In line with the Modern Slavery Act 2015, this is our modern slavery and human trafficking statement for the financial year ending 31 March 2019.
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 2019.
HES is also in a Limited Liability Partnership with Glasgow School of Art in the Centre for Digital Documentation and Visualisation (CDDV LLP) (Company number SO302759). The partnership undertakes digital documentation of heritage sites.
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 1400 staff in a variety of professions from conservation and construction, to archaeology, archives, and more. Some staff 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 all of our recruitment is governed by the Office of the Civil Service Commissioners Recruitment Code and our employment values.
For all staff 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.
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.
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. We recognise this is a specific weakness in our controls to prevent modern slavery and human trafficking in our supply chains.
To address this weakness, we are working to 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 supplier will be required to sign a declaration of Modern Slavery Compliance.
Information on our Procurement policies and strategy are available on our website.
Our grants programme
We offer five 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.
Currently our standard grant contract does not include any specific reference to requirements to comply with the Modern Slavery Act. While our contract does require grantees to comply with all relevant law, we recognise this is a specific weakness in our controls to prevent modern slavery and human trafficking in our grant programmes.
To address this weakness, we are working to include specific requirements on the prevention of modern slavery and human trafficking in our grant due diligence and contracts.
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 and none of our existing policies explicitly reference the Modern Slavery Act.
We recognise this is an area we can improve on and are committed to reviewing the requirement for a corporate Modern Slavery Policy. We will also, as each of the policies below comes up for review, consider the requirement to include any required references to modern slavery and human trafficking.
Risk assessment
It is our view that our most significant risk of modern slavery or human trafficking is connected to our supply chains. Our actions are accordingly targeted to address this risk.
Specific actions we will take include:
- inserting Modern Slavery Act compliance clauses into our standard contracts with suppliers
- increasing the due diligence of suppliers at the supplier selection stage
- begin to audit of our retail supply chains to better understand the end-to-end supply chain for our retail products
Other risks of modern slavery or human trafficking include our people and our grants programme. 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 and will begin the process of developing a specific Modern Slavery Policy for HES. We will also, as existing HR policies come up for review, consider the requirement to incorporate anti-modern slavery or human trafficking requirements.
For our grants programme we consider that the risk is mitigated by the fact our grants are mostly awarded to other public and charitable bodies. We recognise that our due diligence and grant contracts could be better in making sure that we explicitly manage the risk of inadvertently funding grantees who fail to comply with the Modern Slavery Act. To address this, we will look at incorporating the requirement to comply with the Modern Slavery Act into our grant contracts and in our grant award due diligence processes.
Training for staff
We do not provide specific training to our staff on identifying and preventing modern slavery and human trafficking. We do 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.
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. 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:
- Heritage and Society
- Heritage and the Environment
- Heritage and the Economy
- Heritage and Creativity
- Heritage and Us
Alex Paterson
Chief Executive