Human trafficking statement
Human trafficking statement navigation
Slavery and human trafficking statement
This statement explains what we’ll do to find out if there’s any risk of slavery and human trafficking related to our business and supply chain. It also sets out the necessary steps to address these risks. This statement relates to actions and activities undertaken by us in the financial year 1 April 2025 to 31 March 2026.
Terms and conditions of employment
Our People Policies and Procedures are developed in consultation with Trade Union representatives and take account of our legal responsibility as an employer to take steps to prevent human trafficking.
As an Executive Agency of Scottish Government, our employees are civil servants. As civil servants, they have safeguards added to their terms and conditions of employment. This helps to prevent some of the activities characteristic of human trafficking. For example:
- all civil servants are recruited in accordance with the Civil Service Recruitment principals and the Baseline Personnel and Security Standards, which comprises the following four main checks: Identity, Right to Work in the UK, Employment History and Criminal Records check
- salaries are paid into individual bank accounts
- hourly rates are above the National Minimum Wage and the National Living Wage
- annual leave entitlements are above the statutory minimum detailed in the Working Time Directive
- employees can apply for flexible working to help achieve a better work/life balance
Independent audits
Every year we get independent audits to ensure we're meeting the standards laid out in the UK Woodland Assurance Scheme (UKWAS). Amongst other requirements, the standard sets out employee and contractor’s rights to:
- trade union membership
- pay exceeding the statutory national living wage
- access to a grievance procedure and relevant measures relating to compliance
- conformance, including anti-corruption
- measuring compliance with workers’ rights legislation
Civil Service People Survey
We take part in the Civil Service People Survey on an annual basis. The survey allows our employees to tell us their views about:
- their job
- our agency as an employer
- any other workplace issues
Agency structure
We're a Scottish Government Agency, established on 1 April 2019. The Chief Executive is supported by a:
- Director of Land Management
- Director of Commercial Development
- Director of Net Zero
- Director of Corporate Services and Transformation
- Non-Executive Advisors
On behalf of Scottish Ministers, we manage around half a million hectares (ha) of woodland and associated habitats in Scotland. Work is carried out by staff in five regions. A Regional Manager, employing over 100 staff, heads up each region.
Staff work includes:
- management and delivery of establishing and maintaining new woodland
- felling and the sale of timber
- restocking, maintaining and protecting existing woodlands
- native woodland management, restoration and expansion
- wildlife management and conservation
- building and maintaining an access infrastructure to woodlands
- buildings management
- renewable energy production
- managing, developing and promoting access and enjoyment of the land.
Read our Corporate Plan for more information on our structure and activities.
Supply chains
Our supply chain includes a variety of third-party suppliers, contractors and our timber purchasing customers, which provides both skilled and unskilled work. This can be manual, motor manual or machine based. Various organisations also provide us with goods that could have either:
- direct supply chains, which is chemicals supplied direct from the manufacturer
- multi-tier supply chains, which is laptops with components sourced from across the world
This ranges from, but is not limited to, clothing, hardware, chemicals and equipment.
Visit Public Contracts Scotland for a full list of our contracts.
Our Procurement team helps make sure the company does things the right way. They check our contracts and suppliers to see if there’s any risk of human trafficking and take steps to reduce that risk wherever they can.
Countries of operation and supply
We currently only operate in Scotland. The majority of our land management work and services have shorter supply chains. Only a small number of our suppliers (IT, harvesting machinery etc) have extended supply chains which reach into Europe and beyond.
High-risk activities
Our highest risk areas for human trafficking are like those experienced internationally. These are in the areas of:
- civil engineering
- timber production (harvesting)
- haulage
- new planting
- restocking and spraying
Most these areas are now carried out on contract.
A further risk occurs in the procurement of specific goods. For example, the supply chains of materials and garments for the clothing sector are often manufactured outside the EU. Often this includes countries that have experienced these practices before.
Corporate responsibility
Responsibility for the agency's prevention of human trafficking is as follows:
- Director of Commercial Development
- Head of Procurement
- Head of People and Organisational Development
- The Health, Safety and Wellbeing team
The forestry sector is not free from human trafficking. Some of the work in our woodlands could provide opportunities to exploit people.
- The Procurement team and Contract Managers
When procuring goods and/or services, a User Intelligence Group (UIG) is set up. This includes a mix of procurement and technical expert(s) in the procured area. This team looks for risks and checks for signs of human trafficking in our buying processes. They do this by using procurement tools and guidance, which helps public bodies follow policy and legislation. This team looks for risks and checks for signs of human trafficking in our buying processes. Afterwards, they'll ensure the correct specification is in the tender and contract.
Before working with someone, they make sure we get the right documents. These documents will state the action taken to prevent human trafficking. When needed, our contracts include checks by outside organisations to make sure everything’s above board. Our Procurement Strategy explains how we’ll follow the law in Scotland and Europe to stop human trafficking.
- HR and Learning and Development teams (the People team)
This team needs to stay up to date on employment law, including laws about human trafficking. They also make sure what they know is included in our policies, procedures, and messages sent to employees. The People team has access to different legal experts they can turn to whenever they need help.
Relevant policies
Our policies which set out our approach to the risk of modern slavery and steps to prevent this are below:
We ask all current and former employees to report anything they think might be wrong or suspicious in the agency's work or supply chains. This includes anything that could involve slavery or human trafficking.
We’ve a whistleblowing process that lets employees speak up without worrying about getting in trouble. If someone has concerns, they can report them to their:
- Line Manager
- Head of Function
- Chief Executive
- Nominated Officer
The Civil Service Code sets out the actions and behaviours expected of employees when at work or representing the agency. We work hard to maintain high standards of responsibility and ethical behaviour in how we operate as a business and manage our supply chain.
The promotion of fair work practices when procuring goods and/or services.
We undertake due diligence when considering new suppliers and reviewing our existing ones. These steps include:
- mapping the supply chain on a contract by contract basis. This assesses particular product or geographical risks of human trafficking based on high risk activities
- evaluating the human trafficking risks of each new supplier. We do this by using the tools provided within the Scottish Procurement Policy Note (SPPN). Please note, this may be part of a more general human rights or labour rights assessment.
- assuring appropriate supplier audits or assessments through a third-party auditor if appropriate
- having appropriate termination clauses within our contracts. To date, this has not been needed
Actions taken
Since our last statement, we've:
- developed resources and guidance to help staff see the signs of human trafficking
- continued to put in place measures set out in Reducing the Risk of Human Trafficking and Exploitation in the Performance of Public Contracts: SPPN 3/2020
- included clauses to new contracts highlighting the need to meet environmental, social and employment law. This includes the impacts of breaches in high risk areas
- undertake bidder due diligence as part of our procurement process when tendering for work assessed as higher risk by asking for specific evidence and confirmation of adherence to relevant laws and policies in this area. This involved supply chains both directly and indirectly through possible sub-contractor routes.
Last approved
Version 1 - 7 October 2022 by the Executive team
Version 1.1 – 1 May 2025 by Director of Commercial development and Corporate services
This statement is reviewed and updated annually.