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The hidden crime in hospitality

Several prominent hotel chains have faced lawsuits for allegedly turning a blind eye to human trafficking on their premises. These cases often point to hotel staff’s failure to act on evident red flags, like frequent cash payments, a refusal of housekeeping services, and rapid guest turnover. Some lawsuits claim that these hotels profited from trafficking, making them legally accountable under the Trafficking Victims Protection Act (TVPA).

Recently, Sean “P. Diddy” Combs was arrested and charged in Manhattan federal court with racketeering conspiracy, sex trafficking, and transportation for prostitution. The indictment alleges that, from 2008 to the present, Combs led a criminal enterprise involved in sex trafficking, forced labor, kidnapping, and other crimes, leveraging his business empire to facilitate abuse and exploitation. These alleged crimes took place at high-profile hotels and this case highlights the importance of recognizing and reporting such activities, as even prominent figures can be involved in these hidden crimes.

A report from the Human Trafficking Institute highlights that 170 human trafficking lawsuits were filed against hotels in 2019 and 2020. These lawsuits often focus on hotel management companies and franchisees, accusing them of profiting from illegal trafficking activities. Hotels, particularly in high-trafficking districts like the Southern District of New York, responded by tightening policies and training staff to recognize and report suspicious activities. The American Hotel and Lodging Association (AHLA) has also launched the “No Room for Trafficking” campaign, urging hotels to take a stand by training staff, displaying anti-trafficking signage, and creating company-wide reporting policies​.

The prevalence of human trafficking

Human trafficking is an ongoing issue in the United States, with an estimated 200,000 incidents annually. While trafficking victims are exploited across various industries, hospitality and agriculture are often primary targets. States like California, Texas, and Florida see the highest rates of reported trafficking cases due to their large populations and high migration levels. In 2020 alone, 8,839 trafficking cases were reported across the country​.

Despite significant interventions, like the National Human Trafficking Hotline, which handled more than 50,000 contacts in 2021, many cases still go unreported. As a result, the true scope of human trafficking remains difficult to measure.

The role of whistleblowing and incident management

Why whistleblowing is essential

Whistleblowing platforms provide a confidential space for employees to report illegal or unethical behavior without fear of retaliation. In the hospitality industry, staff are often the first line of defense against human trafficking. By empowering employees to speak up about suspicious behavior, companies can prevent human trafficking activities on their premises. Moreover, creating a transparent, safe reporting culture strengthens legal and ethical accountability.

Incident management solutions – A crucial tool

For businesses in high-risk sectors like hospitality, having an incident management solution that tracks reports, automates case workflows, and ensures follow-up is essential. These solutions help manage complex reports and investigations, providing a clear path for resolving issues and ensuring accountability. NAVEX One Whistleblowing and Incident Management solution is an example of a platform designed to handle sensitive cases like trafficking reports efficiently and confidentially​.

The importance of training

The injustices of modern slavery and human trafficking are global issues that can manifest anywhere, including in the hospitality industry. To keep these crimes out of the workplace, supply chain, and beyond, organizations must prioritize employee training to understand the necessary actions to take. The NAVEX Modern Slavery and Human Trafficking course helps learners understand these crimes – how they occur, what they look like, and the warning signs to watch for. Employees also learn the steps to take when they suspect trafficking and the importance of ensuring third-party partners are socially and ethically responsible.

For the hospitality industry specifically, this course covers red flags like suspicious guest requests and room conditions that could indicate trafficking activities. Comprehensive training like this is vital for fostering an ethical culture and empowering employees to help combat these injustices.

Why the hospitality industry needs these solutions

Hotels are uniquely vulnerable to trafficking due to their transient nature and the anonymity provided to guests. With proper tools, including incident management platforms, and policies and procedures designed to identify and follow up on suspected incidents, the hospitality industry can better protect both its staff and its guests from becoming unwitting participants in human trafficking.

In addition to the moral and legal imperatives, hotels face significant financial and reputational risks if they fail to act. As lawsuits increase, implementing comprehensive solutions that prioritize the safety and well-being of all parties is no longer optional – it’s essential for both ethical operations and legal compliance.

The path forward

Moving forward, the hospitality industry must continue to invest in training, policies and technologies that help identify and stop human trafficking. Combining whistleblowing platforms with incident management solutions are critical to ensure every suspicious activity is addressed effectively. Together, we can make a meaningful impact in preventing human trafficking in the places where people expect to feel safe.


If you suspect human trafficking, report it to the National Human Trafficking Hotline:
1-888-373-7888 | TTY: 711 | Text: 233733 | humantraffickinghotline.org