This is the second part of an article that talks about the urgency of combatting human trafficking and hospitality’s role in eliminating this scourge. To read part one, click here.
What Florida’s hotels need to know about growing human trafficking risks
by STEFAN BURKEY
Florida has a human trafficking problem the state’s policymakers hope to solve through new legislation passed in 2023, designed to crack down on offenders.
The state’s hospitality industry was directly in legislators’ line of sight as they tightened enforcement standards for employee training about trafficking and signage requirements. In another move, they closed a legal loophole that allowed non-complying hotels to avoid fines.
The legislative crackdown occurred after an investigation by the South Florida Sun Sentinel found in 2022 that 14,000 citations had been issued to 6,669 hotels and other public lodging establishments for violating those requirements since 2019. While fines of as much as $2,000 a day are called for, not one had been issued by the Florida Department of Business and Professional Regulation.
FLORIDA HOTELS AND THE HUMAN TRAFFICKING RISK
Florida has the third-most reported human trafficking cases – not just for sex, but for forced labor – in the U.S. The Global Slavery Index has found that globally, hotels and motels are implicated in 60% of cases. And it isn’t just second-rate properties being implicated; the largest and most respected chains are among those that have been sued in the growing number of lawsuits by sex trafficking victims looking for accountability.
The industry is keenly aware that human trafficking is wrong on every level, leading both industry groups and hotels to step up their efforts to prevent it.
Alongside industry groups, hospitality brands have been proactive in this fight. More than one million Marriott associates have completed 570,000-plus hours of the chain’s specialized risk training to identify potential victims, monitor situations, and act on them. Another 800,000 employees at rival chains have also participated in the program. Just as important, these brands continue to support government and non-governmental organizations dedicated to preventing and disrupting human trafficking.
In addition, carriers are adding exclusions in the liability and umbrella policies exposing clients to future claims against their hotels, so it’s critical hotels maintain records for employee training (new hires and current employees on an annual basis) and have ready for potential audits since this is required by many states and the franchise.
THE CHALLENGES OF DETECTING TRAFFICKING
Strong risk-management measures have never been more important. And while awareness training and signage are essential components, technological advances make it harder than ever for hotel staff to even be aware the crime is underway.
Contactless technology, for example, has been a boon to hotels and guests during the pandemic, and it has caught on permanently. The U.S. “contactless stays” market – with little, if any, human interaction at any stage of the guest journey – reached $40.3 billion in 2023 and is expect to hit $304.6 billion by 2032.
That lack of human interaction makes it difficult to identify trafficking situations, much less for victims to receive help. But hotels also can use their heightened deployment of technology to counter such abuse. Beyond using tech tools to provide prompts for staff on human trafficking indicators or schedule online awareness training, they can enable hotel security departments to effectively monitor for prevention.
For example, they can monitor guestroom door activity – how often the door is opened, and whether it’s from the outside (keyless) or inside. A frequent number of openings can be a red flag. Technology also can regulate who has access to the elevators, limiting non-guests unless accompanied by a guest or employee. And smartphone text messaging can provide safer interventions, provided it’s framed as a simple service check done for all guests.
DETERRING FORCED LABOR
Forced labor is another trafficking concern for the hospitality industry. This is where individuals are forced, deceived, or coerced to work at, for example, below the minimum age or pay (if any), in debt bondage or other conditions of modern slavery. It’s more likely to occur among hotels, motels, and resorts that depend on specialized recruitment agencies that may have a dubious track record.
Non-native workers unfamiliar with the legal system are at high risk, often bonded through fees for transport and visas before they’ve earned any money. Passports and wages also may be withheld by employers, keeping them from leaving their jobs.
Also at risk are J-1 cultural exchange workers – “guest” workers in the U.S. training in their career fields or for summer work and travel experience. It’s not uncommon for them to pay a substantial sum to a recruitment agency for a below-minimum-wage job, and for the work itself to be misaligned with the individual’s career path – the manager trainee doing housecleaning, for example. Conditions can also lead to human trafficking.
A report by The Human Trafficking Legal Center noted that 72% of civil actions under the Trafficking Victims Protection Reauthorization Act involved at least one corporate defendant. The U.S. Department of Labor’s Wage and Hour Division has stepped up its involvement in preventing and protecting victims, including calculating restitution when requested by legal authorities.
Stefan Burkey is the hospitality practice leader for HUB International Florida. In this role, he oversees insurance placement solutions for owners, developers, and operators from limited-service hotels to full-scale resorts. Stefan and his team clearly understand the financial needs and exposures associated with the hospitality industry, and their singular focus has generated profound market knowledge and significant buying power for HUB clients throughout Florida and the U.S.
