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Modern Slavery Risks in the Travel Industry
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BBC Report Signals Heightened Scrutiny
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The BBC reported today that the UK has recorded the highest number of potential modern slavery victims ever referred through official channels, with over 23,000 cases in 2025 – a 22% increase on the previous year. The reporting draws on new warnings from the Independent Anti‑Slavery Commissioner that rising living costs, insecure work and technology‑enabled recruitment are accelerating labour exploitation across the UK economy. For businesses operating in the travel, hospitality and leisure sector, this coverage is a timely reminder that modern slavery risk remains a significant legal, operational and reputational issue.
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Travel industry employers face heightened exposure
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The travel industry often relies on migrant and overseas labour, extensively uses agency workers and subcontractors and often takes on seasonal and short‑term roles with a high turnover. Not to mention the international aspect of labour supply chains spanning multiple jurisdictions. Modern slavery and labour exploitation frequently occur outside the direct employment relationship in the travel industry, often further down the supply chain – particularly in cleaning, housekeeping, catering, transport and facilities services.
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Under section 54 of the Modern Slavery Act 2015, organisations with turnover above £36 million must publish an annual modern slavery statement. However, recent developments mean that simply publishing a statement is no longer sufficient. Updated UK Government guidance (2025) sets significantly higher expectations around meaningful risk assessment, due diligence and action. Enforcement trends show increasing regulatory and prosecutorial interest where businesses fail to address foreseeable labour risks, even where exploitation is perpetrated by third parties. International employers must also consider evolving EU and global supply‑chain due‑diligence regimes, which may apply via overseas operations or commercial partners.
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Providing a statement that is generic or unsupported by evidence now carries real reputational and legal risk, and news also spreads fast with social media scrutiny often moving faster than formal enforcement. For the travel industry, where trust, ethical reputation and workforce practices directly influence customer choice—adverse publicity can cause immediate commercial harm, including loss of corporate contracts, investor concern and customer disengagement.
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What should Travel Employers do?
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As a travel employer we suggest that you map labour supply chains to understand who supplies your workers at every level. We also suggest reviewing your agency, recruitment and sponsorship arrangements, and ensure that your managers and supervisors are trained to recognise indicators of exploitation
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It would also be sensible to stress‑test your modern slavery statements against the question: Can we evidence meaningful action if challenged?
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The BBC’s latest reporting reinforces a clear trend: modern slavery risk is no longer viewed as a distant or purely criminal issue. Businesses are increasingly expected to take active, preventive responsibility for labour conditions across their operations and supply chains.
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Travel employers that act now will be best placed to mitigate legal exposure, protect their workforce and safeguard brand value.
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Protect Your Business with the Travlaw HR Retainer
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Employment law, like the Travel Industry, is always moving. That’s why we’ve created a service that gives you simple, cost‑certain access to expert employment law advice when you need it – the Travlaw HR Retainer – a comprehensive support package designed specifically for employers across the travel, tourism, leisure, hospitality, and visitor attraction industries.
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With the Travlaw HR Retainer, we can offer:
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| | | • | A full written compliance audit of your employment contracts, policies and procedures
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| | • | Drafting of letters, documents, policies, and detailed advice notes
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| | • | Sense‑checks on your existing HR processes and documentation
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| | • | Practical, commercially‑driven advice from specialists who work with the travel industry every day
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| | • | Access to our employment law team for routine and day‑to‑day HR matters
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| | | | • | A full written compliance audit of your employment contracts, policies and procedures
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| | • | Drafting of letters, documents, policies, and detailed advice notes
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| | • | Sense‑checks on your existing HR processes and documentation
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| | • | Practical, commercially‑driven advice from specialists who work with the travel industry every day
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| | • | Access to our employment law team for routine and day‑to‑day HR matters
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You’d also gain direct access to Ami Naru, Partner and Head of Employment, and her industry‑leading team — trusted advisors to many of the UK’s most recognised travel brands.
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Our retainers are designed to fit you and your business – and we’ll be as involved as much or as little as you decide.
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If you would like advice on modern slavery compliance, labour supply‑chain risk, or reviewing employment and contractor arrangements within the travel sector;
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Contact us on 01132580033 or email ami@travlaw.co.uk to start the conversation!
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