We're committed to ensuring that there's no form of modern slavery within our organisation, the activities funded by our grant giving, or our supply chains. Modern slavery is an umbrella term which covers slavery, servitude and forced or compulsory labour, as well as human trafficking.
This statement sets out our actions for the financial year of 2021 to 2022 to ensure that there is no slavery or human trafficking in our own business.
In line with the Modern Slavery Act 2015, this statement constitutes our modern slavery and human trafficking statement for the financial year ending 31 March 2022.
It sets out an explanation of:
- who we are as an organisation and what we do
- where we believe risks of slavery and human trafficking exist
- how we currently manage those risks
- what further steps we will take to ensure we continue to manage those risks
We were established as an executive agency of the Scottish Government on 1 April 2019, following completion of the devolution of forestry as a result of the Forestry and Land Management (Scotland) Act 2018 (the Act).
We're responsible for forestry policy, regulatory and support functions of the Scottish Government. Our functions also include elements agreed by Scottish Ministers of the new cross-border arrangements that the Scottish Government is co-ordinating on behalf of Scotland, England and Wales. These are the management of the UK Forestry Standard and the Woodland Carbon Code as well as the provision of economic advice on forestry.
Our National Office is at Silvan House, 231 Corstorphine Road, Edinburgh, EH12 7AT. As well as a National Office, we operate a network of 5 conservancies (local offices) who discharge the majority of our statutory and grant giving functions.
Our structure and activities
We employ around 200 permanent staff. These people include a range of professionals such as foresters, economists, IT specialists and accountants.
We're responsible for administering £63M through the Forestry Grant Scheme (FGS), providing funding in 2 key areas:
- Woodland Creation
- Woodland Improvement and Sustainable Management of Forestry
We buy a wide range of goods and services supplies directly from suppliers and contractors. We also provide grant support to the forestry sector in Scotland.
We collaborate with other public bodies and use framework contracts established by the Scottish Government and others.
In 2021, we undertook a review of the evidence available of modern slavery across sector. The sector is mostly commercial, and many operations are mechanised. The workers who do this are highly skilled, very sought after and as such are well paid. Following the EU Exit, there is a shortage of labour, and skilled employees are sought after and highly paid. The reputation of the firms is important in order to attract workers on an ongoing basis. This evidence indicates that forestry is a low risk sector.
However, some operations, such as planting and spraying, need intensive manual labour, and these employees could be vulnerable. Historically, these operations have relied on migrant workers. In addition, operations do take place in remote locations, and it is possible that modern slavery practices may not be visible. Wider research on modern slavery indicates the use of employment agencies in supplying labour from within the UK or to recruit migrant labour from outwith the UK increases risk. If there are significant labour shortages, unscrupulous employers and organised criminals may exploit the vulnerable by trafficking them to the UK to work. Victims can pass unnoticed through operations via temporary labour, especially if they're in and out of the business for very short time periods.
The forestry sector is in a state of flux at present and under some pressure. This is linked to a change in the workforce landscape, the impact of COVID-19, and increasing woodland creation targets. With the development of the carbon market, new companies are becoming involved in the forestry sector. Some of their projects may not be dependent on grants, and therefore may not be subject to some standard processes and/or checks. There are many unknowns across the sector in the short term, and it's difficult to predict how companies will respond to shortages regarding seasonal labour. Anecdotally, there are examples that labour supply and/or recruitment is changing and becoming more global.
There may be also risks through the goods that we procure, arising from our supply chains around the world. Research indicates that many goods within a supply chain may be the product of modern slavery. Of particular relevance to US is clothing and electronics. There was an emphasis on modern slavery in our tendering process for our corporate clothing across 2019 and 2020.
Ongoing actions being taken
We're committed to working to identify and reduce the risk of modern slavery, coerced labour or human trafficking within our agency, our supply chains or amongst our grant recipients.
All potential new employees, regardless of contract status are required to go through our recruitment process, which includes essential checks on the right to live and work in the UK. We do not employ any agency staff at this point in time. We've a number of students on placement each year.
We take modern slavery into consideration as part of our due diligence and risk analysis of all tender exercises. This is done by the purchasing officer pre-contract award alongside other areas such as sustainability, social and environmental outcomes. An assessment of modern slavery is an area that is applied in our procurement process following consideration of and is dependent on the commodity and supplier base involved.
Policies and procedures
Our policies and procedures reflect our ambition to be a high-performing organisation, acting ethically and with integrity in all of our business dealings and relationships.
We follow government best practice in our recruitment policies. This includes essential checks on the right to live and work within the UK, and we believe these policies and processes would identify trafficked or coerced individuals directly employed by us.
We work in partnership with our 2 recognised trade unions:
- PCS (Public and Commercial Services Union)
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.
We believe that our policies and procedures will help us to mitigate against the most significant slavery and human trafficking risks that we face.
Actions planned for 2021 to 2022 and beyond
We'll raise awareness amongst our staff, to ensure they have a clear understanding of what modern slavery and human trafficking is, and that they're alert to the key warning signs as they go about their work engaging with suppliers and delivery partners. We'll explore options to develop this with other agencies and experts in the field.
We'll review our procurement approach as more information and advice becomes available.
We'll be particularly mindful of the risk of modern slavery in our procurement of clothing and electronics.
We'll update our FGS guidance to ensure that grant recipients comply with the requirements of modern slavery legislation. The guidance will be adapted in order to provide assurance that activities approved under a FGS contract mitigate any risks of exploitation, forced labour and human trafficking within forestry operations and activities.
We'll work with the forestry sector to assess their current position in relation to modern slavery. We'll work with the sector to highlight potential areas of vulnerability, particularly where operations are manual, or where labour is seasonal/temporary and/or made up of migrant workers.
We'll highlight the evidence of what is required for modern slavery to be eradicated – such as the regulation and inspection of businesses and employment agencies, adequate pay, enabling workers to have a voice through unionisation, and allowing the safe reporting of abuse. We'll contribute to identifying improvements which may be required across the forestry sector.
We'll support the drive to continue to professionalise the industry and to develop a sector where forestry skills are valued, supported and respected.
Our stance is that of zero tolerance towards the evils of modern slavery or human trafficking within our organisation, supply chains and delivery partners.