Housing Ombudsman Complaint Handling Code – Self-assessment 2024

Code requirement

A complaint must be defined as:

‘an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, affecting an individual resident or group of residents.

Compliance:   YES

Evidence

• Defined as such in the Group’s Complaint Policy and associated documents and literature (leaflets and website).
• Training content for colleagues defines as the same.

Commentary/explanation

• This is referenced in the Group’s Complaint Policy, associated literature and the website. Training has also been provided to all front-line colleagues to ensure that they are clear on how to identify a complaint.
• Colleagues have also attended training provided by the Housing Ombudsman as well as sharing learning from specific cases.
• Housing Ombudsman bitesize training sessions has been added to the Group’s learning directory and promoted internally through the Lowdown (the Group’s internal colleague communication tool).

Code requirement

The resident does not have to use the word ‘complaint’ for it to be treated as such. A complaint that is submitted via a third party or representative must still be handled in line with the landlord’s complaints policy.

Compliance:   YES

Evidence

• Customer Service - contact centre
• Webpage
• MP Enquiries
• ‘Contact Us’ form
• Feedback from transactional satisfaction surveys, such as responsive repairs and lettings.

Commentary/explanation

• Customers can contact us via a variety of methods to raise dissatisfaction, the word ‘complaint’ does not need to be utilised for it to be dealt with as a complaint.
• Colleagues are clear that the word complaint does not have to be used for an incident to be treated as such. Third parties raising complaints on behalf of customers (such as MP enquiries) are accepted and dealt within the Group’s Complaints Policy.

Code requirement

Landlords must recognise the difference between a service request and a complaint. This must be set out in their complaints policy. A service request is a request from a resident to the landlord requiring action to be taken to put something right. Service requests are not complaints, but must be recorded, monitored and reviewed regularly.

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Training video/slides around service request versus a complaint
• Sharing flow diagrams from the Complaint Handling Code
• Leaflet and website
• Service requests and tasks are reviewed for quality control.

Commentary/explanation

• Training has been carried out with both the Complaints Team and Customer Service Teams and processes updated to ensure that colleagues are clear on the difference between a service request and a complaint.

Code requirement

A complaint must be raised when the resident expresses dissatisfaction with the response to their service request, even if the handling of the service request remains ongoing. Landlords must not stop their efforts to address the service request if the resident complains.

Compliance:   YES

Evidence

• Group’s Complaint Policy
• Contact Centre Procedure
• Complaint Procedure

Commentary/explanation

• Irrespective of the complaint process the Group will respond to a request to put something right. An example of this would be a customer requesting a management move. If a complaint was then made in respect of any tenancy management issues, such as ASB handling/outcome, this would not stop the original service request from continuing.

Code requirement

An expression of dissatisfaction with services made through a survey is not defined as a complaint, though wherever possible, the person completing the survey should be made aware of how they can pursue a complaint if they wish to. Where landlords ask for wider feedback about their services, they also must provide details of how residents can complain.

Compliance:   YES

Evidence

• Customer Engagement Team’s procedures document this approach.
• Training material
• Group’s Complaints Policy

Commentary/explanation

• The Customer Engagement Team makes customers aware of the complaints process in the event the customer has raised dissatisfaction as part of their feedback. This is outlined in the Customer Engagement Team’s procedures.

• The Group have engaged a new cohort of customers, recruitment through The Hub, our digital engagement platform, to help develop the ’Customer Journey’ for the recently revised complaints process. This group will be further engaged with complaints assurance and feedback to continue to strengthen the customer voice.

Code requirement

Landlords must accept a complaint unless there is a valid reason not to do so. If landlords decide not to accept a complaint they must be able to evidence their reasoning. Each complaint must be considered on its own merits.

Compliance:   YES

Evidence

• Group’s Complaints procedure
• Group’s Complaints policy
• Knowledge banks

Commentary/explanation

• This is covered in our complaints policy. If a complaint is refused, a letter will be sent to the customer outlining why this has been refused. For the year 2023/24 only 25 complaints were refused.

Code requirement

A complaints policy must set out the circumstances in which a matter will not be considered as a complaint or escalated, and these circumstances must be fair and reasonable to residents. Acceptable exclusions include:

• The issue giving rise to the complaint occurred over twelve months ago.
• Legal proceedings have started. This is defined as details of the claim, such as the Claim Form and Particulars of Claim, having been filed at court.
• Matters that have previously been considered under the complaints policy.

Compliance:   YES

Evidence

• Part 3 of the Group’s Complaints policy

Commentary/explanation

• The Group’s Complaints Policy, Procedure and associated training sets out clearly where the Group will apply exclusions. We will nonetheless always seek to work with the customer to find a satisfactory outcome.

Code requirement

Landlords must accept complaints referred to them within 12 months of the issue occurring or the resident becoming aware of the issue, unless they are excluded on other grounds. Landlords must consider whether to apply discretion to accept complaints made outside this time limit where there are good reasons to do so.

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Group’s Complaint’s Procedure
• Training content
• Knowledge banks

Commentary/explanation

• The Group’s processes do allow discretion and pay regard to circumstances such as vulnerable customers and the Equality Act 2010.

Code requirement

If a landlord decides not to accept a complaint, an explanation must be provided to the resident setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Ombudsman. If the Ombudsman does not agree that the exclusion has been fairly applied, the Ombudsman may tell the landlord to take on the complaint.

Compliance:   YES

Evidence

• Part 3 of the Group’s Complaints Policy
• Evidence in letter templates
• Reporting of exclusions, systems, procedures.

Commentary/explanation

• This is covered in our complaints policy. If a complaint is refused, a letter will be sent to the customer outlining why this has been refused.

Code requirement

Landlords must not take a blanket approach to excluding complaints; they must consider the individual circumstances of each complaint.

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Evidence in letter templates

Commentary/explanation

• The Group does not undertake a blanket approach to exclusions in complaints. It is mindful of the safety of its customers and considers health and safety, safeguarding and vulnerabilities. The Group’s letter templates are clear that customers can escalate matters to the Ombudsman.

Code requirement

Landlords must make it easy for residents to complain by providing different channels through which they can make a complaint. Landlords must consider their duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of residents who may need to access the complaints process.

Compliance:   YES

Evidence

• Part 3 of the Group’s Complaints Policy confirms that customers can raise a complaint by accessing various different channels.

• Complaints Policy Part 4 makes reference to the Equalities Act.

• Each Group policy and procedure is accompanied by an Equality Impact Assessment.

Commentary/explanation

• An Equality Impact Assessment supports all policy revisions and is a standard part of the Group’s Policy Framework.

• In addition, specific policies are reviewed by the Group’s ED&I Group as well as feedback obtained from customers in respect of ED&I impact. Recommendations are recorded and acted upon.

Code requirement

Residents must be able to raise their complaints in any way and with any member of staff. All staff must be aware of the complaints process and be able to pass details of the complaint to the appropriate person within the landlord.

Compliance:   YES

Evidence

• Mandatory reading of the HOS Complaint Handling Code rolled out across customer front facing colleagues, this will be repeated again yearly.

• Training material

• Contact Centre policy and procedures

• Communications across the Group

• Part 3 of the Group’s Complaints Policy

Commentary/explanation

• Customers can raise their complaint in a variety of ways with colleagues. All colleagues understand the complaints process due to continued communication concerning the complaints policy and new HOS Complaint Handling Code. Ongoing training and raising awareness ensures that this is embedded across the Group.

Code requirement

High volumes of complaints must not be seen as a negative, as they can be indicative of a well-publicised and accessible complaints process.  Low complaint volumes are potentially a sign that residents are unable to complain.

Compliance:   YES

Evidence

• Complaint volumes-data

• Governance reporting at a Senior Leadership, Committee and Group Board level

• Involved Customer reporting, Scrutiny Panel, Customer Forum and Improving Lives Panel

Commentary/explanation

• Reporting on complaints is visible at all levels within the Group with feedback actively encouraged on various platforms in addition to reporting a complaint.

• Oversight is held by the Customer Experience Committee and Group Board.

Code requirement

Landlords must make their complaint policy available in a clear and accessible format for all residents. This will detail the two stage process, what will happen at each stage, and the timeframes for responding. The policy must also be published on the landlord’s website.

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Group website

Commentary/explanation

• The Group’s policy and website offers differing formats to meet customer needs, this includes translation services if required.

Code requirement

The policy must explain how the landlord will publicise details of the complaints policy, including information about the Ombudsman and this Code.

Compliance:   YES

Evidence

• Part 4 of the Group’s Policy

Commentary/explanation

• The Group’s website has been updated to direct customers to both the policy and Ombudsman’s details. Letters which are sent to customers in respect of complaints also have information as to how to contact the Ombudsman.

Code requirement

Landlords must give residents the opportunity to have a representative deal with their complaint on their behalf, and to be represented or accompanied at any meeting with the landlord.

Compliance:   YES

Evidence

• Part 3 of the Group’s Complaints Policy confirms that a complaint may be raised and dealt with by a representative.

Commentary/explanation

• In order to comply with its obligations under GDPR, the Group will ask for consent from the customer ahead of embarking on conversations with a third party. This consent is held centrally and reviewed periodically.

Code requirement

Landlords must provide residents with information on their right to access the Ombudsman service and how the individual can engage with the Ombudsman about their complaint.

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Contained within Group letter templates
• On the Group website and associated literature

Code requirement

Landlords must have a person or team assigned to take responsibility for complaint handling, including liaison with the Ombudsman and ensuring complaints are reported to the governing body (or equivalent). This Code will refer to that person or team as the ‘complaints officer’. This role may be in addition to other duties.

Compliance:   YES

Evidence

• Part 3 of the Group’s Complaints Policy confirms that the Director of Housing is the person responsible for oversight of Complaints

Commentary/explanation

• The Director of Housing and Customer Services has overall responsibility to ensure that the policy and procedure are effective and embedded across the Group. They will ensure that the respective teams understand their role.

• They will also provide periodic reporting to both the Customer Experience Committee and Group Board to ensure oversight from the governing body in respect of complaints, complaints handling and any liaison with the Ombudsman.

Code requirement

The complaints officer must have access to staff at all levels to facilitate the prompt resolution of complaints. They must also have the authority and autonomy to act to resolve disputes promptly and fairly.

Compliance:   YES

Evidence

• Director of Housing and Customer Services Role Profile
• Executive Team have oversight through reporting

Commentary/explanation

• The Director has authority over the Complaints Team who link with the Operational Lead responsible for the complaint. The Dynamics housing management system also has an escalation process built into it at each stage of the complaints process so that the complaint is allocated to the correct responsible officer and is then monitored for compliance and completion within timescales.

Code requirement

Landlords are expected to prioritise complaint handling and a culture of learning from complaints. All relevant staff must be suitably trained in the importance of complaint handling. It is important that complaints are seen as a core service and must be resourced to handle complaints effectively.

Compliance:   YES

Evidence

• Mandatory training plans
• Housing Ombudsman refresher training content
• Complaints Policy part 3 as detailed here.

Commentary/explanation

• The Group promotes a culture of learning from complaints. All customer-facing colleagues are suitably trained in the importance of complaint handling.

• Customer Service and Complaint handling training is mandatory for colleagues who are likely to deal with complaints. Refresher training on the new code has also been undertaken.

Code requirement

Landlords must have a single policy in place for dealing with complaints covered by this Code. Residents must not be treated differently if they complain.

Compliance:   YES

Evidence

• Group’s Complaints Policy and Procedure
• Bystander Bias Training
• Vulnerable Customer Training

Commentary/explanation

• The Group’s policy ensures consistency so that customers are not treated differently. The Group’s approach to customers with additional needs ensures that customers are treated fairly in accordance with their individual needs.

Code requirement

The early and local resolution of issues between landlords and residents is key to effective complaint handling. It is not appropriate to have extra named stages (such as ‘stage 0’ or ‘informal complaint’) as this causes unnecessary confusion. 

Compliance:   YES

Evidence

• Group’s Complaints Policy and Procedure
• Bystander Bias Training
• Vulnerable Customer Training
• CIH Mandatory Customer Care Training

Commentary/explanation

• The Group’s policy ensures consistency so that customers are not treated differently. The Group’s approach to customers with additional needs ensures that customers are treated fairly in accordance with their individual needs.

Code requirement

A process with more than two stages is not acceptable under any circumstances as this will make the complaint process unduly long and delay access to the Ombudsman.

Compliance:   YES

Evidence

• Group’s Complaints Policy and Procedure

Commentary/explanation

• The Group does not have a process with more than 2 stages.

Code requirement

Where a landlord’s complaint response is handled by a third party (e.g. a contractor or independent adjudicator) at any stage, it must form part of the two stage complaints process set out in this Code. Residents must not be expected to go through two complaints processes.

Compliance:   YES

Evidence

• Group’s Policy and Procedure

Commentary/explanation

• Not applicable.

Code requirement

Landlords are responsible for ensuring that any third parties handle complaints in line with the Code.  

Compliance:   YES

Evidence

• Group’s Policy and Procedure

Commentary/explanation

• Not applicable.

Code requirement

When a complaint is logged at Stage 1 or escalated to Stage 2, landlords must set out their understanding of the complaint and the outcomes the resident is seeking. The Code will refer to this as “the complaint definition”. If any aspect of the complaint is unclear, the resident must be asked for clarification. 

Compliance:   YES

Evidence

• Group’s Complaint Policy
• Group letter templates

Commentary/explanation

• The Group sets out what it believes is the reason for the complaint and will seek clarity if any aspect is not clear.

Code requirement

When a complaint is acknowledged at either stage, landlords must be clear which aspects of the complaint they are, and are not, responsible for and clarify any areas where this is not clear.  

Compliance:   YES

Evidence

• Acknowledgement Letters and evidence within record keeping

Commentary/explanation

• The Group will send an acknowledgement to the complaint setting out clearly and transparently what they are and are not responsible for. Additional training has been provided for colleagues in 2024 to ensure that they are clear on landlord responsibilities, this has been following learning from the Group’s complaints.

Code requirement

At each stage of the complaints process, complaint handlers must:  

1. deal with complaints on their merits, act independently, and  have an open mind;  
2. give the resident a fair chance to set out their position; 
3. take measures to address any actual or perceived conflict of interest; and  
4. consider all relevant information and evidence carefully. 

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Record keeping on the Group’s CRM system.  

Commentary/explanation

• The person dealing with the complaint, in line with the policy will ensure that they adhere to each point under 5.8.

Code requirement

Where a response to a complaint will fall outside the timescales set out in this Code, the landlord must agree with the resident suitable intervals for keeping them informed about their complaint.

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Record keeping on the Group’s CRM system.  

Commentary/explanation

• Where a complaint is likely to fall outside of the code, the extension is discussed with customers and suitable updates on progress provided. The Group has significantly improved its performance in this area and at present from 1 April 2024, 100% of complaints are within timescales.

Code requirement

Landlords must make reasonable adjustments for residents where appropriate under the Equality Act 2010. Landlords must keep a record of any reasonable adjustments agreed, as well as a record of any disabilities a resident has disclosed. Any agreed reasonable adjustments must be kept under active review.  

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Group’s CRM System
• Group’s Data Protection and Confidentiality Policy
• Group’s Privacy Notice
• Consent process (dealing with advocates and third parties)
• Vulnerability training content
• Bystander Bias training content
• Equality Impact Assessments 

Commentary/explanation

• The Group is committed to ensure that all customers are treated fairly and where required reasonable adjustments made in line with the needs and permission of the customer.

Code requirement

Landlords must not refuse to escalate a complaint through all stages of the complaints procedure unless it has valid reasons to do so. Landlords must clearly set out these reasons, and they must comply with the provisions set out in section 2 of this Code. 

Compliance:   YES

Evidence

• Part 3 of the Group’s Complaints Policy
• Evidence from correspondence with customers

Commentary/explanation

• The Group will not refuse to escalate a complaint through its process unless there is an exceptional and valid reason to do so. This situation would comply with section 2 of the code.

Code requirement

A full record must be kept of the complaint, and the outcomes at each stage. This must include the original complaint and the date received, all correspondence with the resident, correspondence with other parties, and any relevant supporting documentation such as reports or surveys.  

Compliance:   YES

Evidence

• The Group’s CRM system – Dynamics
• Group’s retention process

Commentary/explanation

• All information is  recorded on the Group’s system  including any supporting documentation or evidence. The Group’s retains historical records on an archive system which is accessible if required. The Group’s data retention policy applies.

Code requirement

Landlords must have processes in place to ensure a complaint can be remedied at any stage of its complaints process. Landlords must ensure appropriate remedies can be provided at any stage of the complaints process without the need for escalation.  

Compliance:   YES

Evidence

• Group’s Complaints Policy, Procedure and compensation guidance
• Training content

Commentary/explanation

• The Group’s culture encourages (where appropriate) for complaints to be remedied at any stage or escalation.

Code requirement

Landlords must have policies and procedures in place for managing unacceptable behaviour from residents and/or their representatives. Landlords must be able to evidence reasons for putting any restrictions in place and must keep restrictions under regular review.

Compliance:   YES

Evidence

• Group’s Unacceptable Behaviour Policy
• Evidence on the Group’s CRM system
• Referenced in the Group Complaint policy as detailed here.

Commentary/explanation

• Where restrictions have been put in place these are governed by a senior person within the organisation and reviewed periodically. The customer is advised of any restrictions, timescales and reviews in writing.

Code requirement

Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010. 

Compliance:   YES

Evidence

• Group’s Unacceptable Behaviour Policy
• Evidence on the Group’s CRM system
• Equality Impact Assessments
• Group’s Equality, Diversity and Inclusion Policy

Commentary/explanation

• Decisions are sanctioned by a senior person within the organisation, part of the decision is a due regard to the Equality Act 2010 and restrictions are applied as an exception.

Code requirement

Landlords must have processes in place to consider which complaints can be responded to as early as possible, and which require further investigation. Landlords must consider factors such as the complexity of the complaint and whether the resident is vulnerable or at risk. Most stage 1 complaints can be resolved promptly, and an explanation, apology or resolution provided to the resident. 

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures

Commentary/explanation

• The Group, upon receipt of a complaint will as part of the assessment identify if the customer is considered vulnerable or may have additional needs.

• Complaints are dealt with as quickly as possible. If cases are particularly complex and additional time is needed to carry out an investigation or find a resolution, customer are kept informed.

• The Group has recently introduced a triage process to enable us to respond to less complex complaints at the outset.

Code requirement

Complaints must be acknowledged, defined and logged at stage 1 of the complaints procedure within five working days of the complaint being received. 

Compliance:   YES

Evidence

• Part 3 of the Group’s Complaints Policy
• Evidence from Quality Checks undertaken on cases
• MI reporting of response times

Commentary/explanation

• Performance on the recording and responding to complaints forms part of the MI reporting within the Group.

• The figure for response times as at 1st June 2024 for acknowledgement and being logged is at 100%

Code requirement

Landlords must issue a full response to stage 1 complaints within 10 working days of the complaint being acknowledged.

Compliance:   YES

Evidence

• Part 3 of the Group’s Complaints Policy
• Evidence from Quality Checks undertaken on cases
• MI reporting of response times

Commentary/explanation

• Performance on the recording and responding to complaints forms part of the MI reporting within the Group.

• As at 1^st April 2024, all Stage 1 complaints have been closed within timescale (includes any complaints extended and responded to within the Housing Ombudsman code) with the exception of three complaints, where additional extensions have been agreed with the customer due to the complex nature of the complaint. The Group acknowledges however that it was non-compliant under the provisions of the Code, applicable prior to the 1^st April 2024.

• The Group has ensured that customers with ongoing complaints which were raised prior to the 1^st April 2024, have been kept informed of progress.

Code requirement

Landlords must decide whether an extension to this timescale is needed when considering the complexity of the complaint and then inform the resident of the expected timescale for response. Any extension must be no more than 10 working days without good reason, and the reason(s) must be clearly explained to the resident.

Compliance:   YES

Evidence

• Part 3 of the Group’s Policy and Procedure
• Evidence recorded on the Group’s CRM system- Dynamics
• Evidence from Quality Checks

Commentary/explanation

• Robust governance procedures are in place in regard to extensions, any extension requires approval from a Team Leader in conjunction with agreement from the Operational Lead.

Code requirement

When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman.

Compliance:   YES

Evidence

• Group’s CRM system - Dynamics
• Evidence from Letter Templates
• Evidence from Quality Checks

Commentary/explanation

• The Group provides customers with contact details for the Ombudsman where extensions to timescales are necessary.

Code requirement

A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures
• Evidence from Quality Checks

Commentary/explanation

• Following feedback from complaints the Group has recently updated its processes. This allows the Group to respond with its agreed actions and for the Operational Lead to monitor progress in conjunction with the complaint handler any outstanding actions. This is through to completion of the complaint.

Code requirement

Landlords must address all points raised in the complaint definition and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.

Compliance:   YES

Evidence

• Letters templates
• Group’s CRM system Dynamics
• Evidence from Quality Checks

Commentary/explanation

• The Group has provided further training to colleagues responding to complaints to ensure continued good practice. Further sessions to be provided throughout 2024/25.

Code requirement

Where residents raise additional complaints during the investigation, these must be incorporated into the stage 1 response if they are related and the stage 1 response has not been issued. Where the stage 1 response has been issued, the new issues are unrelated to the issues already being investigated or it would unreasonably delay the response, the new issues must be logged as a new complaint.

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures
• Evidence from Quality Checks
• Training content

Commentary/explanation

• Where additional complaints are raised as part of the investigation, they will be included in the original complaint so as to not unreasonably delay a response to a customer. Where new issues are raised, they are raised as a new complaint. Training to ensure compliance has been delivered to colleagues. The Group has provided further training to colleagues responding to complaints to ensure continued good practice. Further sessions to be provided throughout 2024/25.

Code requirement

Landlords must confirm the following in writing to the resident at the completion of stage 1 in clear, plain language:  

1. the complaint stage;
2. the complaint definition;
3. the decision on the complaint;
4. the reasons for any decisions made;
5. the details of any remedy offered to put things right;
6. details of any outstanding actions; and
7. details of how to escalate the matter to stage 2 if the individual is not satisfied with the response. 

Compliance:   YES

Evidence

• Group’s associated procedures
• Letters templates
• Compensation Procedure provides guidance where financial reimbursement and compensation are required to put things right.
• Evidence from Quality Checks

Commentary/explanation

• Templates are in place within the Group’s system which cover all items within 6.9 – evidence available upon request.

Code requirement

If all or part of the complaint is not resolved to the resident’s satisfaction at stage 1, it must be progressed to stage 2 of the landlord’s procedure. Stage 2 is the landlord’s final response.

Compliance:   YES

Evidence

• Group's Complaints Policy
• Group's CRM System - Dynamics
• Evidence from Quality Checks

Commentary/explanation

• Complaints are escalated when requested. If the Group were to refuse an escalation this would clearly be communicated in writing setting out why this was the case as well as giving the contact details of the Ombudsman .

Code requirement

Requests for stage 2 must be acknowledged, defined and logged at stage 2 of the complaints procedure within five working days of the escalation request being received.

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Group’s CRM system - Dynamics
• Letters templates
• Evidence from Quality Checks

Commentary/explanation

• Acknowledgement is given and confirmation of remaining issues is sought where unclear.

• As of 1st June 2024, 100% of acknowledgements have been logged on the Group’s housing management system and have been completed.

Code requirement

Residents must not be required to explain their reasons for requesting a stage 2 consideration. Landlords are expected to make reasonable efforts to understand why a resident remains unhappy as part of its stage 2 response.

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures
• Group’s CRM system - Dynamics
• Training template and content

Commentary/explanation

• The Group does not require customers to explain their reasons for requesting a stage 2 escalation however the Group will contact the customer to understand the reasons why they are not satisfied to fully understand the complaint.

Code requirement

The person considering the complaint at stage 2 must not be the same person that considered the complaint at stage 1.

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures

Commentary/explanation

• This is clearly defined within the Group’s processes and procedures. Training to ensure independence is provided to all colleagues involved in complaints.

Code requirement

Landlords must issue a final response to the stage 2 complaint within 20 working days of the complaint being acknowledged.

Compliance:   YES

Evidence

• Group Complaints Policy and associated procedures
• Evidence from the Group’s CRM system - Dynamics
• Letter templates and evidence from past cases
• Evidence from Quality Checks and MI reporting

Commentary/explanation

• MI reporting in place. From 1st April 2024, all Stage 2 complaints have been closed within timescale (includes any complaints extended and responded to within the Housing Ombudsman code).

• The Group acknowledges however that it was non-compliant under the provisions of the Code, applicable prior to the 1st April 2024.

• The Group has ensured that customers with ongoing complaints which were raised prior to the 1st April 2024, have been kept informed of progress.

• High volumes of complaints has meant that the Group’s performance in complaint handling was not what the Group would want or expect. Challenges with the Group’s repairs contractor has been the largest source of complaints with over 75% of complaints being either directly due to or connected to repairs.

Code requirement

Landlords must decide whether an extension to this timescale is needed when considering the complexity of the complaint and then inform the resident of the expected timescale for response. Any extension must be no more than 20 working days without good reason, and the reason(s) must be clearly explained to the resident.  

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures
• Evidence from the Group’s CRM system - Dynamics
• Evidence from letter templates
• Evidence from quality checks

Commentary/explanation

• Robust governance arrangements in place in respect of any extensions. Approval is required from a Team Leader with agreement from the Operational Lead.

Code requirement

When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman.

Compliance:   YES

Evidence

• Group’s Complaints Policy
• Letter templates
• Evidence from Quality Checks and MI reporting

Commentary/explanation

• The Group will provide customers with contact details of the Ombudsman where an extension is required.

• MI reporting is in place capture extensions and adherence to timescales.

Code requirement

A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.  

Compliance:   YES

Evidence

• Group’s Complaint Policy and associated procedure
• Evidence on the Group’s CRM system
• Letter templates

Commentary/explanation

• The Group has recently updated its  process to enable it to respond with agreed actions and for the Operational Lead to also monitor complaints in conjunction with the complaint handler until any outstanding actions are seen through to completion.

Code requirement

Landlords must address all points raised in the complaint definition and provide clear reasons for any decisions, referencing the relevant policy, law and good practice where appropriate.  

Compliance:   YES

Evidence

• Evidence from the Group’s CRM system - Dynamics
• Letters templates
• Evidence from Quality Checks

Commentary/explanation

• The Group will address all points raised within the complaint definition, providing clear reasons for decisions and will refer to the law, good practice etc where appropriate.

Code requirement

Landlords must confirm the following in writing to the resident at the completion of stage 2 in clear, plain language:  

1. the complaint stage; 
2. the complaint definition;
3. the decision on the complaint;
4. the reasons for any decisions made; 
5. the details of any remedy offered to put things right;
6. details of any outstanding actions; and
7. details of how to escalate the matter to the Ombudsman Service if the individual remains dissatisfied.

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures
• Evidence from the Group’s CRM system - Dynamics
• Letter templates
• Evidence from Quality Checks

Commentary/explanation

• The Group’s process and letter template sets out all of the requirements referred to under item 6.19.

Code requirement

Stage 2 is the landlord’s final response and must involve all suitable staff members needed to issue such a response.

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures
• Evidence from the Group’s CRM system - Dynamics
• Letter templates
• Evidence from Quality Checks
• Training plans

Commentary/explanation

• The Group ensures that stage 2 letters are overseen by colleagues with the appropriate training, experience and authority.

Code requirement

Where something has gone wrong a landlord must acknowledge this and set out the actions it has already taken, or intends to take, to put things right.

These can include: 

• Apologising;
• Acknowledging where things have gone wrong; 
• Providing an explanation, assistance or reasons; 
• Taking action if there has been delay; 
• Reconsidering or changing a decision; 
• Amending a record or adding a correction or addendum; 
• Providing a financial remedy;
• Changing policies, procedures or practices. 

Compliance:   YES

Evidence

• Group’s Complaints Policy and associated procedures
• Group’s Compensation Guidance
• Evidence from Quality Checks
• Reported (redacted) within the annual report on complaints, published on the Group’s website

Commentary/explanation

• The Group would set the details out at an individual case level within the response to the customer. More wider learning would be reported within the Group’s governance structure (at a Board and Committee level) as well as in the Group’s annual report on complaints.

Code requirement

Any remedy offered must reflect the impact on the resident as a result of any fault identified. 

Compliance:   YES

Evidence

• Group’s Compensation Guidance
• Evidence from Quality Checks

Commentary/explanation

• The Group would accept any failing identified and offer appropriate remedies to the customer.

• The Group has also learnt from previous determinations where compensation levels have been set and any similar complaints, similar redress has then been offered to ensure a consistency and fairness in approach.

Code requirement

The remedy offer must clearly set out what will happen and by when, in agreement with the resident where appropriate. Any remedy proposed must be followed through to completion.

Compliance:   YES

Evidence

• Evidence from customer letters
• Evidence from the Group’s CRM system - Dynamics
• Evidence from Quality Checks

Commentary/explanation

• Remedies are confirmed to the customer as part of the complaint standard process.

Code requirement

Landlords must take account of the guidance issued by the Ombudsman when deciding on appropriate remedies.

Compliance:   YES

Evidence

• Group’s Compensation guidance
• Evidence from Quality Checks
• Review of Housing Ombudsman Remedies Guidance and action plans implemented

Commentary/explanation

• The Group’s Governance Team undertake a review against all Spotlight reports that the Ombudsman produces, any actions or learning are shared with the business so that the Group learns from others as well as its own complaints. Outcomes are reported to the Customer Experience Committee.

Code requirement

Landlords must produce an annual complaints performance and service improvement report for scrutiny and challenge, which must include: 

1. the annual self-assessment against this Code to ensure their complaint handling policy remains in line with its requirements.
2. a qualitative and quantitative analysis of the landlord’s complaint handling performance. This must also include a summary of the types of complaints the landlord has refused to accept;
3. any findings of non-compliance with this Code by the Ombudsman;
4. the service improvements made as a result of the learning from complaints;
5. any annual report about the landlord’s performance from the Ombudsman; and
6. any other relevant reports or publications produced by the Ombudsman in relation to the work of the landlord. 

Compliance:   YES

Evidence

• Report presented to the Customer Experience Committee (11/06/2024)
• Self Assessment checklist presented as part of the report to the above Committee (11/06/2024)
• Copies of minutes for the Customer Experience Committee (11/06/2024)
• Report presented to the Group Board for approval (26/06/2024)

Commentary/explanation

• The copy of the covering report to this checklist sets out all of the requirements under 8.1.

Code requirement

The annual complaints performance and service improvement report must be reported to the landlord’s governing body (or equivalent) and published on the section of its website relating to complaints. The governing body’s response to the report must be published alongside this.

Compliance:   YES

Evidence

• On the agenda for the Group Board  (26/06/2024)

Code requirement

Landlords must also carry out a self-assessment following a significant restructure, merger and/or change in procedures.

Compliance:   YES

Commentary/explanation

• The Group would undertake a new self-assessment following a significant restructure or merger as part of its review of its governance documents. It would apply the same in the event of material changes to procedures.

Code requirement

Landlords must also carry out a self-assessment following a significant restructure, merger and/or change in procedures.

Compliance:   YES

Commentary/explanation

• The Group enjoys an open and transparent relationship with its Regulators, in the event of an investigation the Group would cooperate fully and where necessary update its self-assessment.

Code requirement

If a landlord is unable to comply with the Code due to exceptional circumstances, such as a cyber incident, they must inform the Ombudsman, provide information to residents who may be affected, and publish this on their website. Landlords must provide a timescale for returning to compliance with the Code.

Compliance:   YES

Evidence

• Group Business Continuity Plans

Commentary/explanation

• Part of the Group’s process when invoking the BCP is to assess the impact of the event on critical activities and services, this would include services to customers. The Group would continue an open dialogue with its Regulator’s in respect of any non-compliance, including remedial timescales and risk.

Code requirement

Landlords must look beyond the circumstances of the individual complaint and consider whether service improvements can be made as a result of any learning from the complaint. 

Compliance:   YES

Evidence

• Group’s Annual Complaint and Service Improvement Report
• Working with Customer to review complaints quarterly through the newly formed Customer Experience Committee from 01 April 2024
• Spotlight Report reviews and action plans
• Trend analysis reporting and MI

Commentary/explanation

• The Group has developed a data warehouse which is providing the Group the ability to look at trends and correlate complaints against different customer types, locations and homes. The outcomes of this are informing future service deliver and the Group’s overall target operating model.

• The Group audited its complaints process in 2024 and will be conducting a further review later in the year to ensure continual improvement.

Code requirement

A positive complaint handling culture is integral to the effectiveness with which landlords resolve disputes. Landlords must use complaints as a source of intelligence to identify issues and introduce positive changes in service delivery. 

Compliance:   YES

Evidence

• Inter-team work group – outcomes and minutes
• Damp and mould review – East Northants
• Bystander Bias training
• Vulnerable Customer training
• People Strategy
• Group’s Values
• Group’s associated processes
• Group’s reporting on damp and mould in East Northants

Commentary/explanation

• The Group Board and Customer Experience Committees receive reporting in respect of common themes and where service delivery can be improved. Culture more broadly across the Group is reviewed by the People, Remuneration and Nominations Committee (PREMCO) to ensure that the culture of the Group reflects a customer centric service.

Code requirement

Accountability and transparency are also integral to a positive complaint handling culture. Landlords must report back on wider learning and improvements from complaints to stakeholders, such as residents’ panels, staff and relevant committees. 

Compliance:   YES

Evidence

• Group’s Annual Service and Performance Improvement Report
• Group Board Complaints Report
• Group Board Performance Report
• Customer Experience Committee reporting cycle
• PREMCO reporting cycle
• Director’s meeting agenda
• Executive Team agenda
• Customer Complaints Committee
• Customer Forum Report

Commentary/explanation

• Learning through complaints forms part of the periodic reporting to the Group Board and Committees. Directors and Executives also receive reporting on complaints and lessons learnt.

Code requirement

Landlords must appoint a suitably senior lead person as accountable for their complaint handling. This person must assess any themes or trends to identify potential systemic issues, serious risks, or policies and procedures that require revision.

Compliance:   YES

Evidence

• Director of Housing and Customer Services

Code requirement

In addition to this a member of the governing body (or equivalent) must be appointed to have lead responsibility for complaints to support a positive complaint handling culture. This person is referred to as the Member Responsible for Complaints (‘the MRC’).Landlords must appoint a suitably senior lead person as accountable for their complaint handling. This person must assess any themes or trends to identify potential systemic issues, serious risks, or policies and procedures that require revision.

Compliance:   YES

Evidence

• Chris Tyson, Chair of the Customer Experience Committee
• Job description for the Chair of the Customer Experience Committee
• Annual report on complaints performance
• Statement on website from governing body in respect of complaints performance

Code requirement

In addition to this a member of the governing body (or equivalent) must be appointed to have lead responsibility for complaints to support a positive complaint handling culture. This person is referred to as the Member Responsible for Complaints (‘the MRC’).Landlords must appoint a suitably senior lead person as accountable for their complaint handling. This person must assess any themes or trends to identify potential systemic issues, serious risks, or policies and procedures that require revision.The MRC will be responsible for ensuring the governing body receives regular information on complaints that provides insight on the landlord’s complaint handling performance. This person must have access to suitable information and staff to perform this role and report on their findings.

Compliance:   YES

Evidence

• Customer Experience Committee rolling agenda, reports and minutes
• Group Board rolling agenda, reports and minutes
• Governing Body statement

Commentary/explanation

• The MRC as Chair of the Customer Experience Committee will receive reports which include all specifications under 9.6. This is confirmed in the statement from the governing body and published on the Group’s website.

Code requirement

As a minimum, the MRC and the governing body (or equivalent) must receive: 

1. regular updates on the volume, categories and outcomes of complaints, alongside complaint handling performance;
2. regular reviews of issues and trends arising from complaint handling;  
3. regular updates on the outcomes of the Ombudsman’s investigations and progress made in complying with orders related to severe maladministration findings; and 
4. annual complaints performance and service improvement report.

Compliance:   YES

Evidence

• Customer Experience Committee rolling agenda, reports and minutes
• Group Board rolling agenda, reports and minutes
• Governing Body statement

Code requirement

Landlords must have a standard objective in relation to complaint handling for all relevant employees or third parties that reflects the need to: 

1. have a collaborative and co-operative approach towards resolving complaints, working with colleagues across teams and departments;
2. take collective responsibility for any shortfalls identified through complaints, rather than blaming others; and
3. act within the professional standards for engaging with complaints as set by any relevant professional body.

Compliance:   YES

Evidence

• Customer Experience Committee rolling agenda, reports and minutes
• Group Board rolling agenda, reports and minutes
• Governing Body statement

Commentary/explanation

• The MRC as Chair of the Customer Experience Committee will receive reports which include all specifications under 9.6. This is confirmed in the statement from the governing body and published on the Group’s website.