Under new regulations by the NJ Department of Community Affairs, hotels and motels in New Jersey must train owners, operators and staff how to recognize signs of human trafficking.
Employers must post educational posters about human trafficking and require employees to watch an educational video as a condition of employment.
The regulation applies to all hotels and motels regardless of how many employees they have. Any license, permit, certificate, or approval under New Jersey’s Hotel and Multiple Dwelling Law may be at risk if the hotel or motel does not verify its employees have completed the required training.
According to the law firm Jackson Lewis, NJBIA’s HR legal hotline provider, the video advises workers to look for signs like a hotel guest who prevents another individual from speaking for himself or herself, or a guest controlling another’s identification documents. It also explains what viewers should and should not do in response to a situation in which human trafficking may be suspected.
“Among other things, the video instructs viewers to report any concerns of human trafficking to management and security,” attorneys David Islinger and Eliza Lloyd state. “Viewers are cautioned not to falsely accuse or relay suspicions of human trafficking directly to the hotel guest, as there may be an alternative explanation.”
Jackson Lewis advises covered employers to:
- Ensure current employees working in management, at the front desk or in registration, in janitorial or housekeeping services, or in security watch the training video available at the Department’s website;
- Include the video as part of the hiring process for new employees;
- Maintain a list of current employees who have watched the video, identifying their names, positions, and the dates on which they watched the video; and
- File the Bureau of Housing Inspection’s certification form with the hotel’s or motel’s application for a certificate of inspection.