Modern Slavery Transparency Statement
Historic England is committed to preventing modern slavery and human trafficking in all aspects of our operations, supply chains, and grant funding. This statement outlines the steps we have taken and will continue to take to identify, assess, and mitigate risks related to modern slavery.
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.
Modern slavery remains a widespread and devastating issue. In 2025, the International Labour Organization (ILO) estimated that 49.6 million people globally are victims of modern slavery — a significant increase from the 2016 figure of 40 million. In the UK, the issue continues to grow, with 19,125 potential victims referred to the National Referral Mechanism (NRM) in 2024. However, the true scale is likely much higher due to underreporting and the hidden nature of the crime.
The Modern Slavery Act 2015 put forward new measures that 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 Office’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 about £16million, with additional funding being available for specific programmes such as the Heritage at Risk Capital Fund and Heritage Revival Fund. - Supply Chains
As a public body, Historic England’s procurement activities are regulated by the Procurement Act 2023 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 looks 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 and as part of our commitment to ethical procurement and the prevention of modern slavery, Historic England has strengthened its due diligence processes by conducting a targeted risk assessment of our top suppliers by spend in the years 24/25.
In line with Cabinet Office risk assessment guidance, we considered the following risk factors in our assessments:
- Industry type
- Nature of the workforce
- Supplier location
- Context of operations
- Commodity type
- Business/supply chain model
The suppliers identified as potentially higher risk are requested to complete the ‘Modern Slavery Assessment Tool’ (MSAT) to evaluate and improve organisational responses to modern slavery risks. This initiative enables us to:
- Benchmark the suppliers performance rating and measure improvement
- Gain deeper insight into supplier practices and supply chain transparency
- Identify areas requiring further scrutiny or improvement
- Promote continuous improvement and accountability in ethical sourcing
This proactive approach reinforces our zero-tolerance stance on modern slavery and supports our goal of maintaining a responsible and transparent supply chain.
Key performance indicators to measure effectiveness of steps being taken
Supplier responses are now embedded into the contract management process, with a review carried out at least once a year for suppliers rated ‘Yellow’ or ‘Green’. Suppliers who are rated ‘Red’ or ‘Amber’ will be more closely monitored.
Although individual results cannot be shared due to data protection, all suppliers who have responded have, where relevant, published a Modern Slavery statement and are rated either Yellow or Green.
The same process will be repeated annually with these suppliers in addition to any new suppliers identified as high spend and/or high risk.
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.
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 Procurement-HE@HistoricEngland.org.uk
Duncan Wilson
Chief Executive