Five Questions for Business & Human Rights Leaders: Michelle Naggar, Starwood Hotels

Article One is pleased to launch our new interview series: Five Questions for Business & Human Rights Leaders. The series profiles leaders from business, civil society, and government who are working to advance corporate respect for human rights. Our inaugural interview is with Michelle Naggar, Vice President of Social Responsibility for Starwood Hotels & Resorts Worldwide, Inc.. Under Ms. Naggar’s leadership, Starwood has published a Human Rights Policy, conducted corporate- and country-level human rights impact assessments and established a Human Rights Council.  Ms. Naggar speaks with Article One about how she secured internal buy-in and what steps she is taking to advance industry practice globally.

1. As Vice President of Social Responsibility at Starwood Hotels you lead the company’s human rights work.  How were you able to ensure human rights was high on the company’s agenda?  

Creating a Human Rights strategy at Starwood Hotels didn’t happen overnight.  Prior to building a strategy, it was important to educate internal stakeholders on the UN Guiding Principles on Business and Human Rights (UNGPs), how our business may impact the rights of people around the world, and how interconnected these issues are throughout multiple functional areas.  In order to gain initial buy-in, we focused on areas of highest risk to our brands and operations, retelling the story of relevant incidences with a new lens.  By reframing the conversation, business leaders were able to better understand how human rights can be affected on large and small scales throughout our global operations. Once we raised awareness of the importance of getting in front of these concerns, rather than remaining solely reactive, we were able to proceed with a formal corporate Human Rights Impact Assessment.

2. What was the impetus for Starwood to focus on its human rights impacts?

Several years ago, there was a general effort to raise awareness across the hospitality industry about the risks of sex trafficking, and the role of hotel companies in mitigating those risks.  By training our associates on how to identify the signs of trafficking and the process to follow in order to report concerns, while keeping our associates safe, the industry has empowered hundreds of thousands of people to make a difference.  The focus on sex trafficking was the beginning, but as our awareness and knowledge increased, we realized that we wanted to play a more active role in addressing potential and actual human rights abuses that may be caused, directly or indirectly, by our operations. Through our corporate Human Rights Impact Assessment and Gaps Analysis, we were able to determine what we were already doing well as a company and where there was greater opportunity for impact in addressing human rights.

3. Starwood recently launched an Executive-Level Human Rights Council, how has that group helped embed respect for human rights throughout the company?

In 2015, Starwood formed an Executive-Level Human Rights Council (HRC), which is comprised of cross-functional members who represent multiple key disciplines for the company.  Their commitment to fully understanding human rights issues and embedding the Human Rights strategy throughout Starwood’s current systems, policies and operations has been integral in ensuring that our approach is integrated and consistent.  Our Human Rights Council is accountable for the progression of the overall strategy throughout the business.  Recently, our HRC released an updated Human Rights Policy that mentions multiple areas of the business, all of which are represented in HRC membership. 

4. The Starwood Foundation is sponsoring a human rights impact assessment of the hospitality sector in Mexico. What do you hope to accomplish through that assessment?

We saw immense value from conducting an HRIA for Starwood in the past, and we recognized the industry’s need to examine human rights impacts from a country level in order to really be able to address potential concerns and make a difference.  Like most significant efforts, in order to make progress you need to start small, so we picked one country, Mexico, to conduct the first assessment and learn from the experience of implementing recommendations.  Because of the nature of this work, it is not a competitive issue and all businesses as well as all stakeholders involved can benefit from access to the impact assessment results.  This is why we decided to conduct this effort through the Starwood Hotels & Resorts Worldwide Foundation, Inc., as a charitable effort that will be made public for use throughout the industry.  We hope that this effort will elevate the conversation on human rights throughout our industry, and inspire similar HRIA efforts to be conducted in high risk, popular tourism destinations around the globe.

 5. What recommendations do you have for other human rights champions seeking to advance corporate respect for human rights within their own companies?

Start at the top – make sure you have sponsorship at the highest levels of your organization.  Human rights can touch many sensitive and often controversial topics, and in order to make progress, there needs to be education of and buy-in from key executives.  The education piece includes internal understanding of the UNGPs, and what potential human rights risks exist throughout all aspects of the business.  The buy-in piece can only happen after company leaders feel fully informed and equipped to take the tough stand that may be needed when (not if) controversial issues arise.