Modern Slavery Transparency Statement
Historic England has a zero-tolerance policy for any form of modern slavery, coerced labour or human trafficking, both within its own business, amongst grant recipients and within its supply chain.
About Historic England
Historic England is the government’s statutory adviser on the historic environment; championing historic places and helping people to understand, value and care for them.
Historic England is an executive non-departmental public body, sponsored by the Department for Culture, Media & Sport (DCMS). The organisation is led by an Executive Team reporting to the Chief Executive and is responsible to a Chair and Commissioners who are appointed independently by the government.
Further information about Historic England can be found in the About Us section of our website, or via our annual report and accounts.
Modern slavery
Modern Slavery is a serious and often hidden crime in which people are exploited for criminal gain. The impact can be devastating for the victims. Modern slavery comprises slavery, servitude, forced and compulsory labour and human trafficking.
There were an estimated 40 million people in slavery globally in 2016 and 10,000 –13,000 potential victims in the UK, however many victims are not identified or reported.
The Modern Slavery Act 2015 put forward new measures which are directly related to businesses and their supply chains. Section 54 of the Act requires companies with an annual turnover above £36 million, and carrying out a business, or part of a business, in the UK, to publish a Modern Slavery Statement each year.
Policies in relation to slavery and human trafficking
Historic England has a zero-tolerance policy for any form of modern slavery, coerced labour or human trafficking, both within its own business, amongst grant recipients and within its supply chain.
- Our people
Historic England is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. The risk of modern slavery and exploitation of our people is low due to the comprehensive policies and processes we have in place for recruiting and employing people.
Our policies follow government best practice and ensure that all prospective employees are legally entitled to work in the UK. We believe these policies and processes would identify trafficked or coerced individuals directly employed by us. We are committed to fair and equitable pay and reward systems and policies that are legislatively compliant.
We recognise the Prospect trade union and include them in discussions of pay and conditions. We also permit them to advertise and recruit members in our workplaces. They provide another route for individuals to raise concerns.
Furthermore, we fund an external employee assistance helpline through which employees who feel coerced, threatened or exploited at work could obtain help, without fear of being identified or exposed to retribution.
Our policies are available on the Historic England intranet. Those policies that directly relate to the Modern Slavery Act 2015 and minimise the risk of exploitation of our people are:- Bullying and Harassment
- Diversity and Inclusion
- Conduct and Performance
- Whistleblowing
- Recruitment and Selection
- Employee Assistance Programme
- Pay & Reward
- Grants
In line with the requirements as set out by the Cabinet Officer’s Government Grants Management Function, our grant funding agreements contain a Modern Slavery clause which requires all grant recipients of Historic England grant funding to confirm their adherence to the Modern Slavery Act 2015.
We consider the grants that we give to be low risk as they are usually to organisations or individuals with specific skills in heritage, with limited supply chains, and most commonly to UK based organisations. In a typical year, Historic England would make grants of £15 million-£20 million, with additional funding being available for specific programmes such as Covid recovery and High Street Heritage Action Zones. - Supply Chains
As a public body, Historic England’s procurement activities are regulated by the Public Contract Regulations 2015 (PCR2015) and associated Cabinet Office requirements; in particular, Procurement Policy Note 02/23, which provides guidance on how to tackle Modern Slavery in Supply Chains, and which can also be applied to grants.
Historic England purchases around £25 million of goods and services from third-party suppliers each year. A significant portion of our procurement is done via government framework contracts, for which suppliers will have already been reviewed by Crown Commercial Services (CCS).
CCS look at whether suppliers (in scope of S54 of the Modern Slavery Act) have up-to-date statements as part of the tendering process, and this is checked annually as part of their supplier assurance process.
For agreements rated as medium or high risk of Slavery, CCS conducts annual modern Slavery assessments with suppliers and follow-up conversations with suppliers to discuss areas for improvement.
Risk assessment and management
The great majority of the goods and services we purchase are from within the UK and EU and we therefore believe that the risk of modern slavery in our supply chain is relatively low. However, in accordance with the guidance in Procurement Policy Note 02/23 we will be adopting a risk based approach and will be carrying out a risk assessment of our existing contracts.
In line with Cabinet Office risk assessment guidance, we will consider the following potential risk factors in our assessment:
- Industry Type
- Nature of the Workforce
- Supplier Location
- Context in which the Supplier operates
- Commodity Type
- Business Supply Chain Model
Where any Contracts are identified as Medium or High risk; by having 3 or more risk factors, we will require the supplier in question to carry out an assessment using the Modern Slavery Assessment Tool (MSAT) available from the Cabinet Office. The MSAT is designed to help public sector organisations work in partnership with suppliers to improve the protection and reduce the risk of exploitation of workers in their supply chains. It also aims to help public sector organisations understand where there may be risks of modern slavery in the supply chains of goods and services they have procured.
The tool asks questions about the procedures that organisations have in place for managing modern slavery risks, in order to provide good practice recommendations based on the six themes above. It is also proportional in how it evaluates risk, considering the size of organisation in any suggested improvements.
Key performance indicators to measure effectiveness of steps being taken
We will work with our suppliers to reduce their risk rating. Over time we will progressively apply this approach to more suppliers across our supply base and we will report on our progress in subsequent iterations of this statement.
Due diligence processes
When developing specifications or statements of requirements we will consider whether our requirement is such that suppliers who respond to our tenders are likely to be at risk, but our approach will be proportionate to ensure that the barriers to participating in public procurement remain as low as possible for suppliers, especially small businesses and VCSE organisations. Similarly we undertake due diligence on philanthropic funders of Historic England and the Historic England Foundation, in line with our Ethical Fundraising Policy.
New procurements
We will also consider the risk of Modern Slavery when designing new procurements. We will include appropriate selection criteria in our tenders and make greater use of Social Value criteria in our evaluation process. A key policy outcome of the Social Value Model is to ‘tackle workforce inequality’. This outcome is particularly relevant when vulnerability to modern slavery threats is a consideration in the contract supply chain.
For example, we recently re-tendered our Facilities Management contract for our office in Swindon and as part of the selection process we assessed the bidders’ own Modern Slavery statements and included their approach to tackling workplace inequality in our evaluation process. Appropriate KPIs to monitor their delivery against the commitments they made are being agreed as part of the mobilisation process.
Training on modern slavery and trafficking
All members of the Procurement Team and other staff where appropriate will be required to complete the Chartered Institute of Procurement & Supply’s “Ethical Procurement and Supply” e-learning module, and the Government Commercial College’s “Tackling modern slavery in supply chains: PPE case study “.
We believe awareness of modern slavery and human trafficking is important to make this statement effective. To achieve this, we will therefore also communicate this statement to all our staff. Staff who have any concerns may raise these through our whistleblowing policy, or report suspicions through our counter fraud policy. Our whistleblowing and counter fraud contacts are monitored and reported internally to our General Counsel.
Any questions about our approach to Modern Slavery should be sent to [email protected]
Duncan Wilson
Chief Executive
