Business Travel Duty of Care: 7 Gaps in Most Travel Policies
Your travel policy runs to four pages. Booking channels, cabin class, expense limits, approval thresholds, preferred hotel chains. It is a procurement document, and as a procurement document it is probably good.
It is not a duty of care document, and most organisations own only the first kind. That distinction matters because the employer's obligation to an employee does not pause at the airport. The duty under section 2 of the Health and Safety at Work etc. Act 1974 attaches to the employment relationship rather than to the premises, and the obligation to assess risks to employees under regulation 3 of the Management of Health and Safety at Work Regulations 1999 does not carve out work performed abroad. Separately, and in many jurisdictions more consequentially, a common law duty of care follows the traveller.
Seven gaps recur, and each is more visible after an incident than before one.
1. No assessment of the trip, only approval of the cost
The foundational gap. Trips are approved on budget and business justification, and nobody asks what the risk actually is.
A structured programme assesses the traveller, the destination and the activity together. A senior partner flying to a familiar European city for two nights is a different proposition from a junior analyst on a first overseas assignment to an unfamiliar location, staying two weeks and moving between sites, and the two should not receive identical treatment because they cost the same.
The practical version is a short pre-travel assessment proportionate to the trip, with a route for escalating the unusual ones. The FCDO's foreign travel advice is the natural starting reference for destination risk, and the World Health Organization publishes guidance on travel and health.
2. Ignoring the largest actual risk
Ask an executive what threatens a business traveller and the answers tend towards the dramatic. The mundane answer is road transport.
Journeys to and from airports, unfamiliar road conditions, local driving standards, long transfers after overnight flights, and fatigue at the wheel account for a substantial share of serious harm to business travellers. HSE's guidance on driving and riding safely for work addresses the domestic version of the same problem, and the principles transfer.
Controls are unglamorous and effective: vetted transport providers rather than whatever is outside the terminal, restrictions on self-driving in unfamiliar territory, limits on driving after long flights, and journey planning for anything substantial.
3. Treating the standard as unavailable
ISO 31030:2021, travel risk management guidance for organizations, sets out a structured approach to exactly this problem. It covers organisational preparedness, preparation for travel, the travel itself, and what happens afterwards, and it aligns with ISO 45001 and the wider risk management framework.
Two features make it more useful than most organisations assume. It is guidance rather than a certifiable requirements standard, so there is no audit to pass and no certificate to buy, which means you can adopt the parts that fit your travel footprint proportionately. And it is increasingly treated as the reference point for what a reasonable employer does, appearing in insurance assessments and procurement questions.
An organisation that has never heard of it is not non-compliant. An organisation whose arrangements diverge substantially from it, having had an incident, is in a weaker position than one whose arrangements broadly align.
4. Defining the traveller too narrowly
Policies are written for employees, and the population that travels is wider than that.
Contractors, agency staff, secondees, non-executive directors and, in professional firms, partners who are not employees at all. The definitional question is the same one that arises whenever your people work at a client site: duties can attach to people who are not on your payroll, and the arrangement that covers only employees leaves the others outside every control you have built.
Decide who is in scope deliberately rather than by default, and state it.
5. No mechanism during the trip
Most policies stop at departure. Something happens, and the organisation discovers it has no way of knowing where someone is, no agreed contact route, and no plan.
Three components close it, and none requires an expensive platform for an organisation of modest size. A record of who is where and when, held somewhere retrievable rather than in a booking inbox. An agreed contact point that operates outside business hours in the traveller's time zone, not yours. And a documented escalation route covering medical events, security incidents and disruption, including who has authority to spend money at two in the morning.
The last one is what actually fails. Decisions get delayed because nobody knows who can authorise a private ambulance or an early flight home.
6. Assuming insurance is the plan
Insurance is the funding mechanism. It is not the response, and it is not a defence to a failure to assess.
Two checks are worth running annually. Does the cover match where people actually go, including any destinations subject to advisories, and does it match what they actually do when they are there. And does the assistance provider's service level correspond to what you have told employees to expect, particularly on medical evacuation and on locations away from major cities.
An organisation that has confirmed both is in a materially better position than one that has a policy number.
7. Nothing happens afterwards
The most consistently absent element. Travel incidents, near misses and health events after return are rarely captured, so the same exposures repeat.
Two habits fix it. Capture travel-related incidents in the same register as everything else, so patterns become visible across destinations, providers and trip types. And check in after significant trips, particularly long-haul, extended assignments, and travel to demanding environments, because the health effects frequently appear after return rather than during. Where the traveller's role also involves difficult content or environments, the psychosocial dimension belongs here too rather than being treated separately.
What a proportionate programme covers
| Stage | Minimum for most organisations | Add for higher-risk travel | |---|---|---| | Policy | Scope stating who is covered, including non-employees | Approval thresholds by destination and traveller | | Before | Short pre-travel assessment, destination and health check | Briefing, training, medical clearance | | Transport | Vetted ground transport, limits on self-driving | Journey management and route planning | | During | Location record, out-of-hours contact, escalation route with spending authority | Active monitoring, check-in schedule | | Insurance | Cover matched to destinations and activities, assistance service confirmed | Evacuation planning tested | | After | Incidents captured in the main register | Post-trip check-in, health follow-up |
The left-hand column is achievable for an organisation of any size and costs very little. The common failure is not that firms choose the wrong column. It is that they have neither, because travel was owned by finance and health and safety was owned by somebody who was never shown the itinerary.
The multi-country complication
For groups, one further wrinkle. Travel is frequently between your own entities, which means the receiving office has host duties towards your visiting employee at the same time as you retain your own.
Where employees of several undertakings share a workplace, co-operation duties apply, and a visiting colleague from headquarters is not exempt from the destination country's arrangements. A German site has its own obligations. A French site maintains its own documentation. Neither is displaced because the visitor arrived on a group travel booking.
Holding travel arrangements, assessments and incidents in one register across every entity is what makes this answerable, which is where health and safety consultants and software are worth more together than either alone, and periodic health and safety audits confirm the arrangements still match how people actually travel.
Where Arinite fits
Arinite works with organisations whose people move between countries routinely, which describes most of the legal, finance and banking and professional services firms we support. We work with 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years, and our health and safety consultants build travel arrangements that are proportionate rather than performative.
Because we coordinate locally qualified practitioners in each jurisdiction, our global health and safety consultants can tell you what the destination expects as well as what you owe, and our international health and safety consultants keep that current as your travel footprint changes.
If your travel policy is a procurement document and nothing more, a free gap analysis will identify which of the seven gaps apply to you before an incident does.
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Written by
Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
