Housing Ombudsman Complaint Handling Code – Self-assessment, post merger

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 landlord, its own staff, or those acting on its behalf, affecting a resident or group of residents.’

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our Complaints Policy (Section 3) our definition reflects the Housing Ombudsman Code as follows:

A complaint is an expression of dissatisfaction, however made, about the standard of service, actions, or lack of action by Amplius, it is colleagues or those acting on its behalf, affecting an individual customer or a group of customers.

Evidence:

• Complaints Policy
• Link to Website

Improvement action

 None

Code requirement

A resident does not have to use the word ‘complaint’ for it to be treated as such. Whenever a resident expresses dissatisfaction landlords must give them the choice to make complaint.

A complaint that is submitted via a third party or representative must be handled in line with the landlord’s complaints policy.

Compliance:   

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our Complaints Policy (section 3) we have specified our customers do not need to use the word complaint for it to be treated as such.

Whenever a customer expresses dissatisfaction, Amplius will offer them the option to formally log a complaint.

Improvement action

We are developing our new induction programme for colleagues across the merged organisations to further strengthen this section of the code.

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:   

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy outlines that a service request is for us to take action to put things right. Whilst a service request is not a complaint we record and monitor the types of service requests we receive.

Definition of a Service Request

A service request is a request from a resident to Amplius requiring action to be taken to put something right.

Where possible we will encourage an early and local resolution of concerns and recognise that there will be times where it may be possible to agree and secure resolutions with customers immediately. In these circumstances, in agreement with the customer, we will not log a formal complaint and will deal with this as a service request.

Where our customer expresses dissatisfaction with the response to their service request, the issue will be logged as a formal complaint and progress to Stage 1.

We completed a focus group with customers in May 2024 to discuss our complaints process and delivered colleague training.

Improvement action

We are commencing a new Complaints Working Group with our involved customers in February 2025 to work with us to develop and monitor our performance of complaint handling and ongoing compliance with the Ombudsman Complaint Handling Code.

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:   

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our Complaints Policy, we have a section headed:

Dissatisfaction with our Decision-Making:

There will be occasions where customers have exhausted our complaints process and remain dissatisfied with the outcome. In these circumstances there are a range of options available for further escalation.

• Any customers, leaseholders and housing applicants who are unhappy with the outcome of their review (stage 2), can escalate the matter directly with the Housing Ombudsman
• For complaints relating to our care and support services, customers can refer their complaint to the Care Quality Commission.

Improvement action

We are designing new colleague training and awareness material to roll out for induction of new employees and annual awareness training by end of July 2025.

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:   

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We conduct transactional customer satisfaction surveys using both digital and telephone methods.

We closely monitor the scores received and when customers request a callback to discuss their concerns, we offer them the opportunity to raise a complaint if they wish to pursue their issues through our complaints process.

Improvement action

We are reviewing our approach to satisfaction surveys to ensure this is a consistent approach across the new organisation. This will be completed by March 2025 to be implemented for 1st April 2025.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy outlines the situations when we would not accept a complaint (Part 3) 

When we have identified an exclusion, we will write to our customer to explain why this is the case. 

Our reasonable adjustment section outlines that we will make any reasonable adjustments needed to ensure our customers are able to use our complaints process. 

Evidence: 

• Complaints Policy 
• Template Exclusion letter 

Improvement action

We have developed a mechanism to capture exclusions for Legacy Grand Union and exclusion templates have been implemented for consistency until whole ICT system development is undertaken. 

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:

1. The issue giving rise to the complaint occurred over twelve months ago.
2. 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.
3. Matters that have previously been considered under the complaints policy.

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy outlines the situations when we would not accept a complaint. 

If we do not accept a complaint, a detailed explanation will be provided to customers setting out the reason why the matter is not suitable for the complaints process and the right to take that decision to the Housing Ombudsman. 

Evidence: 

• Complaints Policy 
• Copy of the exclusion template letter 

Improvement action

We will be developing our housing management systems to ensure the exclusions are monitored and recorded consistently for the organisation. 

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states that complaints referred to us within a 12-month period of time will be accepted.

Within the Policy we outline that this time limit will not apply if we are satisfied that there are exceptional circumstances such as safeguarding or health and safety concerns.

Evidence:

• Link to website for Policy
• Copy of Policy

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

• Our Complaints Policy outlines the circumstances in which we would not accept a complaint. 

When Amplius applies an exemption contained with the handling code and set out within our Complaints Policy, the reasons for the decision are included in the acknowledgement response and the customer is advised on the next steps and how to seek further advice from the Housing Ombudsman. 

Evidence: 

• Copy of Complaints Policy 
• Exemption template letter 
• Reports on number and reason for exclusions

Improvement action

We have developed a mechanism to capture exclusions for Legacy Grand Union and exclusion templates have been implemented for consistency until whole ICT system development is undertaken. 

Consistent letter templates to be rolled out 3^rd February 2025 

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy outlines the situations when we would not accept a complaint.

If we do not accept a complaint, a detailed explanation will be provided to customers setting out the reason why the matter is not suitable for the complaints process and the right to take that decision to the Housing Ombudsman.

Evidence:

• Complaints Policy
• Evidence in template letters

Improvement action

Policy updated under Fairness of Complaint Handling, so it is explicit to the customer. 

We will consider the individual circumstances of each complaint throughout our review and before we make any decisions. 

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy provides guidance that complaints can be received through any of our communication channels, which includes telephone, email and our website.

Under the section titled ‘Equality, Diversity, and Inclusion,’ we confirm that all complaints will be handled in accordance with Amplius commitment to promoting equality, diversity, and inclusion. On our website, we provide guidance to customers on many ways to contact Amplius for making a complaint.

Evidence:

• Complaints Policy
• Link to the website.

Improvement action

To implement a Reasonable Adjustment Policy to strengthen our approach to include that information is accessible and available in appropriate formats, including interpretation and translation services, large print, and audio formats.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy informs customers how they can make a complaint, and this includes to our employees.

All colleagues within Amplius know we have a dedicated complaints team who handle complaints and how to make the referral if complaints are reported to them.

Evidence:

• Complaints Policy
• Mandatory Training of code - Legacy GU have posted on Intranet when changes made – Mandatory E Learning (Skill gate) rolled out to all operational colleagues.

Improvement action 

New Induction and mandatory complaint training to be rolled out by end of July 2025

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our Complaints Policy we have a section of evaluation, review and performance monitoring which demonstrates how we will monitor performance weekly, monthly and quarterly.

Evidence:

• Complaint Reports for Committee, Board and
• Customer Forum
• Website Links
• Copies of Newsletters

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy is on our website with an easy read version breakdown on the main page. Translations and copies in alternative formats are available on request. To improve accessibility on our website, it is tested to W3C AA accessibility standard. This allows customers to change contrast levels, modify the font, colours, line height or spacing of text, increase or decrease the website font size, navigate the website using a keyboard, translate the website into a different language.

Evidence:

• Complaints Policy
• Link to website page.

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

This section is not included in the Complaints Policy.

Improvement action

Policy has been updated, adding in the section of accessing the complaints service:

The Complaints Policy is accessible on our website together with the contact details for the Housing Ombudsman Service.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy has a reasonable adjustment section informing customers they have the opportunity to have a representative.

Evidence:

• Complaints Policy 
• Link to website.
• Vulnerability Statement

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our Complaints Policy in Stage 2 written responses to customers, we provide contact information for the Housing Ombudsman. This practice is outlined within our Complaints Policy.

Evidence:

• Complaints Policy
• Template letters.
• Website

Improvement action

Updated Policy adding in Stage 1 as only Stage 2 is confirmed at present, so does not comply with draft letters being used as letters at stage 1 provide the opportunity for referral at this stage.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Amplius has a dedicated Complaints Team, responsible for overseeing the handling of all complaints received. This team ensures compliance with the Ombudsman Complaints Handling Codes.

We have a Housing Ombudsman case Team Leader within the same structure for liaison with the Ombudsman. We have a Senior Complaints and Improvement Manager responsible for training and embedding improvements alongside a Head of Customer Experience who is responsible our overall complaint handling processes, performance, and business wide awareness training as well as ensuring learning from complaints.

Evidence:

• Complaints Policy confirms
• Structure
• Job Descriptions
• Director of Customer Operations has oversight of complaints.

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaint Officers proactively engages with colleagues upon logging the complaint, aiming to gain a comprehensive understanding of the issue and work toward a fair and balanced resolution.

Evidence: 

• Complaints Procedure 
• Process Map 

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Amplius colleagues responsible for managing complaints possess the necessary skills, experience and training. Upon logging a complaint, our Complaint Officers proactively engage with the complainant to gain a comprehensive understanding of the issue and work toward a fair and balanced resolution.

As a social landlord, we have established mechanisms to capture our lessons learnt from complaints for service improvement.

Complainants who have complained to Amplius are requested to participate in surveys to express their views on the handling and outcome of their complaints, allowing us to monitor customer satisfaction and identify areas for improvement.

Evidence:

• Complaints Policy
• Housing Ombudsman Training
• Satisfaction Survey Questions
• Satisfaction Survey results
• Lessons learnt

Improvement action

By the end of July 2025, we will implement mandatory induction training and refresher training for complaint handling staff for Amplius. 

Develop a consistent approach to sharing lessons learnt and satisfaction results with customers by the end of July 2025. 

New Complaints Working Group implemented in February 2025 to monitor performance and progress against improvement actions. 

Aligning current customer satisfaction survey questions to commence reporting shared performance from April 2025 in line with our Policy.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Amplius has a single Complaints Policy that applies to anyone who is a tenant or resident. A tenant or resident is anyone who receives or requests a service from us or who is affected by our activities. 

Evidence: 

• Complaints Policy and Procedure 
• Unconscious Bias Training 
• Vulnerable Customer Training 
• CIH Training – All training on portal 

Improvement action

Amplius to develop Complaint mandatory induction and colleague training incorporating legacy Grand Union E-Learning by the end of July 2025.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our Complaints Policy we have a two-stage complaint handling process in line with the Housing Ombudsman Code.

Evidence:

• Complaints Policy and Procedure

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our process consists of two stages, as outlined in our Complaints Policy. 

Evidence: 

• Complaints Policy 
• Committee Performance Reports 

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

All complaints even those about contractors are handled by our centralised Complaints Team. Amplius does not outsource the responsibility to those outside of our organisation, our complaint officers will collaborate with contractors throughout the investigation. 

Evidence: 

• Complaints Policy  
• Job Descriptions 

Improvement action

None.

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

All complaints even those about contractors are handled by our centralised Complaints Team. Amplius does not outsource the responsibility to those outside of our organisation, our Complaint Officers will collaborate with contractors throughout the investigation. 

Evidence: 

• Complaints Policy  
• Job Descriptions 

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We initiate contact using the complainant’s preferred communication methods and promptly send an acknowledgment letter that includes clarification regarding their Stage 1 and Stage 2 complaint, we advise our customers to reach out to us if there is anything they feel we have missed in the acknowledgement. 

Evidence: 

• Letter Templates 

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We have implemented consistent letter templates, and our written acknowledgments include a concise summary of the issues raised by the complainant and the desired outcomes. Additionally, the initial contact between the Complaint Officer and the tenant provides the opportunity to confirm the aspects of the complaint we are investigating. 

Evidence: 

• Letter templates 

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Team are an impartial and independent team that enables them to deal with complaints fairly with consideration given to all evidence received. In our acknowledgements to tenants, we provide them the opportunity to provide further evidence of their position to support and effective investigation. 

Evidence: 

• Template Letters 

Improvement action

Develop and implement a new Quality Assurance Framework by May 2025.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy sets out our approach to situations where our initial timescales agreed are not possible to adhere to, due to the specifics of the complaint. In these cases, we will agree an appropriate extension for response with the complainant in line with our Policy (up to 10 working days for a Stage 1 complaints and up to 20 working days for a Stage 2 complaint) and will keep our customers informed of how we will resolve the complaint. 

Evidence: 

• Complaints Policy 
• Template Letters 

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We keep details of tenant disabilities and vulnerabilities on our core housing management system.

Should a customer make us aware of any disability during the complaint process, this will be recorded within the complaint and only recorded on our database, should our customer request it. Should our customer ask us to record any disability, we will add this to our database.

Our reasonable adjustments section outlines that we will make any reasonable adjustments needed to ensure tenants are able to access and participate in the complaints process.

Evidence:

• Complaints Policy
• Data Protection
• Vulnerability Statement
• Consent Process (dealing with advocates and third Parties)
• Vulnerability Training
• Equality Impact assessments

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy outlines the situations in which we would not accept a complaint.

Evidence:

• Complaints Policy
• Letter Templates
• Evidence from correspondence with customers and CRM

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

All tenants who make a complaint have the details of their complaint and the outcome(s) stored securely on our core case management systems.

Evidence:

• Amplius’ CRM system
• Retention Policy

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints process enables remedies to be offered any stage of the process, with our Customer Experience Team given the autonomy to offer redress and remedies.

Evidence:

• Complaints Policy
• Compensation Procedure
• Training content

Improvement action

Develop and implement a single compensation procedure and deliver training by the end of March 2025.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

In our Complaints Policy we outline how we will deal with manage unacceptable actions and behaviours from customers.

In these circumstances we will refer to our Customer Conduct Procedure  

Evidence: 

• Customer Contact Policy 
• Evidence on CRM  
• Reference in Complaints Policy 

Improvement action

We have an Unreasonable Behaviour Policy and a Customer Conduct Procedure in place.

An overarching policy is being developed to be implemented by May 2025. 

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Customer Conduct Procedure ensures that decisions made are proportionate to the situation and take into account tenant needs. Prior to considering limited contact, colleagues should consider if there are any factors that may be influencing a customer’s behaviour and whether there are steps/referrals we can make to address this. For example, colleagues should consider if a customer has communication or capacity issues. Any restrictions imposed will be reasonable and proportionate and based on individual circumstances.

Evidence:

• Customer Conduct Procedure

Improvement action

We have an Unreasonable Behaviour Policy and a Customer Conduct Procedure in place.

An overarching policy is being developed to be implemented by May 2025. 

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We assess all complaints individually and will look to resolve them as early as possible. Our Team Leaders within the Complaints Team assess complaints to ensure priority is given for more complex complaints received.

Evidence:

• Complaints Policy
• Complaints Procedure

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states that we will acknowledge requests for Stage 1 complaints within 5 working days.

We monitor our performance against our compliance targets. The Head of Customer Experience and our Managers have oversight of the data, which shows performance in real time.

Evidence:

• Complaints Policy
• Complaints Procedure
• Quality Checks
• Performance Data

Improvement action

None.

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states that where an investigation is required our target to respond will be 10 working days.
We have a performance dashboard to monitor our performance against our compliance targets. The Head of Customer Experience and the Managers have oversight of the data, which shows performance in real time.

This allows us to identify and monitor complaints within required deadlines. The performance dashboard is able to demonstrate any complaints which fall outside our compliance.

Evidence:

• Complaints Policy
• Complaints Procedure
• Performance Reports
• Quality Checks
• Dynamics and BI reporting

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states that during the Stage 1 investigation of the process, there may be occasions where we are not able to provide our customer with a response to their complaint within the timescales we set. Where this happens, we will inform them of the expected timescale for a response and ensure they are aware of your right to contact the Housing Ombudsman. Any extension will be no more than 10 working days for a stage 1 response.

Evidence:

• Complaints Policy and Procedure
• Evidence on CRM of extensions and reason for extension
• Quality Checks
• Template Letters

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our extension letters we inform our customers of the extension, and they are signposted to the Housing Ombudsman if they are unsatisfied with our response.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates
• Performance information on extensions
• Quality Checks

Improvement action

System development to capture extensions within legacy GU Dynamics by end of March 2025.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states that we will inform our customer of any outstanding actions when we provide a response to their complaint.

There may be situations where actions are ongoing or outstanding following a complaint is closed.

Our Senior Complaint and Improvement Manager ensures our outstanding actions are tracked and customers are kept informed of any updates regarding these actions.

Evidence:

• Complaint Policy
• Complaint Procedure
• Performance Reports

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our complaint letters clearly set out each element that customers have asked us to investigate and the person responding to the complaint will set out clearly our response to each section, our decision and reason for this on each section of the complaint.

There is a section within our Complaints Policy to confirm we will address all points raised in the complaint and provide clear reasons for any decisions, referencing the relevant policy, law, and good practice where appropriate.

We have a quality checklist in place for monitoring purposes.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates
• Quality Checks

Improvement action

Develop and implement a new Quality Assurance Framework by May 2025.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We will incorporate any new complaints raised as part of the investigation into our stage 1 response where they relate to the investigation in question. If an issue is unrelated or will cause an unreasonable delay to us responding to the original complaint, this will be logged as a new complaint.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates

Improvement action

Policy updated.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We use a consistent structure in our complaint outcome letters at stage 1, this includes aspects a-g referenced in the code.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates
• Compensation Procedure
• Quality Checks

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy outlines that if our customer is unhappy with our resolution to their complaint, we will escalate this to stage 2, which is our final stage. Colleagues undergo training which ensures that they are clear on the process.

Evidence:

• Complaints Policy and Procedure
• CRM
• Quality Checks

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states we will acknowledge requests for Stage 2 within 5 working days.

Evidence:

• Complaints Policy
• Letter Templates
• Reporting BI and Dynamics

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

It is helpful for us to understand why a tenant remains unhappy with our

response when their complaint is escalated. Tenants may be contacted to help us understand how we can work with them to find a resolution that they are happy with, however this is not a requirement of a complaint being escalated and is not included in our list of exclusions.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates

Improvement action

None.

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy outlines that all stage 2 complaints will be considered by a different person within our Complaints Team.

Evidence:

• Complaints Policy
• Complaints Procedure

Improvement action

None.

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states that where a formal review is required our target to respond will be 20 working days.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates
• Committee Performance Reports
• Quality Checks

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states that during the Stage 2 review stage of the process, there may be occasions where we aren’t able to provide our customer with a response to their complaint within the timescales we set. Where this happens, we will inform them of the expected timescale for a response and ensure they are aware of your right to contact the Housing Ombudsman. Any extension will be no more than 20 working days for a stage 2 response.

Evidence:

• Complaints Policy
• Complaints Procedure
• Evidence on extensions and reason for extension
• Template Letters
• Committee Performance Reports

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our extension letters we inform our customers of the extension, and they are signposted to the Housing Ombudsman if they are dissatisfied with our response.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates
• Performance information on extensions
• Quality Checks
• Improvement action

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy states that we will inform our customer of any outstanding actions when we provide a response to their complaint.

There may be situations where actions are ongoing or outstanding following a complaint being closed. We will ensure that these actions are tracked, and customers are kept informed of any updates regarding these actions.

Evidence:

• Complaint Policy
• Complaint Procedure
• Committee Performance Reports

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our complaint letters clearly set out each element that customers have asked us to investigate and the team member responding to complaints will set out clearly our response to each section, our decision and reason for this on each section of the complaint.

There is a section within our Complaints Policy to confirm we will address all points raised in the complaint and provide clear reasons for any decisions, referencing the relevant policy, law, and good practice where appropriate.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates
• Quality Checks

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We use a consistent structure in our complaint outcome letters at stage 1, this includes aspects a-g referenced in the code.

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates
• Compensation Procedure
• Quality Checks

Improvement action

Develop and implement a new Quality Assurance Framework by May 2025.

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy and procedure it outlines that if a tenant is unhappy with our resolution to their complaint, we will escalate this to stage 2, which is our final stage. At this stage, the investigation

will include a review by a director or Head of Service

Evidence:

• Complaints Policy
• Complaints Procedure
• Letter Templates
• Committee Performance Reporting

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We will consider the full suite of remedies when considering the action needed to put things right and will track and monitor these actions to ensure we learn from trends.

Evidence:

• Complaints Policy
• Complaints Procedure
• Compensation Procedure
• Letter Templates

Improvement action

None.

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Within our Compensation Procedure any remedy offered will reflect the impact on the resident as a result of any fault identified.

Evidence:

• Compensation Procedure
• Committee Performance Reports

Improvement action

To review and implement one compensation procedure for Amplius.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Completion and monitoring are inconsistent. This is due to the two legacy organisations working in different ways, our improvement plan will ensure we are working to harmonise the processes.

Improvement action

By the end of March 2025 meetings wi.th owners of open commitments to commence fortnightly

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our complaints process outlines that any compensation offered will be appropriate, fair in accordance with our Compensation Procedure which has been developed alongside the Housing Ombudsman remedies guidance.

Evidence:

• Complaints Policy
• Complaints Procedure
• Compensation Procedure

Improvement action

Overarching compensation procedure to be implemented by end of March 2025.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our annual Complaints Performance and Service Improvement Report will be shared with our Customer Experience Committee on 14/5/25 and our Board on 20/5/25 head of the deadline for publication since we have merged our Organisations by 30^th June 2025. 

The assessment conducted in relation to the merger is to be completed by 28^th February 2025.  

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Annual Complaints Performance and Service Improvement Report will be shared with our Customer Experience Committee on 14/5/25 and our Board on 20/5/25 head of the deadline for publication since we have merged our organisations by 30^th June 2025.  

Improvement action

None.

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

This is our completed self-assessment following our merger of Grand Union and Longhurst Group.

A further self-assessment will be undertaken for Amplius by 30th June 2025.

The assessment is undertaken by the Head of Customer Experience but is also reviewed by the Compliance and Regulation Team as an independent check that the self-assessment is robust.

Improvement action

None.

Code requirement

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

Compliance:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We will comply with any orders made by the Ombudsman which includes reviewing and updating our self-assessment where required. 

We review knowledge and information management report after a determination.  An example of this was when we created a Damp and Mould Policy.

We undertake lessons learnt exercise after determinations received.

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We will ensure that we update our customers and the Housing Ombudsman if we are unable to comply with the code in exceptional circumstances. We have a clear Business Continuity Plan (BCP) to assess the impact of activities and services delivered to our customers. 

Evidence: 

• Business Continuity Plan 

Improvement action

Creating a customer portal would also aid this event. 

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We have a data warehouse which allows Amplius to bring data from different systems together so that we are able to identify trends and a dedicated Learning and Improvement Officer who collates our lessons learnt and shares with teams across the business.

On 4^th February 2025 we commenced a Complaints Working Group with our customers to strengthen the ability for them to influence and challenge our learning into changes in service delivery.   

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Board and Customer Experience Committee receive reports on common themes and identify areas for enhancing service delivery. In addition, the People and Governance Committee conducts broader reviews of the organisation’s culture to ensure it aligns with a customer-centric service approach. 

Evidence: 

• 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 

Improvement action

Develop induction training for new starters to Amplius and refresher training for all colleagues in relation to their role delivering awareness and role specific training by end of July 2025.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We have a specific section within our Complaints Policy in relation to how we learn from complaints.

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

Improvement action

Develop a page on our internal Facebook page where we share monthly information for colleagues by end of June 2025. 

Develop action plans for improvements and track change. 

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our Complaints Policy outlines that our Director of Customer Operations will have lead responsibility for complaints to support a positive complaint handling culture.

We have appointed a new Head of Customer Experience that has overall responsibility for our complaint handling function. 

Our Senior Complaint and Improvement Manager in collaboration with our Learning and Improvement Officer analysis themes and trends and presents the information back to senior colleagues with action plans.  

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

We have appointed Ashleigh Webber as the Member Responsible for Complaints (MRC). 

Our MRC is a Board Member, a member of our People and Governance Committee and a member of our Customer Experience Committee.

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our MRC 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.

As and when required our appointed MRC has direct access to the complaints team; they have been provided with a copy of the role responsibilities as defined by the Housing Ombudsman and that their role as MRC forms part of their appraisal review on an annual basis.

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

Our MRC receives the required outcomes in a-d. 

Evidence: 

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

Improvement action

None.

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:

• Longhurst Group:   YES
• Grand Union:   YES
• Amplius:   YES

Evidence and commentary

The legacy Longhurst 2025 Strategy is focussed upon customers, in order to deliver this Amplius requires colleagues who will embed a customer centric culture and approach. 

Evidence: 

• Agendas, reports, and minutes from management team meetings.
• CIH professional standards training  
• Training templates  
•  Complaints Policy  
• Complaints Team’s objectives / Job descriptions 

Improvement action

Include in the training to act within the Professional Standards for engaging with complaints as set by the Chartered Institute of Housing.