Free Enterprise - The FindLaw Small Business Law Blog

Why the Hospitality Industry Must Train Employees to Spot Human Trafficking

When most of us think "human trafficking," we think of semi trucks loaded with immigrants, some tragically not surviving the journey. We're generally not thinking about $700/night Ritz-Carlton hotels in Beaver Creek, Colorado.

But human trafficking has many different faces, requiring many different people to be vigilant in the fight against it. Recently, the focus has turned to training employees and managers in restaurants, hotels, and others in the hospitality industry to prevent, spot, and report human trafficking. Here's why:

Where Human Trafficking Occurs and Why

As Fast Company reports, hotels and resorts have become a focal point in human trafficking. Ritz-Carlton team trainer Wendy Hunter told the publication about a family who rented a condo and "enslaved a foreign couple to do their cleaning and other chores" before being detecting by resort staff. And hotels from Philadelphia to Houston to Salisubry, Maryland have been sued for failing to address sex trafficking at their locations. And states are passing laws requiring hotels and motels to train staff to spot human trafficking and creating civil liability for hotels that turn a blind eye to trafficking.

Airlines are also being asked to join the fight, and Stanford even offers a course in human trafficking awareness, "designed for employees, managers, and patrons of restaurants and hotels... aiming to educate individuals on how to spot [trafficking] and what to do about it in their own communities."

How to Spot and Prevent Human Trafficking

Whether you're doing it to protect your establishment's reputation or to comply with local, state, or federal law, how do you go about training staff to spot human trafficking? The Department of Homeland Security has resources to help, depending on your business and your staff:

  • HOTEL AND MOTEL STAFF: Should look for patrons showing signs of malnourishment, poor hygiene, fatigue, sleep deprivation, untreated illness, injuries, and/or unusual behavior; patrons lacking freedom of movement or are constantly monitored; or patrons who dress inappropriately for their age or have lower quality clothing compared to others in their party;
  • HOUSEKEEPING, MAINTENANCE, AND ROOM SERVICE STAFF: Should look for requests for room or housekeeping services but denials for hotel/motel staff entry into room; and presence of multiple computers, cell phones, pagers, credit card swipers, or other technology;
  • CONCIERGE, BELLMAN, FRONT DESK, SECURITY & VALET STAFF: Should look for the same person reserves multiple rooms; rooms rented hourly, less than a day, or for long-term stay that does not appear normal; or patrons selling items to or begging from other patrons or staff; and
  • FOOD & BEVERAGE STAFF: Should look for patrons loitering and soliciting other, usually male patrons; patrons waiting at a table or bar and picked up by a male (trafficker or customer); and patrons asking staff or other patrons for food or money.

To learn about your legal obligations or to set up a training program for your business and employees, contact a local attorney for help.

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