Risk management and the prevention of human trafficking

The U.S. Department of State estimates more than 24.9 million adults and children are subjected to human trafficking around the world today. Increasing awareness and educating staff on human trafficking (also known as modern slavery) is key to identifying this activity and understanding best practices.

As defined by the Department of Defense, human trafficking is a crime in which force, fraud or coercion is used to compel a person to perform labor, services or commercial sex. It affects all populations: adults, children, men, women, foreign nationals and U.S. citizens, and all economic classes. 

Human trafficking occurs every day and across every industry and geography, but the hospitality industry, with its unique combination of privacy and anonymity, is a frequent target. Hotels and motels can be especially attractive locations for trafficking, though human trafficking also occurs in all forms across all areas for the tourism industry—at sporting events and theme parks, on cruise ships and public transportation. Because of the elevated risk in these locations, it is imperative that staff members are taught how to recognize the signs and trained on appropriate next steps. 

Potential Human Trafficking Indicators

As risk-management specialists, we’re frequently asked by our client partners to help with education and training materials about this issue. We’re pleased to help our insureds develop targeted programs and would urge all hospitality organizations to similarly prioritize human trafficking as a key area of risk-management focus. If your organization doesn’t currently have a human trafficking awareness program, it’s important that one is implemented. 

A great starting point is the Department of Homeland Security Blue Campaign. Here you will find a complete document library as well as videos to help implement your plan. The materials on this page, which are available in 17 languages, are designed to increase public awareness and educate the community, with helpful information like this list of common indicators that could suggest an individual may be the victim of trafficking:

  • Is a juvenile engaged in commercial sex acts?
  • Has there been a sudden or dramatic change in behavior?
  • Does the person have bruises in various stages of healing?
  • Is the person fearful or timid?
  • Does the person show signs of having been denied food, water, sleep or medical care?
  • Does the person not talk in front of others and let others talk for them? Does the person appear to be coached on what to say?
  • Does the person have freedom of movement? Can the person freely leave where they live? Are there unreasonable security measures?

It’s important to note that these indicators may not be present in every situation and the presence or absence of these indicators is not necessarily proof of human trafficking. But training your team to watch for these indicators can help to create a culture of awareness around the topic.

How Human Traffickers Operate

Human traffickers use coercion, threats and fraud to control their victims. It is important to recognize that human trafficking does not require a person to be moved from one place to another. As mentioned earlier, human trafficking is the exploitation of the person. Human smuggling is transportation based and these are not interchangeable terms.

Identifying potential victims, understanding behaviors and scenarios associated with human trafficking and being educated on company policies on how to report and respond to human trafficking is critical. Often, victims are unnoticeable. Signs of human trafficking can be present in the workplace, in the behavior of the employee or in the behavior of the trafficker, so staff members have to know what to watch for. 

According to the 2020 National Human Trafficking Hotline Report, a total of 51,667 substantive phone calls, text, webchats, e-mails or online tips were received in 2020 alone. Each contact was evaluated for potential human trafficking and, if cause was found, handed over to the local authorities to address. Of the total number reported, 10,583 were deemed potential human trafficking incidents with 70 percent being sex-related, 13 percent labor-related and the remainder considered unclassified. 

How to Spot Concerns and What to Do Next

It is important that if trafficking is suspected, the victim or the trafficker is not confronted. Employees should be trained on how to report their suspicions to allow law enforcement to investigate.

Educating staff, both new hires and existing team members, to recognize and report signs of trafficking is a practice that should be continued throughout the year. Providing the appropriate training in addition to sharing safety tips and best practices on at least a monthly basis recommended. The communication does not have to be in-depth, but the message needs to be consistent and reinforce the expectation for staff to follow a “see something, say something” mentality. 

From a risk-management perspective, implementing a written, effectively communicated and enforced human trafficking awareness program within your organization will help to reduce trafficking-type incidents. Ensuring that the program is understood by all employees will provide a higher potential of success at eliminating this practice.  

Christine Sullivan is SVP, risk control services leader at Sompo Global Risk Solutions. Glen O’Connor is SVP, risk control services technical director at Sompo Global Risk Solutions.