Un-Trained: Human Trafficking Training for Employees and What HR Teams Should Cover
Updated: Oct 28
A housekeeper notices the same room has a "do not disturb" sign for days, with a steady stream of visitors. A line cook mentions that his boss keeps his passport "for safekeeping." Your employees see things like this before anyone else does. The question is whether they know what it means and who to tell.
Human trafficking training for employees is now required by law in several states for hotels, healthcare, and transportation, and federal contractors carry their own duties. This guide walks HR leaders, compliance officers, and managers through what a strong program covers, which laws may apply to you, and how to build a reporting path that protects workers and your company.
The short answer
Good human trafficking training for employees teaches staff what trafficking is (both labor and sex trafficking), the warning signs specific to their job, and exactly how to report a concern safely without confronting anyone. HR teams should also check state and federal rules, since some industries must train on a set schedule, use approved courses, and keep completion records.
Why does human trafficking training matter for employers?
Trafficking is not only a crime that happens somewhere else. In 2021, an estimated 27.6 million people were in forced labour worldwide on any given day, and the ILO found that 86% of cases were imposed by private actors, not governments (ILO, Walk Free, and IOM, 2022). The same report names services, manufacturing, construction, agriculture, and domestic work as the sectors that make up most adult forced labour.
In the U.S., Polaris has documented labor trafficking among workers on temporary visas in agriculture, domestic work, landscaping, hospitality, restaurants, and construction (Polaris). Its review of National Human Trafficking Hotline data also noted a rise in labor trafficking situations in the restaurant industry starting in late 2021 (Polaris Hotline Trends Report, 2023).
That means trafficking can touch your guests, your customers, your vendors, and sometimes your own workforce. A 2019 SHRM article put it simply: companies fight trafficking by teaching employees how to recognize it and how to respond (SHRM, 2019).
Is human trafficking training required by law for employees?
For many employers, yes. Requirements depend on your state, your industry, and whether you hold federal contracts. Here is a sample of verified rules. It is not a complete list, and laws change often.
Virginia hotels (Rule: Va. Code § 35.1-15.1; What it requires: Guest-facing staff, managers, and anyone with room access must complete a DCJS course or DCJS-approved alternative within six months of hire, then at least once every two calendar years. The free DCJS online course must be taken individually. The Virginia Department of Health enforces it.)
California hotels and motels (Rule: Gov. Code § 12950.3 (SB 970, 2018); What it requires: At least 20 minutes of interactive training for employees likely to come into contact with people being trafficked, within six months of starting the role and every two years after.)
Florida lodging (Rule: Fla. Stat. § 509.096; What it requires: Annual training for housekeeping and front desk staff, with new staff trained within 60 days. Fines can reach $2,000 per day.)
Texas lodging (Rule: HB 390 (2021) and Texas Attorney General guidance; What it requires: Annual training of at least 20 minutes from an AG-approved program, with new hires trained within 90 days and records kept.)
New York lodging (Rule: General Business Law, Article 12; What it requires: On-site recognition training for staff likely to interact with guests, with new employees trained within 60 days (Cole Schotz summary).)
Florida healthcare licensees (Rule: Fla. Stat. § 456.0341; What it requires: A one-hour board-approved course covering sex and labor trafficking, identification, reporting, and resources.)
Federal contractors (Rule: FAR 52.222-50; What it requires: All covered contractors must notify employees of the U.S. policy against trafficking and the consequences of violating it. Larger contracts performed outside the U.S. (over $700,000) require a full compliance plan with an awareness program.)
Two notes for HR teams. First, coverage is often defined by job duties, not job titles, so map roles carefully. Second, some laws require a specific course, a minimum length, or a certificate. A general awareness video may not satisfy them.
The legal details here are a starting point, not legal advice. Please confirm your obligations with qualified employment counsel or your state agency before you finalize a program.
What should human trafficking training for employees cover?
Whether or not a law applies to you, a strong program covers the same core ground. Use this as a checklist when you build or buy a course.
Core content checklist
[ ] A clear definition. Trafficking is the use of force, fraud, or coercion to get someone to work or perform commercial sex. Any commercial sex involving a minor is trafficking, no force required.
[ ] Labor and sex trafficking, side by side. Many courses lean on sex trafficking. California's hotel law specifically requires covering the difference between labor and sex trafficking in the hotel sector (SB 970).
[ ] Trafficking versus smuggling. Texas requires approved courses to explain this difference (Texas AG training standards). Smuggling is about crossing a border. Trafficking is about exploitation, and it can happen to U.S. citizens who never travel.
[ ] Role-specific warning signs. What a housekeeper sees is different from what a dispatcher or nurse sees.
[ ] How to report, step by step. Who to tell internally, when to call the hotline, and when to call 911.
[ ] What not to do. Never confront, follow, photograph, or post about a suspected trafficker or a person you think is being trafficked.
[ ] Trauma-informed language. Talk about people with respect. Say "person who was trafficked" or "survivor," not labels that define someone by what happened to them.
[ ] Non-retaliation. Employees need to hear, in writing, that good-faith reports will not cost them their jobs. Texas lodging law includes this protection (HB 390).
What warning signs should employees learn in different industries?
Generic lists help, but role-specific signs stick. Here are examples drawn from the sources above. One sign alone proves nothing. Several together are a reason to report.
Labor trafficking signs (any workplace, including your own supply chain)
Someone else holds a worker's passport or ID "for safekeeping" (Polaris).
Large recruitment fees or debts the worker can never seem to pay off (Polaris).
Threats of deportation, blacklisting, or police if the worker complains.
Housing controlled by the employer or recruiter, with limits on leaving.
Wages withheld, unpaid overtime, or pay that goes to someone else.
By industry
Hotels: Guests who are not allowed to speak for themselves, many visitors to one room, refusal of housekeeping for long periods.
Restaurants and retail: Workers who live on-site, seem afraid of a manager, or are always driven to and from shifts by the same person.
Logistics and trucking: Drivers are well placed to notice people being sold at truck stops and rest areas. Truckers Against Trafficking offers free industry-specific training.
Healthcare: A patient whose companion answers every question, holds their ID, or refuses to leave the room.
Staffing and HR itself: Third-party recruiters who charge workers fees, or job offers that change after arrival.
For hotels, the AHLA Foundation's No Room for Trafficking program offers a free 30-minute course. The Foundation says it has been completed more than 2.2 million times since 2020 and is available in 34 languages. Aviation employers can join DHS's free Blue Lightning Initiative, and the DHS Blue Campaign offers free awareness materials.
Want your team to practice these signs with a live trainer? Leaving The Jar's free course on the learning hub is a good first step.
How should HR set up a safe reporting process?
Training without a reporting path leaves employees stuck. Build the path before you roll out the course.
Name an internal contact. Pick a person or role (often HR, security, or compliance) who receives concerns 24/7 and knows the next steps.
Post the hotline. The National Human Trafficking Hotline is 1-888-373-7888, text 233733, or humantraffickinghotline.org. Many states also require hotline posters in certain businesses.
Set the 911 rule. If anyone is in immediate danger, call 911 first.
Write a no-confrontation rule. Staff observe and report. They never investigate.
Protect the reporter. Put non-retaliation in writing and mean it.
Protect the person. If the concern involves your own worker, keep it confidential and do not threaten their job or immigration status. The U.S. Department of Labor's Wage and Hour Division can certify T and U visa requests for some workers who experienced trafficking at work (DOL).
Keep records. Track who was trained, when, and with which course. Texas and New York lodging laws both require completion records.
Federal contractors: If FAR 52.222-50 applies, the Global Human Trafficking Hotline (1-844-888-FREE, help@befree.org) must be part of your compliance plan.
How often should employees get human trafficking training?
Follow the strictest rule that applies to you. Florida and Texas lodging laws require annual training, while Virginia and California set a two-year cycle with training within six months of hire. If no law applies, a reasonable pattern is training at onboarding, a short annual refresher, and deeper sessions for managers and high-contact roles.
Short and frequent beats long and forgotten. A 20 to 30 minute module each year, plus a quick scenario in a team meeting, keeps the signs fresh.
What you can do
This week: List every role that interacts with the public, guests, patients, drivers, or contract workers. Check which state rules cover them.
This month: Choose a course that meets any legal requirements. Add role-specific scenarios.
This quarter: Publish your reporting process, post the hotline, and train managers first so they can answer questions.
Every year: Audit completion records and review recruiter and staffing agency practices for worker-paid fees.
Leaving The Jar can help. Our Free In Truth Training (FITT) is a free trafficking-awareness training for businesses, schools, churches, and community groups. It covers what trafficking is, warning signs, boundaries, trauma-informed responses, and safe reporting. As a 100% volunteer-run nonprofit, we have trained more than 2,000 people, including 1,020+ in 2025 across 24 sessions and events. Companies that want to go further can partner with us or host an event.
FAQ
Do all employers have to provide human trafficking training?
No. There is no single federal rule requiring every U.S. employer to train staff. Requirements usually apply to specific industries in specific states, such as hotels in Virginia, California, Florida, Texas, and New York, or licensed healthcare workers in Florida. Federal contractors must notify employees of the government's anti-trafficking policy under FAR 52.222-50. Even when no law applies, training is a smart, low-cost way to protect workers and customers.
How long should human trafficking training be?
Several state laws set a floor of about 20 minutes, as in California and Texas hotel rules, while Florida's healthcare course is one hour. Free industry courses such as AHLA's program run about 30 minutes. For most employers, a 20 to 45 minute core module plus short role-specific refreshers works well. Managers and HR staff who receive reports benefit from longer, live training.
Should we train employees on labor trafficking or just sex trafficking?
Both. Many people picture only sex trafficking, but the ILO estimates that most forced labour worldwide happens in the private economy, in industries like services, construction, and agriculture. Restaurants, hotels, staffing, and logistics employers should pay special attention to labor trafficking signs, including recruitment debt, confiscated documents, and withheld wages.
What should an employee do if they suspect trafficking at work?
Stay calm and do not confront anyone. If someone is in immediate danger, call 911. Otherwise, tell the designated internal contact and call the National Human Trafficking Hotline at 1-888-373-7888 or text 233733. Write down what you saw, including times and descriptions, but do not take photos of people or post anything online.
Can a nonprofit train our employees for free?
Yes. Leaving The Jar offers Free In Truth Training (FITT) for businesses and community groups at no cost. If your state requires a specific approved course, such as Virginia's DCJS course for hotel staff, use that course for compliance and add live training to deepen understanding and build a culture where people feel safe to speak up.
Ready to train your team?
Request a free FITT training for your workplace and give your employees the confidence to recognize trafficking and report it safely.
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