An estimated 40 million people live in modern slavery, more than ever before in human history, according to the 2018 Global Slavery Index. The International Labour Organization reports that slavery is an industry that generates $150 billion annually, and perpetrators profit off of society’s most vulnerable people—often women, children, and immigrants.

For two years, I worked for an anti-human trafficking organization in South Asia where I observed firsthand the impact of human trafficking. The abuse was hidden and took many forms; from teenage boys trafficked to work in plastic factories, to children as young as six forced to work in brick kilns, to young women and girls exploited and forced into servitude in brothels.

While it might be easy to assume that these kinds of labor conditions do not occur near your own home, for the past six years, California has had the highest number of reported cases of human trafficking in the United States. This is a complex issue and it can be difficult to know how to begin to confront it, but it is also possible to make progress, and companies have been recognized as key players in the fight against human trafficking. Companies such as Walmart and Target have both launched projects to ensure workers’ well-being throughout their supply chains. Delta, Ford, Coca-Cola, and Exxon Mobile are all part of a Global Business Coalition Against Human Trafficking. An employer of any size who works in an industry where victims of human trafficking may be encountered is uniquely positioned to make a difference.

Recently, California recognized the importance of the role that employers play in combating human trafficking through two new laws that went into effect on January 1, 2019: Senate Bill 970 and Assembly Bill 2034. These laws require hotel and motel employers, as well as transit employers, to provide education and resources regarding human trafficking to their employees. Additionally, employers at certain types of businesses, such as airports and urgent care centers, must comply with notice requirements. While the penalties for violations of these laws are relatively insignificant, the broader ramifications have a lasting impact.

Human Trafficking Training for Hotel and Motel Employers

Hotels are a common target for traffickers and, therefore, the hotel industry is uniquely positioned to prevent trafficking. However, prevention is only possible if employees know how to identify the signs. Training sessions can help hotels and their employees identify victims, protect hotel property and guests, and play an important role in preventing trafficking and exploitation. Many hotels are already leading the way in this area.

Under S.B. 970, by January 1, 2020, hotel and motel employers must provide at least 20 minutes of human trafficking awareness training and education to new and existing employees who are likely to come into contact with victims of human trafficking. This includes employees who have reoccurring interactions with the public, such as employees who work in a reception area, perform housekeeping duties, help customers in moving their possessions, or drive customers. This training must be provided once every two years. (Cal. Gov. Code §12950.3).

The mandatory training must include:

  • The definition of human trafficking and commercial exploitation of children;
  • Guidance on how to identify individuals most at risk for human trafficking;
  • The difference between labor and sex trafficking specific to the hotel sector;
  • Guidance on the role of hospitality employees in reporting and responding to this issue; and
  • The contact information of appropriate agencies.

Human Trafficking Training for Transit Employers

Perpetrators of human trafficking exploit transportation systems to operate. In response, the transit industry has helped to lead the frontline effort to combat human trafficking. For example, the U.S. Department of Transportation’s Transportation Leaders Against Human Trafficking (TLAHT) coalition has brought together more than 200 organizations to share resources and combat trafficking.

Under A.B. 2034, by January 1, 2021, businesses and establishments that operate intercity passenger rail systems, light rail systems, and bus stations, must provide at least 20 minutes of training to their employees regarding how to recognize the signs of and report human trafficking. (Cal. Civ. Code §52.6).

The mandatory training must include:

  • The definition of human trafficking, including sex trafficking and labor trafficking;
  • Myths and misconceptions about human trafficking;
  • Physical and mental signs to be aware of that may indicate that human trafficking is occurring;
  • Guidance on how to identify individuals most at risk for human trafficking;
  • Guidance on how to report human trafficking; and
  • Protocols for reporting human trafficking when on the job.

Posting of Notice

Existing California law requires specified businesses and establishments to post a Department of Justice (“DOJ”) approved notice containing information relating to slavery and human trafficking. (Cal. Civ. Code §52.6). Under the amended law, the Department of Justice was required to create an updated model notice by January 1, 2019. The model notice is posted on the Department of Justice’s website.

The following businesses and establishments are affected by the posting mandate:

  • On-sale general public premises licensees under the Alcoholic Beverage Control Act;
  • Adult or sexually oriented businesses;
  • Primary airports;
  • Intercity passenger rail or light rail stations;
  • Bus stations;
  • Truck stops;
  • Emergency rooms within general acute care hospitals;
  • Urgent care centers;
  • Farm labor contractors;
  • Privately operated job recruitment centers;
  • Roadside rest areas;
  • Businesses or establishments that offer massage or bodywork services for compensation;
  • Hotels, motels, and bed and breakfast inns.

The notice must be at least 8.5 inches by 11 inches in size, written in a 16-point font, and be provided in English, Spanish, and in one other language that is the most widely spoken language in the county where the establishment is located, unless English or Spanish is the most widely spoken language. The notice must include particular information regarding human trafficking and how to report suspected cases, as provided in the DOJ’s model notice.