Article One developed a five-step methodology to conduct the country-level assessment. The process was informed by guidance from the UN Guiding Principles on Business and Human Rights (UNGPs) and best practice guidance on assessing risks to foreign migrant workers.

The assessment was conducted in five steps. The first step included a gap analysis of IHG’s human resources policies and approach to management – globally and in Oman specifically – against the ITP Principles on Forced Labor and the Dhaka Principles for Migration with Dignity.

The second step included review of Oman-specific risks to foreign migrants and relied on desk-based research and interviews with international experts.

Based on the findings of the first two steps, Article One developed tools to support a field-level assessment. This included interview guides, focus group facilitation plans and guidance for hotels to effectively engage in the process.

Once the tools were created, Article One conducted in-person engagements at all seven IHG properties in Oman. The property-level engagement included interviews with hotel management, including hotel General Managers and Human Resources Managers, and focus groups with foreign migrant workers including:

  • Direct employees: Individuals hired directly by each hotel.
  • Casual labor: Individuals serving core functions of the business but employed by a third party, typically housekeeping and food and beverage staff.
  • Contract workers: Individuals performing specialized services and employed by a third party, typically performing services such as landscaping and pest control.

Article One conducted the interviews independently with a facilitator and note-taker present for each interview and focus groups. Hotel senior management were not present for any of the focus groups with workers. In total we spoke with 293 foreign workers across four cities in seven properties.

Once the country-level engagement was complete, Article One consolidated findings from all four phases and developed a final report with corresponding recommendations for IHG to proactively mitigate risks.


Most migrants travel willingly and legally to Oman with the expectation of employment in a variety of industries, including hospitality. Hotels rely heavily on foreign migrants to fill key roles, including housekeeping, cooking, and groundskeeping. According to Human Rights Watch there is a clear ‘north-south’ divide in the roles and responsibilities of migrant employees in the hotel industry, with those from poorer countries working at the lower skills end of the workforce spectrum and those from developed countries taking senior managerial and technical positions. Similarly, ILO research found that migrants generally work longer hours, accept lower wages, and tolerate poorer working conditions and more physically demanding jobs as opposed to nationals. This is compounded by the fact that migrants have no political rights or electoral opportunities in Oman.

The assessment findings mirrored country and industry level risks surfaced during the desk review. In general, Article One found that IHG has robust policies covering many of the expectations of the Dhaka Principles. In addition, we found significant variation in the experiences and issues raised by workers depending on the contractual agreement between worker and hotel. For direct employees, the overwhelming majority reported being treated with respect by management and guests. No employee reported paying for their job and all had access to their identity documents. On the other hand, casual and contract workers were much more likely to have experienced issues such as recruitment fees, retention of their identity documents and poor living conditions


Based the findings of the assessment, IHG commissioned Article One to develop Recruitment and Accommodation toolkits. These toolkits were designed to mitigate the risks of both forced labor and poor living conditions for migrant workers associated with hospitality work, but not directly employed by IHG, and direct employees.

The Recruitment toolkit provided checklists to help assess various stages of the recruitment process, including supplier selection and contractual negotiations. The Accommodation toolkit adapted OHCHR’s “The Right to Adequate Housing” guidance into a checklist. The checklist included clear contractual expectations for third party labor providers to provide adequate housing, including as it relates to affordability, availability of services, habitability, accessibility, cultural adequacy and so no.

IHG piloted the Toolkits in 2020 and, in 2021, built on them to develop the “Responsible Labour Requirements” for their owned, leased, and managed hotels. The Requirements set out minimum standards for responsible recruitment and onboarding, hotel staff living accommodation and grievance mechanisms. In 2022, IHG began the global roll-out of the Requirements and in 2023 will focus on risk-based based measuring and monitoring.