Beyond Compliance in the Hotel Sector: A Review of UK Modern Slavery Act Statements

The travel and tourism industry continues to see uninterrupted growth, with more people than ever before traveling for work or leisure to a broader range of destinations. Yet this growth brings with it 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 the employment of workers, even in countries where abuse is endemic.

To assess how the hotel sector is responding to these risks, this report reviews the statements produced by 71 hotel companies under the UK Modern Slavery Act, which requires companies with a turnover of £36 million to release annual statements on their anti-slavery 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 labor, 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 more detailed disclosure and demonstrate a much better understanding of the well-publicized risks in the sector. However, the findings show a disappointing lack of effort to protect against labor 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).

These failures can be explained by a lack of commitment by hotel companies to prioritize the elimination of modern slavery, and the weakness of the legislation to change corporate behavior and hold laggard 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. Hotel companies 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 of modern 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.

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

Read the full report here.