf

Imperial London Hotels Group Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292082/20435842.pdf

Indian Hotel Company

2018

No

InterContinental Hotels Group

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5430462/20747736.pdf

J D Wetherspoon

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5398930/20688963.pdf

Jumeirah Group

2019

No

Jupiter Hotels Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5398937/20688971.pdf

Jurys Inns Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406165/20707503.pdf

Landmark Hotel London Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292117/20435877.pdf

MacDonald Hotels Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5398727/20688206.pdf

Mandarin Oriental Hyde Park Ltd

2018

No

Marriott International

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5430669/20748089.pdf

Marston’s

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406193/20707540.pdf

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Appendix 2: Hotels and statements included in this analysis

Company

Year ofstatement
being
assessed

Do they havea UK Modern
Slavery Act
statement?

URL on WikiRate platform

Maybourne Hotels Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5410869/20713993.pdf

Meininger Holding GmbH

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5294248/20441502.pdf

Merlin Entertainments PLC

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5410882/20714014.pdf

Millennium Copthorne Hotels

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5410955/20714411.pdf

Mitchells & Butlers plc

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292162/20435922.pdf

Morris Leisure Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292170/20435930.pdf

Parkdean Resorts Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5400959/20693363.pdf

Percy R Brend Sons Hoteliers Limited

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5406228/20707600.pdf

PGL

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5294840/20442728.pdf

RBH Hotel Management Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5304446/20469902.pdf

RBH Hotels UK Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5294937/20442975.pdf

Rocco Forte Hotels Limited

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5444109/20775024.pdf

SACO The Serviced Apartment
Company Limited

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5398997/20689040.pdf

Shearings Leisure Group Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5410917/20714080.pdf

Shiva Hotels Group LLP

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5320529/20497730.pdf

Sir Richard Sutton Limited

2018

No

Soho House Holdings Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292214/20435974.pdf

Splendid Hospitality

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5406241/20707613.pdf

Strand Palace Hotel & Restaurants Ltd

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5292223/20435983.pdf

Taj International Hotels Limited

2016

Yes

https://wikirate.s3.amazonaws.com/
files/5291922/20435682.pdf

The Celtic Manor Resort

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406077/20707400.pdf

The Goodwood Estate Company
Limited2018Yes

https://wikirate.s3.amazonaws.com/
files/5292196/20442012.pdf

The Rezidor Hotel Group

2017

Yes

https://wikirate.s3.amazonaws.com/
files/5324807/20507684.pdf

The Savoy Hotel Ltd

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406033/20707298.pdf

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

37

Appendix 2: Hotels and statements included in this analysis

38

Company

Year ofstatement
being
assessed

Do they havea UK Modern
Slavery Act
statement?

URL on WikiRate platform

Travelodge Hotels

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5406255/20707629.pdf

Trust Inns

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5403925/20700889.pdf

TUI Group

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5398580/20687736.pdf

VUR Village Trading No 1 Limited

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5410926/20714092.pdf

Whitbread

2019

Yes

https://wikirate.s3.amazonaws.com/
files/5399032/20689125.pdf

Wyndham Worldwide

2018

Yes

https://wikirate.s3.amazonaws.com/
files/5292258/20436018.pdf

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Endnotes

ENDNOTES
1

International Labour Office 2015, “Sectoral Studies on Decent Work in Global Supply Chains Comparative Analysis of Good Practices
by Multinational Enterprises in Promoting Decent Work in Global Supply Chains”.
2
As above.
3
Shiva Foundation 2018, Stop Slavery Blueprint. Available from: http://www.shivafoundation.org.uk/Blueprint/#153416614979546b5e29a-c1e9. [23 August 2019].
4International Labour Office and the Walk Free Foundation 2017, “Global Estimates of Modern Slavery”. Available from: https://www.ilo.
org/wcmsp5/groups/public/---dgreports/---dcomm/documents/publication/wcms_575479.pdf. [23 August 2019].
5
See: Tuppen, H. 2013, “Addressing Human Trafficking in the Hospitality Industry”. Available from: http://www.greenhotelier.org/knowhow-guides/addressing-human-trafficking-in-the-hospitality-industry/. [23 August 2019].; Stop Slavery Hotel Industry Network
2017, “Framework for working with suppliers: mitigating risk of modern slavery”. Available from: https://www.stopslaverynetwork.
org/wp-content/uploads/2018/03/SF17_SHIN_framework_dec17-11-links-RGB-min-1.pdf. [23 August 2019].; Kotecha, A.,
Hargrove, J. n.d., “Modern Slavery & the Hotel Industry: Best Practice Guidance for Franchising”. Available from: https://s3.apsoutheast-1.amazonaws.com/freedom.collaborative.prod/uploads/SN10265%20Hotel%20Franchisors%20and%20Modern%20
Slavery%20Brochure%20v5.pdf [23 August 2019].; Shiva Foundation 2018, “Stop Slavery Blueprint”. Available from: http://www.
shivafoundation.org.uk/Blueprint/#1534166149795-46b5e29a-c1e9. [23 August 2019].
6
Baum, T. 2012, “Migrant workers in the international hotel industry”, International Labour Office. Available from: https://www.ilo.org/
wcmsp5/groups/public/---ed_dialogue/---sector/documents/publication/wcms_180596.pdf. [23 August 2019].
7
Stop Slavery Hotel Industry Network 2017, “Framework for working with suppliers: mitigating risk of modern slavery”. Available from:https://www.stopslaverynetwork.org/wp-content/uploads/2018/03/SF17_SHIN_framework_dec17-11-links-RGB-min-1.pdf. [23August 2019].;
8
Patty A. 2019, “Staff at luxury hotel group threatened after speaking out about exploitation”, The Sydney Morning Herald. Available
from: https://www.smh.com.au/business/workplace/staff-at-luxury-hotel-group-threatened-after-speaking-out-aboutexploitation-20190708-p5258b.html. [17 September 2019].
9
Kelly, A. McNamara, M-L., 2017, “A slave in Scotland: ‘I fell into a trap – and I couldn’t get out’”, The Guardian. Available from: https://www.theguardian.com/global-development/2016/may/28/slavery-human-trafficking-hotel-workers-bangladesh-scotland.
[17 September 2019].
10
Polaris 2015, “Human Trafficking the Hotel Industry”. Available from: https://polarisproject.org/sites/default/files/human-traffickinghotel-industry-recommendations.pdf. [23 August 2019].
11
International Labour Office 2015, “Sectoral Studies on Decent Work in Global Supply Chains Comparative Analysis of Good Practices
by Multinational Enterprises in Promoting Decent Work in Global Supply Chains”.
12
Roberts, Y 2015, “Britain’s hotel workers – bullied, underpaid and with few rights”, The Guardian. Available from: https://www.
theguardian.com/business/2015/may/30/hotel-workers-bullied-underpaid-few-rights-uk. [16 October 2019].
13
ECPAT USA 2017. “No Vacancy for Child Sex Traffickers Impact Report.” Available from: https://static1.squarespace.com/
static/594970e91b631b3571be12e2/t/59c9b6bfb07869cc5d792b8c/1506391761747/NoVacany_Report.pdf. [23 August 2019].
14
Polaris 2015, “Human Trafficking the Hotel Industry”. Available from: https://polarisproject.org/sites/default/files/human-traffickinghotel-industry-recommendations.pdf. [23 August 2019].
15
International Labour Office 2015, “Sectoral Studies on Decent Work in Global Supply Chains Comparative Analysis of Good
Practices by Multinational Enterprises in Promoting Decent Work in Global Supply Chains”.
16
As above.
17
Business and Human Rights Resource Centre n.d., “Inhospitable: How hotels in Qatar & the UAE are failing migrant workers”.
Available from: https://www.business-humanrights.org/sites/default/files/Gulf-Hotels-Briefing.pdf. [23 August 2019].
18
As above.
19
Adapted from: International Labour Office 2015, “Sectoral Studies on Decent Work in Global Supply Chains Comparative Analysis ofGood Practices by Multinational Enterprises in Promoting Decent Work in Global Supply Chains”.
20
Kotecha, A., Hargrove, J. n.d., “Modern Slavery & the Hotel Industry: Best Practice Guidance for Franchising”. Available from:https://s3.ap-southeast-1.amazonaws.com/freedom.collaborative.prod/uploads/SN10265%20Hotel%20Franchisors%20and%20
Modern%20Slavery%20Brochure%20v5.pdf. [23 August 2019].
21
As above.
22
Kafala is a sponsorship system where workers’ visas are directly sponsored by employers, which makes the ability to complain or
leave difficult or impossible.
23
Business and Human Rights Resource Centre n.d., “Inhospitable: How hotels in Qatar & the UAE are failing migrant workers”.
Available from: https://www.business-humanrights.org/sites/default/files/Gulf-Hotels-Briefing.pdf.
[23 August 2019].
24
Ghani F. 2019, “Qatar moves to announce abolishment of kafala system”, Al Jazeera. Available from: https://www.aljazeera.com/
news/2019/10/qatar-moves-announce-abolishment-kafala-system-191017070750729.html. [28 October 2019].
25
Pattisson, P. 2018, “Migrants claim recruiters lured them into forced labour at a top Qatar hotel”, The Guardian. Available from:https://www.theguardian.com/global-development/2018/oct/29/agents-duped-us-into-forced-labour-at-top-qatar-hotel-saymigrant-workers-marsa-malaz-kempinski. [23 August 2019].
26
Tuppen, H. 2013, “Addressing Human Trafficking in the Hospitality Industry”. Available from: http://www.greenhotelier.org/knowhow-guides/addressing-human-trafficking-in-the-hospitality-industry/. [23 August 2019].
27
UK Government 2015, “Modern Slavery Act”. Available from: http://www.legislation.gov.uk/ukpga/2015/30/section/54/enacted.
[23 August 2019].
28
Australian Government 2018, “Modern Slavery Act No 153, 2018”. Available from: https://www.legislation.gov.au/Details/
C2018A00153. [23 August 2019].

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

39

Endnotes

29

Due to the complexity of the statements’ contents and the occasional need for subjective interpretation there may be discrepancies
between the data and cited sources. Upon review of the data and finding such discrepancies, we invite you to make corrections
directly on the WikiRate platform. In case of any questions or difficulties please reach out to the WikiRate team.
30
UK Government 2015, “Modern Slavery Act”. Available from: http://www.legislation.gov.uk/ukpga/2015/30/section/54/enacted.
[23 August 2019].
31“Independent Review of the Modern Slavery Act 2015: Final Report”. May 2019. Available from: https://assets.publishing.service.gov.
uk/government/uploads/system/uploads/attachment_data/file/815410/Government_Response_to_Independent_Review_of_MS_
Act.pdf?_ga=2.113206284.924453583.1566910438-1687666633.1527168977. [24 August 2019].
32
Accor (U.K.) Limited has published a statement, which details the steps taken by corporate group Accor S.A. and its worldwide
subsidiary undertakings. Accor UK Business Leisure Hotels Limited is listed on OpenCorporates as a subsidiary of Accor S.A,
however it is not explicitly listed as an entity in the Accor (U.K.) Limited statement. See Accor (U.K.) Limited statement: https://wikirate.s3.amazonaws.com/files/5406024/20707281.pdf. A search of the website on 15th November did not reveal a statement.
33
Capital Hill Hotels Group London Limited had a turnover of over £40million in 2018 and in 2017. See https://beta.companieshouse.
gov.uk/company/03462675/filing-history. It does not have a website, and the two hotels described in the company information on
Companies House are St Martins Lane and Sanderson. These appear to be associated with Morgans Hotel Group, which is part ofsbe. Accor has just acquired 50 percent stake in sbe. https://www.sbe.com/aboutsbe/. A search of the website on 15th November
did not reveal a statement.
34
Four Seasons Hotels and Resorts has an estimated annual turnover of US$12 billion and operates hotels in the UK, including Four
Seasons Hotel London at Park Lane, at Ten Trinity Square, and in Hampshire. It is controlled by Whitbread, however, it is not listed
as a brand or subsidiary in the Whitbread statement. A search of the website on 15th November did not reveal a statement.
35
Taj hotels has a statement and is a brand of Indian Hotel Company Limited. Indian Hotel Company Limited does not have astatement. A search of the website on 15th November did not reveal a statement.
36
Dubai Holdings, of which Jumeirah Group is a part, had an estimated revenue of £3.7billion in 2016. https://www.thenational.ae/
business/travel-and-tourism/jumeirah-group-ceo-steps-down-for-personal-reasons-1.91376. Jumeirah operates hotels in theUK, including Grosvenor House Suites, Jumeirah Carlton Tower, and Jumeirah Lowndes Hotel. Neither Jumeirah Group nor Dubai
Holdings have released a statement. A search of the website on 15th November did not reveal a statement.
37
Mandarin Oriental Hyde Park Ltd had a turnover of £37 million in 2018. A search of the website for Mandarin Oriental The HotelGroup also did not reveal a statement. See https://beta.companieshouse.gov.uk/company/06192910/filing-history. A search of thewebsite on 15th November did not reveal a statement.
38
Sir Richard Sutton Limited had a revenue of over £74 million in 2018 and over £52 million in 2017. See: https://beta.companieshouse.
gov.uk/company/00346359/filing-history. No statement could be found on the website. A search of the website on 15th November
did not reveal a statement.
39
Home Office 2018, “Transparency in Supply Chains etc. A practical guide.” Available from: https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/attachment_data/file/649906/Transparency_in_Supply_Chains_A_Practical_Guide_2017.
pdf. [23 August 2019].
40
UK Government 2015, “Modern Slavery Act”. Available from: http://www.legislation.gov.uk/ukpga/2015/30/section/54/enacted. [23August 2019].
41
WikiRate and the Walk Free Foundation 2018, “Beyond Compliance: The Modern Slavery Act Research Project”. Available from:https://cdn.minderoo.com.au/content/uploads/2019/05/27154005/Wikirates_WFF_MSA-Analysis_180917_Digital.pdf. [23 Augus
2019]. Business & Human Rights Resource Centre n.d., “FTSE 100 & the UK Modern Slavery Act: From Disclosure to Action”.
Available from: https://www.business-humanrights.org/sites/default/files/FTSE%20100%20Briefing%202018.pdf. [25 August2019]. See also Carrier, P. 2019, “The Modern Slavery Act turns four today. Is it working? And how can it be improved?” Business &Human Rights Resource Centre. Available from: https://www.business-humanrights.org/en/the-modern-slavery-act-turns-fourtoday-is-it-working-and-how-can-it-be-improved. [9 September 2019].
42“Modern Slavery Registry”. Available from: https://www.modernslaveryregistry.org/. [9 September 2019].
43
UK Government 2015, “Modern Slavery Act”. Available from: http://www.legislation.gov.uk/ukpga/2015/30/section/54/enacted.
[23 August 2019].
44
Home Office 2018, “Transparency in Supply Chains etc. A practical guide.” Available from: https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/attachment_data/file/649906/Transparency_in_Supply_Chains_A_Practical_Guide_2017.
pdf. [23 August 2019].
45
As above. See also United Nations Human Rights Office of the High Commissioner 2011, “Guiding Principles on Business and Human
Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework”. Available from: https://www.ohchr.org/
documents/publications/GuidingprinciplesBusinesshr_eN.pdf. [17 September 2019].
46
Home Office 2018, “Transparency in Supply Chains etc. A practical guide.” Available from: https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/attachment_data/file/649906/Transparency_in_Supply_Chains_A_Practical_Guide_2017.
pdf. [23 August 2019].
47
International Tourism Partnership 2019, “Human Rights”. Available from: https://www.tourismpartnership.org/human-rights//.
[16 September 2019].
48
International Tourism Partnership 2019, “News”. Available from: https://www.tourismpartnership.org/blog/itp-launches-principleson-forced-labour/. [16 September 2019].
49
Home Office 2018, “Transparency in Supply Chains etc. A practical guide.” Available from: https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/attachment_data/file/649906/Transparency_in_Supply_Chains_A_Practical_Guide_2017.
pdf. [23 August 2019].
50
As above.
51
As above.
52
ECPAT USA 2017. “No Vacancy for Child Sex Traffickers Impact Report.” Available from: https://static1.squarespace.com/
static/594970e91b631b3571be12e2/t/59c9b6bfb07869cc5d792b8c/1506391761747/NoVacany_Report.pdf. [23 August 2019].

40

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statement

Endnotes

ABOUT THE AUTHORS
Minderoo Foundation’s Walk Free Initiative recognises that tackling
one of the world’s largest and most complex human rights issues
requires serious strategic thinking. We approach this challenge byintegrating world class research with direct engagement with some of
the world’s most influential government, business and religious leaders.
We invest our time and resources in a collaborative manner to drive
behaviour and legislative change to impact the lives of the estimated 40
million people living in modern slavery today.
WikiRate has developed an open access research platform thatallows anyone to systematically gather and report publicly available
information on corporate Environmental, Social and Governance(ESG) practices. By making corporate responsibility data accessible,
comparable and free for all, the organisation aims to provide society
with the tools it needs to encourage companies to respond to socialand environmental challenges.
Business & Human Rights Resource Centre is a high-impact, globalorganisation that works to advance respect for human rights in businessand hold companies accountable for abuse. The Resource Centre
operates the Modern Slavery Registry, a free and independent resourcethat holds over 10,000 company statements published pursuant to the
UK Modern Slavery Act 2015. The Registry is a resource that tracks
compliance with the legislation, increases transparency and helps holdcompanies accountable for their efforts to combat modern slavery.
Australian National University (ANU) College of Law is one of theworld’s top 15 law schools. As Australia’s national law school, we address
the major legal, social and political challenges of the 21st century byshaping and influencing public policy. The College makes a significant
contribution to the University’s five-star rating in Excellence in Research
Australia.

Beyond compliance in the hotel sector: A review of UK Modern Slavery Act statements

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MINDEROO.COM.AU/WALK-FREE