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Modern Slavery Statement

Modern Slavery Statement

At Historic Environment Scotland (HES), we are committed to acting ethically and with integrity to ensure that there is no form of modern slavery or human trafficking in our organisation, our supply chains or our grant recipients.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which aim to deprive liberty and exploit people for personal or commercial gain.

At Historic Environment Scotland (HES), we are committed to acting ethically and with integrity to ensure that there is no form of modern slavery or human trafficking in our organisation, our supply chains or our grant recipients. We are committed to fair employment practices in line with our core values and behaviours, and all relevant labour legislation. We adopt a ‘zero-tolerance’ approach to slavery and human trafficking.

Any breach of this commitment should be reported through the HES Whistleblowing Policy and may result in disciplinary action. These standards apply to everyone working for or on our behalf including all employees, contractors, agency workers, and Board Members. It is their responsibility to prevent, detect and report modern slavery in any and all parts of our business operations.

About this statement

In line with the Modern Slavery Act 2015, this is our modern slavery and human trafficking statement for the financial year ending 31 March 2021.

It sets out:

• who we are as an organisation and what we do
• where we believe our risks of slavery and human trafficking exist
• how we currently manage those risks
• what further steps we are taking to ensure we continue to manage those risks

We have followed guidance provided by the Home Office and this statement has been evaluated using the Ethical Trading Initiative ‘Modern Slavery Statements: A Framework for Evaluation’.

About us

Historic Environment Scotland (HES) is the lead public body for the historic environment in Scotland.

We’re an executive Non-Departmental Public Body (NDPB) established under The Historic Environment Scotland Act 2014 and is also a registered charity (Scottish Charity number SC045925).

We’re governed by a non-executive Board supported by the Audit, Risk and Assurance Committee and Staff Governance Committee. Day to day running of HES is delegated to the Chief Executive and Senior Management Team (SMT).

Our framework document, drawn up by the Scottish Government in consultation with the HES Board, defines our purpose, relationship with Scottish Ministers and our sponsor in Scottish Government, and how we are governed.

Our main office is at Longmore House, Salisbury Place, Edinburgh, EH9 1SH, with local offices and depots throughout Scotland.

Our responsibilities include:

  • caring for more than 300 sites of national importance all over Scotland
  • looking after and providing access to internationally significant archives and artefacts
  • investigating and researching the historic environment and addressing the impacts of climate change on its future
  • protecting historic places through designations and consents
  • providing millions of pounds each year to local communities to repair and revitalise their historic environment
  • delivering training and learning opportunities, giving advice and offering best practice guidance

Find out more about us or download our annual report and accounts.

Our structure

HES wholly owns two subsidiaries:

  • Historic Environment Scotland Enterprises Limited (HESe) (Limited Company number SC510997)
  • Scran Ltd (Limited Company number SC163518)

These companies are included in our financial statements.

HESe carries out non-core trading activity, including retail sales of our merchandise and catering facilities and the commercial online sale of images. HESe is governed by a separate Board of Directors which reports to the HES Board.

Scran Ltd ceased trading on 31 March 2016 and was dormant for the year to 31 March 2021.

HES was also in a Limited Liability Partnership with Glasgow School of Art, Centre for Digital Documentation and Visualisation LLP (CDDV LLP). HES and Glasgow School of Art agreed to dissolve the partnership and the partnership was dissolved on 1 June 2021.

The activities of HES are distinct from the Historic Scotland Foundation Trust (Charity number SC032044), which was set up in 2001 as an independent charitable trust to accept donations, gifts and legacies for the work of Historic Scotland or any successor body.

Our people

We employ around 1,400 staff in a variety of professions from conservation, to archaeology, archives, and more. Some are seasonal employees who work at our visitor sites as Stewards, Guides and within Admission and Retail teams.

We aim to employ a workforce that reflects, at all levels, the diversity of society as a whole and our recruitment is governed by the Office of the Civil Service Commissioners Recruitment Code and our employment values.

For all people we employ, whether permanent or short-term posts, we require proof of eligibility to work in the UK. This is verified during the recruitment process before any offer of employment.

As a Sponsor Body, we follow strict adherence to Home Office instructions for recruiting and appointing those who meet the criteria of the Tier 2 General License.

We work in partnership with our three recognised Trade Unions:

  • Unite the Union
  • PCS
  • Prospect

Our Partnership Agreement outlines our joint approach to the management of employment relations and reinforces the relationship between Management and Trade Union within the organisation.

We are a Living Wage accredited employer.

Our contractors and supply chains

We buy a wide range of goods, services, and works directly from suppliers and contractors. Our main supply chains fall under the following categories:

  • Estates and Facilities: Construction, Capital Building Projects, Cleaning and Catering Services, Security, Clothing and Furniture.
  • Professional Services: Research, Media, Printing, Events, Recruitment
  • Corporate Services: ICT Equipment and Services
  • Retail

Our supply base is predominately Scottish (60%) with the rest of the UK and international making up the remaining 40%.

Our retail supply chain

Our retail suppliers include distributors and manufacturers of products made in Scotland, UK and internationally.

We have direct suppliers based in Scotland, UK, France, the Netherlands and Spain. Our indirect suppliers, including manufacturers who supply our UK-based distributors, are based globally. Some raw materials used by our UK based suppliers will be purchased from overseas and the products finished in the UK.

In our Corporate Plan, we are committed to responding to the challenges of climate change and promoting sustainable tourism. Understanding our supply chains is an important part of achieving those aims and is therefore key to delivering our strategic priorities and outcomes.

Currently, across all our supply chains, we have limited knowledge of our indirect suppliers.To address this weakness, we now include appropriate clauses in contracts which require our direct suppliers to comply with the requirements of the Modern Slavery Act. These clauses will also apply to indirect suppliers in the supply chain.

We are also working to ensure that in the supplier selection process, appropriate measures are taken to exclude suppliers with convictions under the relevant sections of the Modern Slavery Act. In the future, it is our aim that every retail supplier will be required to sign a declaration of Modern Slavery Compliance.

Our Climate Action Plan sets out our commitment over the next five years to achieve Sustainable Procurement, including actions to audit our supply chains for goods and services to ensure we are not funding unethical or environmentally detrimental operations. We believe this action will help us in further managing the risk of modern slavery and human trafficking in our supply chains by improving our knowledge of our indirect suppliers.

Information on our Procurement policies and strategy are available on our website.

Our grants programme

We offer six grant schemes to groups, organisations and individuals, to assist with projects that benefit the historic environment, and which help to deliver the training and skills needed in caring for the historic environment.

These projects vary in scope and size, with decisions for funding made in line with our corporate objectives and within the strategic aims of the Scottish Government. Grants are issued to a variety of recipients, including not for profit organisations, such as charitable trusts, local authorities and religious bodies. We publish details of grants awarded annually.

Our grants contracts include several specific clauses requiring our grant recipients to comply with the Modern Slavery Act, both directly and through any contracts associated with delivery of an HES grant.

Policies

We believe the following policies help us minimise the risk of modern slavery and human trafficking in our organisation.

Name of policy Description Policy approver Review frequency
HES Code of Conduct For all employees of HES, this provides guidance about employee rights, responsibilities and duties while at work including fair treatment, disclosure of convictions, gifts and hospitality and conflicts of interest. SMT Ongoing
Anti-bribery commitment Outlines our commitment to the high standards of conduct and integrity expected from all public sector employees and Board members. Links to the Bribery Act and its responsibilities/expectations for employees. SMT Annually
Whistleblowing Provides a framework for employees to blow the whistle. This is to raise any concerns about wrongdoing, malpractice or impropriety in the organisation that would be in the public’s interest. HES Board Annually
Counter-Fraud Policy Outlines the HES approach towards the prevention, detection, reporting and handling of fraud. SMT Annually
Grievance Policy and Procedures Provides staff with a clear framework for raising grievances / disputes and outlines how the cases will be managed. SMT Annually

Currently we do not have any explicit Modern Slavery Policy for HES. However our existing policies support and reference the Modern Slavery Act and this statement.

Risk assessment

It is our view that our most significant risk of modern slavery or human trafficking is connected to our supply chains.

In February 2020, we commissioned an internal audit review of our approach to managing the risk of modern slavery and human trafficking that identified areas of good practice in our approach as well as several recommendations for improvement. Our actions are accordingly targeted to address those recommendations and the risk in our supply chains.

Specific actions we will take include:

  • increasing the due diligence of suppliers at the supplier selection stage
  • begin to audit our retail supply chains to identify suppliers who may have a higher risk of Modern Slavery in their supply chains and mitigate those risks.

We believe that our recruitment policies and processes mitigate the risk of our directly employing any person that has been trafficked or coerced into working. However, we remain vigilant to the risk.

As existing employee policies come up for review, we will also continue to consider the requirement to incorporate anti-modern slavery or human trafficking requirements.

Training for staff

We provide training to staff, through our induction processes and ongoing learning and development, on our corporate policies. We also provide extra training and guidance to staff involved in recruitment and procurement exercises. This training helps us to make sure staff follow our policy and procedures, which we believe lessens some of the risks of modern slavery and human trafficking.

However, we know we can do more, and so we are committed to reviewing how we can improve training provided to staff with roles most likely to encounter risks of modern slavery and human trafficking, with the aim of developing and providing appropriate training to those staff.

Measuring effectiveness

Our Corporate Plan, Heritage for All, sets out our vision and the five outcomes we want to achieve:

  • Heritage and Society
  • Heritage and the Environment
  • Heritage and the Economy
  • Heritage and Creativity
  • Heritage and Us

We believe that vision and our priorities are consistent with an organisation committed to preventing modern slavery and human trafficking in all areas we operate.

Alex Paterson
Chief Executive

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