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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, within its supply chain and amongst grant recipients.

About Historic England

Historic England is the government agency charged with protecting England's historic environment, and also acts as a grant giving body for the heritage sector. 

We deliver this work from 10 regional offices across England.  The organisation is led by an Executive Team reporting to the Chief Executive, and responsible to a Chair and Commissioners who are appointed independently by the government.

We are largely funded via government grant in aid.

Further information about Historic England can be found in the About Us section of our website, or via our annual report and accounts, and is not duplicated here so that the key points of this statement are not obscured by unnecessary organisational detail.

Our policy

Historic England has a zero tolerance policy for any form of modern slavery, coerced labour or human trafficking, both within its own business, within its supply chain and amongst grant recipients.

This policy has been endorsed by the Chairman, the Chief Executive, and the Executive Team of the organisation, and communicated to our Commissioners, staff and suppliers.
We have reviewed our operations to identify areas where there is a risk of us unwittingly employing victims of modern slavery

From this review, we believe that the potential for modern slavery within our operations can be divided into three areas – our own staff, recipients of our grants and within our supply chain. We have then considered whether the policies and safeguards we have in place are appropriate, and have concluded that they are. More detail is provided for each of the areas below.

Our own staff

Historic England employs around 850 staff, largely in technical and professional roles.

Our recruitment and Human Resources policies follow government best practice, including checks on right to work within the UK, and we believe these policies and processes would identify trafficked or coerced individuals directly employed by us.

We recognise the major trade union which represents the largest number of union members among our staff, and both include the representatives of the union in discussions of pay and conditions and permit them to advertise and recruit freely in our workplaces.

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.

Recipients of our grants

Historic England acts as a distributor for around £20 million of grants each year.  The majority are relatively small, and focused on the preservation of historic buildings. 

Our standard grant conditions include a reminder to recipient bodies that they should review their obligations under the Modern Slavery Act 2015. 

We are reviewing whether it would be useful and proportionate to ask grant recipients to demonstrate compliance with the Act as part of our grant conditions, or whether this would be unduly burdensome, given the low risk of our grant recipients (all UK based, and usually small organisations or individuals) not being compliant. 

Alternatively, the review may suggest that we require this only for recipients of grants above a certain threshold.

Our supply chain

Historic England purchases around £26 million of goods and services from third-party suppliers each year.

The great majority of these goods and services we purchase are from within the UK and EU, where employment legislation is generally both reasonably comprehensive and generally enforced.

In addition, very little of what we purchase comes from industry sectors where poor employment practices are more common, such as the extractive or textile industries, catering & hospitality or security and cleaning services. 

A significant portion of our procurement is done via government framework contracts, for which suppliers have already been reviewed by Crown Commercial Services.

We therefore believe that the risk of modern slavery in our supply chain is relatively low.

However, we take our responsibilities in this area seriously, and have taken proportionate steps to reassure ourselves that our suppliers do not employ modern slaves, either directly or via their own downstream supply chains.

We have included a requirement in all new procurement tenders and contracts that all suppliers must declare that they (and any subcontractors) are compliant with the Modern Slavery Act 2015.

We are developing a programme to review our existing "tier 1" suppliers, and ensure those which are material and / or which operate in high risk countries or industries are also compliant with the Act.

Making our policy effective

We are very conscious that even the most comprehensive policy will achieve very little if it remains just a piece of paper, and that communication to our staff is essential if it is to have a real effect.

We have communicated our policy to our staff via our normal internal communications routes, including e-mail, intranet and awareness training seminars at our major offices.

These communications have been endorsed by the most senior people in the organisation, to underscore the importance we attach to this.

Aside from the moral aspect, the communications stress that it is much better for us to identify any potential issues around modern slavery ourselves, so that we can take action if necessary.  This would obviously be much less harmful than the potential reputational damage we might suffer, should it emerge later that we were complicit in such things, even if only through failure to ask reasonable questions.

Staff who have any concerns have been advised to raise them via our anonymous fraud, bribery and corruption helpline, which is monitored and reports any concerns raised to our Audit Committee.

Duncan Wilson
Chief Executive

Sir Laurie Magnus
Chairman

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