Modern Slavery Statement

At Edinburgh World Heritage (EWH), we are committed to acting ethically and with integrity to ensure that there is no form of modern slavery or human trafficking in our organisation, our supply chains or our grant recipients.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which aim to deprive liberty and exploit people for personal or commercial gain.

We are committed to fair employment practices in line with our core values and behaviours, and all relevant labour legislation. We adopt a ‘zero-tolerance’ approach to slavery and human trafficking.

Any breach of this commitment should be reported through the EWH Whistleblowing Policy and may result in disciplinary action. These standards apply to all persons working for or on our behalf including all employees, contractors, agency workers, and Board Members, and it is their responsibility to prevent, detect and report modern slavery in any and all parts of our business operations.

About this statement

In line with the Modern Slavery Act 2015, this is our modern slavery and human trafficking statement for the financial year ending 31 March 2024.

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

Edinburgh World Heritage is an independent charity whose mission is to build meaningful connections that facilitate and nurture a shared sense of belonging and ownership through the conservation of historic buildings, delivering improvements to the public realm, developing our new climate emergency programme and engaging people directly with the rich heritage of the city.

We’re a Company Limited by Guarantee (Registration number SC195077) a registered charity (Scottish Charity number SC037183).

We’re governed by a non-executive Board supported by the Projects & Programmes Committee and Finance & General Purposes Committee. Day to day running of EWH is delegated to the Director.

Our Articles of Association define our purpose and how we are governed.

Our office is at Acheson House, 5 Bakehouse Close, Edinburgh, EH8 8DD.

Our terms of reference include:

  • Historic Building Grants: To stimulate and co-ordinate action for the conservation and repair of historic buildings in the World Heritage Site
  • Conservation Area Issues: To promote the preservation and enhancement of the character of the Site; and to develop and maintain an Action Plan
  • Advice: To advise Scottish Ministers and the Local Authority on major policy and development issues; and to comment on other planning issues as necessary
  • Monitoring: To monitor the Site on behalf of Scottish Ministers; and to inform and advise organisations involved in the management of the City Centre
  • Projects: To initiate projects and attract funding for the preservation and enhancement of the Site
  • Promotion: To promote the World Heritage Site through education, exhibitions, conferences and examples of skill and good practice

Find out more about us or download our annual accounts.

Our people

We employ around twelve people in a variety of professions, from conservation, to engagement, operations, and more. We also offer volunteering opportunities, for example student projects related to conservation activity, in archiving/library roles, supporting our engagement activities and maintaining our community garden.

We aim to employ a workforce that reflects, at all levels, the diversity of society as a whole.

For all people 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 are working towards becoming a Living Wage accredited employer.

Our contractors and supply chains

We buy a limited range of goods, services, and works directly from suppliers and contractors. Our main supply chains fall under the following categories:

  • Professional Services: Legal, Accounts, HR, Health & Safety, ICT and website support
  • Corporate Services: ICT equipment & software, rent and services related to our offices

Our supply base is predominantly Scottish (90%) with the rest of the UK making up the remaining 10%.

We have incorporated a modern slavery clause into the EWH standard procurement terms and conditions, and we look to include it in other contracts where appropriate.

We have direct suppliers based in Scotland and the rest of the UK. 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.

We are committed to responding to the challenges of climate change and promoting responsible 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. To address this weakness, we now 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.

Our grants programme

We offer several grant schemes to groups, organisations (including businesses) 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 charitable objectives. Grants are issued to a variety of recipients, including not for profit organisations, such as charitable trusts. 

Our grants contracts include several specific clauses requiring our grant recipients to comply with the Modern Slavery Act, both directly and through any contracts associated with delivery of an EWH grant.

Policies

Our commitment to anti-slavery builds upon our existing framework of ethical policies. We believe the following policies help us minimise the risk of modern slavery and human trafficking in our organisation.

Name of Policy/Strategy

Description

Policy/Strategy approver

Review frequency

EWH Office Handbook

Provides guidance for employees about employee rights, responsibilities, and duties while at work including grievance, anti-bribery commitment, fair treatment, whistleblowing, disclosure of convictions, gifts and hospitality and conflicts of interest.

EWH Board

Annual

Equality, Diversity & Inclusion

Articulates how EWH will drive systemic change, including within recruitment and partnership working, and work to embed a diverse and inclusive culture that provides opportunities for all to realise their potential

EWH Board

Annually

People Strategy

Provides a clear set of recommendations and a framework for engaging, developing and managing EWH employees in supporting strategic aspirations

EWH Board

Annually

Introduction to EWH

Defines EWH vision, mission, purpose and values for all Trustees and employees

Senior Management Team

Annually

While we do not have an explicit Modern Slavery Policy for EWH we have strengthened and updated our existing policies to support and reference the Modern Slavery Act and this statement.

Risk assessment

It is our view that our most significant risk of modern slavery or human trafficking is connected to our supply chains. To mitigate this risk, we have undertaken a supplier mapping exercise to determine where modern slavery risks are most likely in our supply chains and actions to mitigate any remaining risk have been identified.

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. We will also, as existing employee policies come up for review, continue to consider the requirement to incorporate anti-modern slavery or human trafficking requirements.

Training for staff

We do not provide specific training to all our employees on identifying and preventing modern slavery and human trafficking. We do provide training to employees, through our induction processes, which highlights the modern slavery statement, and ongoing learning and development, on our corporate policies.

We also provide extra training and guidance to employees involved in recruitment and procurement exercises. This training helps us to make sure employees follow our policy and procedures, which we believe lessens some of the risks of modern slavery and human trafficking.

We are committed to reviewing how we can improve training provided to employees with roles most likely to encounter risks of modern slavery and human trafficking, with the aim of developing and providing appropriate training to those employees.

Measuring effectiveness

Our Business Plan sets out our vision and aligns with Historic Environment Scotland’s five outcomes which we want to achieve:

  1. The historic environment makes a real difference to people’s lives
  2. The historic environment is looked after, protected, and managed for the generations to come
  3. The historic environment makes a broader contribution to the economy of Scotland and its people
  4. The historic environment inspires a creative and vibrant Scotland
  5. The historic environment is cared for and championed by a high-performing organisation

We believe that our vision and priorities are consistent with an organisation committed to preventing modern slavery and human trafficking in all areas we operate in.

Christina Sinclair
Director

If you would like to know more about the topic above, please contact us directly.