Modern Slavery Transparency Statement

About Historic England

Historic England is the government’s statutory adviser on the historic environment, helping people to understand, value and care for heritage while bringing new life to historic places to build a better future for every place and everyone.

Historic England is an executive non-departmental public body, sponsored by the Department for Digital, 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. The latest global estimates suggest that 49.6 million people worldwide are living in conditions of modern slavery, an increase of almost 10 million since 2016. In the UK, 23,411 potential victims were referred to the National Referral Mechanism (NRM) in 2025, the highest annual number on record. Despite these figures, the true scale of modern slavery is likely to be significantly 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.

1. 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 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 24-hour and confidential 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
2. 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 we give to be low risk, as they are usually to organisations or individuals who own heritage assets or have specific heritage skills. They are almost exclusively UK-based organisations with limited supply chains.
   
   In a typical year, Historic England would make grants of about £16 million, with additional funding being available through specific programmes such as the Heritage at Risk Capital Fund and Places of Worship Renewal Fund.
3. 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 the Government Commercial Agency (GCA).
   
   The GCA 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, the GCA 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, in 24/25 Historic England strengthened its due diligence processes by conducting targeted risk assessments of our top current suppliers by spend. This has been continued in 25/26 for both new and existing suppliers, with an increase in the number of suppliers surveyed.

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.

Results achieved during 2025/26

During 2025/26, Historic England expanded its supplier modern slavery assessment programme from 7 to 17 suppliers, extending coverage to both new and existing suppliers.

Assessment outcomes have been incorporated into contract management processes, improving visibility of supply chain risks and enabling targeted engagement with suppliers where opportunities for improvement have been identified. This has strengthened Historic England's ability to monitor, manage and mitigate modern slavery risks within its supply chain.

Key performance indicators to measure effectiveness of actions 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 ‘Orange’ are subject to increased scrutiny and ongoing monitoring to mitigate potential risks.

Suppliers who have been invited but have not completed the assessment are actively monitored through the contract management process. They are contacted periodically to request completion of the assessment or provide a satisfactory rationale for non-submission and are subject to ongoing follow-up to ensure appropriate oversight of potential risks.

Effectiveness of this process will be further enhanced through the appointment of a Contract Management support resource within the Procurement function, providing a level of dedicated oversight and supplier governance that has not previously been available.

Historic England measures the effectiveness of its modern slavery controls through the performance indicators outlined below. As the Procurement Contract Management function continues to develop and mature, additional KPIs will be introduced to provide deeper insight, demonstrate trends over time, and better evidence continuous improvement in modern slavery risk management.

• Number of suppliers assessed using the Modern Slavery Assessment Tool (MSAT).
• Percentage of assessed suppliers responding to the survey.
• Percentage of assessed suppliers achieving Green, Orange, Yellow and Red ratings. Scores are RAG based dependant on percentage score achieved: 
  70-100% = GREEN, 40-69% = ORANGE, 20-39% = YELLOW, 0-19% = RED)

Four suppliers completed the assessment in both years, resulting in a response rate of 57% in 2024/25 and 24% in 2025/26. The lower response rate reflects the expansion of the assessment programme and the inclusion of a larger supplier cohort. Suppliers who have not completed the Modern Slavery Assessment are actively monitored through contract management arrangements and are contacted periodically to request completion of the assessment or provide a satisfactory rationale for non-submission. Where suppliers are identified as operating in higher-risk sectors, they are subject to additional scrutiny and ongoing engagement to ensure appropriate oversight of potential risks.

No significant concerns were identified through the assessment process, although opportunities for continuous improvement were discussed with several suppliers.

Whilst no suppliers were assessed as Red risk in 2025/26, participation rates remain a challenge and will be a focus of future supplier engagement activity.

The August 2026 assessment remains ongoing. The results contained within this report are therefore provisional and may change as further assessments are completed.

Read more about information relating to the MSAT

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. Over the next year, we will start to utilise the Home Office’s ‘Anti-slavery Risk Tiering Tool (ARTT)’, which will allow us to more accurately assess contracts at the point of award, helping us work with suppliers to improve protections and reduce the risk of exploitation of workers in their supply chains.

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

Claudia Kenyatta and Emma Squire
Co-Chief Executives