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A new report produced by the Walk Free initiative of Minderoo Foundation, in partnership with Business & Human Rights Resource Centre, WikiRate, and Australian National University assesses 71 hotel companies against the requirements of the UK Modern Slavery Act.

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 the employment of workers, even in countries where abuse is endemic.

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 more detailed disclosure and demonstrate a much better understanding of 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.

Key Findings

• Only 25% of hotel companies met the minimum requirements of the UK Modern Slavery Act.
• 68% of hotel companies did not disclose any information about the risks in their direct operations and their supply chains, including how they check and address risks to workers.
• Just 8% of hotel companies prohibit workers being charged recruitment fees, thereby protected migrant workers from debt bondage.
• Only 14% of hotel companies reported specific policies to prevent the sexual exploitation of workers.

Since producing the report, we have received updates and clarifications detailed below.

Recommendations

UK Government should

• Publish a list of companies required to report under the UK Modern Slavery Act.
• Create or nominate a body to monitor corporate compliance with the UK Modern Slavery Act.
• Bring the Registry of corporate compliance into the UK Home Office, or similar government department.
• Implement its principles for nations to tackle modern slavery in supply chains.
• 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.

Companies should

• Implement due diligence with a focus on sector specific risks.
• Engage in pe-competitive collaboration with peers.
• Improve transparency.

What people are saying

Dame Sara Thornton, UK Independent Anti-Slavery Commissioner, said:

“This new report takes an innovative and data-driven approach to assessing modern slavery statements produced by hotel companies, with volunteers across the academic and online communities checking statements against legal requirements and additional metrics.

Compliance with the reporting requirements of the Act remains a significant issue and the quality of statements varies enormously. This is true of the hotel sector, where complex supply chains and seasonal labour present additional challenges, potentially increasing the risk of modern slavery taking place.

Taking a sector-specific approach is important and revealing. It is disappointing that only 25% of hotel companies in scope of the Act are found to meet the minimum requirements. I hope the information revealed by this report go some way towards alleviating this risk.”

Jen Morris, CEO of Walk Free Foundation said:

"Despite the introduction of the UK Modern Slavery Act four years ago, this report shows hotels are failing to meet the legal reporting requirements, let alone moving beyond compliance to protect against modern slavery risks.

"Everybody loves to go on holiday but how would you feel if the porter taking your suitcase was a migrant worker trapped in debt bondage? Or if the person cleaning your room was forced to work long hours for little pay? It is a sobering reality that requires action from the hotel sector.

"It comes down to two things: a lack of commitment by hotel companies to do the right thing, and a failure of the UK Government to hold companies to account.

"Without effective implementation and a renewed commitment from business to combat modern slavery, the estimated 16 million people in forced labour in the private economy around the world remain at risk."

Shiva Foundation said:

“This report allows us to have a clearer picture of the level and quality of compliance with the Modern Slavery Act 2015 in the hotel sector. The evidence revealed in this document shows there is a need for more vigorous law enforcement from the government and a higher level of commitment from hotel companies. It will also help hotel clients to make informed decisions when using hotel services individually or at a corporate level. Consumers are a driving force in transforming the industry by demanding actions and transparency to tackle modern slavery."

"We would also like to point out that this report only shows the tip of the iceberg since most of the hotels in the UK do not meet the £36M threshold set by the government legislation. If an important proportion of the big players are underperforming as proven by this research, what is happening in the rest of the sector?"

Visit the Modern Slavery Registry

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Company updates

Accor UK Business & Leisure Hotels Limited Modern confirmed it has a modern slavery statement available here.

Four Seasons Hotels and Resorts confirmed it has a modern slavery statement available here.