Human trafficking prevention policy

Template, not legal advice. Written for a fictional hotel to show what a policy under Hawaii's Act 191 (2026) can look like. A real hotel should check it against the final rules from the Department of Law Enforcement and have its own counsel review it.

1. Why we have this policy

Traffickers use hotel rooms because they are private and paid by the night, and workers can be exploited inside hotels too. Our staff are often the first to notice. This policy says what we expect, how to report, and how we protect the people who do.

2. Who it covers

Every employee of the Seabright, and every contract worker placed here by a staffing contractor, including part-time, seasonal and temporary staff.

3. What we expect

• Notice it. Know the signs taught in our training. Signs are behaviors and situations, never race, nationality, accent or looks.
• Don't confront. Do not question, accuse, follow, search or try to rescue anyone. Act normally and keep yourself safe.
• Report it. Report what you saw the same shift, using the steps below. You do not need to be sure.

4. How to report

1. Someone in danger right now: call 911 first. Then tell the manager on duty.
2. If a manager, the owner or a staffing agency may be involved, go straight to the hotline (1-888-373-7888) or the police.
3. Otherwise: tell the manager on duty or security, in person or by phone, the same shift. A supervisor who hears it first tells the manager on duty. Give the room or place, the time, what you saw or heard, and what you did.
4. Alone on a shift (for example, the night auditor): call the manager on call. If no one answers, call the hotline directly. A manager or security person is reachable by phone on every shift, and their numbers are posted at the desk.
5. The manager on duty follows the manager guide: writes the report down, contacts the National Human Trafficking Hotline (1-888-373-7888) or the Honolulu Police Department (911, or (808) 529-3111 when it is not an emergency), and keeps the report confidential. When a child may be involved, the manager also calls Child Welfare Services' child trafficking line, open 24 hours: (808) 832-1999 on Oahu, 1-888-398-1188 on the other islands.
6. Anyone may also contact the hotline directly, at any time: by phone, by texting HELP to 233733, by TTY at 711, or by live chat at humantraffickinghotline.org. It is confidential, has interpreters for more than 200 languages, and is not police or immigration.
7. Never post, text or group-chat about a suspected case, and never tell the people involved that a report was made.

5. Protection for people who report

No one will be disciplined, demoted or treated worse for a report made in good faith, even if it turns out to be nothing. Hawaii's law also protects a worker who reports in good faith under this policy from liability for trafficking that someone else commits, unless the worker knowingly helped.

A worker who is being exploited, by anyone, may ask any manager or Human Resources for help, or call the hotline directly. The Seabright will not discipline an employee, or ask an agency to remove a contract worker, because they asked for help. Free legal help for immigrant workers is available from the Hawai‘i Immigrant Justice Center at the Legal Aid Society of Hawaii, (808) 536-4302, on weekdays.

6. Training

Every employee and contract worker who has contact with guests or access to guest rooms completes human trafficking awareness training within 180 days of starting, and again at least every two years. The training will be the Attorney General's program or one the Attorney General has approved. Staffing contractors train their own contract workers and give us their records on request. (Our reading of the Act: it also treats a hotel that uses contract workers as an employer, so confirm with counsel who trains them.)

7. Records

Human Resources keeps a record of each completion: the person's name, role, the date, and the course. Records are available to the Department of Law Enforcement on request.

8. Signs

Human trafficking awareness signs, in the form the Department of Law Enforcement sets by rule, are posted where staff gather: the staff entrance, the break room, the laundry and the housekeeping office. Each sign is posted in English and in every other language spoken by at least ten percent of our staff and contract workers.

9. Review

The general manager reviews this policy every year and whenever the law or its rules change.

Based on Hawaii Act 191 (HB 1960, 2026): policy by September 1, 2027; training by December 1, 2027; signs by January 1, 2028. Contacts from the National Human Trafficking Hotline, DHS Blue Campaign and Honolulu Police Department, checked October 7, 2026; Child Welfare Services and the Legal Aid Society of Hawaii, checked October 8, 2026. The Seabright is a fictional hotel in a portfolio demo.