Housing Ombudsman Self Assessment with the Housing Ombudsman Complaint Handling Code - Sept 25

Clipboard with form to be filled by man with a ballpoint pen

As a member of the Housing Ombudsman Scheme, we must comply with the Housing Ombudsman Complaint Handling Code. As required, we have reviewed our complaint-handling processes to ensure that they align with the requirements of the code.

Our self assessment, updated in September 2025, is below.

Alternatively, this document and be downloaded and printed — Housing Ombudsman Self Assessment - 2025[pdf] 460KB

Definition of a Complaint

Definition of a Complaint

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/Explanation
1.2 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.”		 Yes The exact Housing Ombudsman definition is included within our Complaints and Customer Feedback Policy which is available on our website (section 6).  
1.3 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.     Yes All staff have received training on the Housing Ombudsman Complaint Handling Code and have been trained to identify when issues raised should be escalated to a complaint. We do not rely on the customer using the word ‘complaint’ to escalate to a formal complaint.  (section 7.4)
Included in the Complaints and Customer Feedback Policy under section 7.3, we have included information on complainants approaching a dedicated person to facilitate resolution of complaints who include MP and councillor.		  
1.4 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. Yes As per our Complaints and Customer Feedback Policy, we will always look to try and resolve issues as quickly as possible and we will be clear with the customers as to what action has been taken following the issue/s being raised.  We would not deny a request for a customer to log a complaint, unless the request falls within the exemptions outlined within our Complaint and Customer Feedback Policy. (section 7.2)
We have a description of a service requested included in our Complaints and Customer Feedback Policy.  
All customer contact is logged and recorded via our Customer Relationship Management (CRM)system.  		  
1.5 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.  Yes All staff received training on the Housing Ombudsman Complaint Handling Code and have been trained to identify when issues raised should be escalated to a complaint. Our policy also supports this requirement. (section 7.4 and 10)   
1.6 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.  Yes We ensure that in cases where we ask for any wider feedback about our services, information on how to make a complaint is provided. (This includes our TSM and other perception surveys)  

Exclusions

Exclusions

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/
Explanation
2.1 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 Yes As per our Complaints and Customer Feedback Policy, we will always contact the customer to explain the reason for the complaint not progressing and provide support where possible and advise them of their right to contact the Housing Ombudsman at this stage. 
We would then update our Customer Relationship Management system (CRM) to record this contact for audit purposes. (section 7.2)		  
2.2

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.
 Yes We have a section in our Complaints and Customer Feedback Policy which outlines instances where cases ay not be considered as part of the policy. (section 7.2)  
2.3

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. 

 Yes This point is included in our Complaints and Customer Feedback Policy. (section 7.2).   
2.4

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.

 Yes As per our Complaints and Customer Feedback Policy, we will always contact the customer to explain the reason for the complaint not progressing and provide support where possible and advise them of their right to contact the Housing Ombudsman at this stage. (section 7.2)  
2.5

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

 Yes As per our Complaints and Customer Feedback Policy, in these instances, we will always consider the individual circumstances of each case. We will always contact the customer to explain the reason for the complaint not progressing and provide helpful support where possible. (section 7.2)  

Accessibility and Awareness

Accessibility and Awareness

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/
Explanation
3.1 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. Yes Multiple accessible routes are available for residents to make a complaint. These include via phone, email, social media, letter, via dedicated online complaints form, face to face and our customer portal. We manage all complaints, regardless of the channel in which they have originated, with the same expectations and timescales. This is outlined in our Complaints and Customer Feedback Policy. (section 7.3)  
3.2 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. Yes Front line staff have received training on the Housing Ombudsman Complaint Handling Code and have been trained to identify when issues raised should be escalated to a complaint and referred to our complaints process. (section 7.4) We also have a complaints training video on our staff intranet for staff to access.  
3.3 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. Yes We are committed to developing a positive complaints culture and recognise learning from our complaints is vital for service improvement. We would not deny a request for a customer to log a complaint, unless the request falls within the exemptions outlined within our Complaint and Customer Feedback Policy. (section 7.2) We have multiple accessible routes available for residents to make a complaint. (section 7.3)  
3.4 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. Yes Our Complaints and Customer Feedback policy is available online, along with an online version of our complaints leaflet. We also have an easy read version of this leaflet available on the website too. All can be downloaded from the website and paper copies can be provided on request. 
The leaflet has also been shared with front line staff to hand out to customers as and when required.
Our information is also available in several languages on our website. 
Our policy also details the 2 stage process (section 7.4)		  
3.5 The policy must explain how the landlord will publicise details of the complaints policy, including information about the Ombudsman and this Code. Yes This is included in our Complaints and Customer Feedback Policy statement. (section 1)  
3.6 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. Yes This is included within our “Who Can Complain” section of our Complaints and Customer Feedback Policy. (section 7.1)  
3.7 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. Yes We advise in our policy that customers can contact the Housing Ombudsman at any point during the complaints process for their guidance and advice. Contact details of the Housing Ombudsman service is included within our Complaints and Customer Feedback policy (section 7.6) , as well as in our acknowledgment letters, complaint holding letters and response letters. We also post regular social media posts to advertise the Housing Ombudsman service.
We also have a section on our feedback website page on the Housing Ombudsman and their contact details. 
Staff have also received training on how to sign post to the Housing Ombudsman Service if required. 		  

Complaint Handling Staff

Complaint Handling Staff

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/

Explanation
4.1 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. Yes We have a dedicated Complaints and Customer Feedback Team who act as the first point of contact for complaints and provide guidance and support to customers using our complaints service. They are responsible for the monitoring and auditing of the complaint process as well as outcome of complaints, including lessons learnt. This team is part of the Customer Directorate. 
A complaint feedback report is presented quarterly to our Customer Experience Committee, which is made up of senior staff, residents and Board representatives. 		  
4.2 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. Yes Complaints are investigated and dealt with by an appropriate investigating officer within each department. 
These staff are appropriately trained, as well as receiving support from the Complaints and Customer Feedback Team. Investigating officers are responsible for investigating the complaint and offering resolution and compensation as necessary. There are no conflicts of interest. Our stage 2 complaints are reviewed by a Head of service or Assistant Director/Director.		  
4.3 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 Yes

Complaint handling and learning from complaints is top priority. We strive to be better and learn from complaints. All investigating officers have received internal training on our complaints procedure (this training is also provided to all new staff whose role will include complaint investigations) Training guides are also available on our staff intranet. The Complaints and Customer Feedback Team attend team meetings to maintain staff awareness on complaints. This team will also provide support and guidance to staff when required. 
As part of our complaint response template letters, we include a section for learning and report on these areas in our customer feedback reports. Learning from complaints is also published on our dedicated learning page on our website.

We also hold a lesson learnt project with members of our Resident Voice and Influence Panel to help develop this area. This project group meets 4 times and year and focus on top complaint trends and themes. Lessons Learnt Project Group | Estuary
We also have a live learning tracker in place, which is actively monitored at Executive level and our Customer Experience Committee . This ensures transparency and provides ongoing visibility into the actions taken to address and learn from complaints.
 This point is covered in our Complaints and Customer Feedback Policy (section 9)
We will be including learning from complaints in our staff briefings. 

  

 

The Complaint Handling Process

The Complaint Handling Process

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/ Explanation

5.1 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. Yes The requirements of this code are covered under our Complaints and Customer Feedback Policy   
5.2 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. Yes We adopt a two stage complaints process. This is outlined in our Complaints and Customer Feedback Policy. (section 7.4) All staff have received training on our internal complaints process and Housing Ombudsman Complaint Handling Code to ensure that complaints are picked up and logged appropriately.  
5.3 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. Yes We adopt a two stage complaints process. This is outlined in our Complaints and Customer Feedback Policy. (section 7.4)  
5.4 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. Yes All complaint cases are handled and investigated by Estuary staff. When a complaint is received that requires information from any of our partners, an information request is sent to them to obtain any relevant evidence for consideration as part of the complaint investigation.  
5.5 Landlords are responsible for ensuring that any third parties handle complaints in line with the Code. Yes All complaint cases are handled and investigated by Estuary staff  
5.6 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. Yes Our complaint acknowledgement letter templates contain a dedicated section to outline the understanding of the complaint and the outcome the customer is seeking. In our current policy it outlines that should there be areas which are unclear, a member of the Complaints and Customer Feedback team will contact the complainant to ensure there is an accurate understanding of what has gone wrong and how the complainant would like us to resolve the issue. 
Our complaints policy outlines that the investigating officer will make initial contact with the resident once the complaint is received. (section 7.4)		  
5.7 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. Yes We have a section on our complaint acknowledgment template where aspects which are raised that we would not be responsible for can be added. (section 7.4)  
5.8

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. 
 Yes Our complaints training covered the importance of remaining objective and keeping an open mind in dealing with complaints. Sample checks of complaint responses are conducted by a range of officers, including the complaints team and Assistant Director of Customer Service and Director of Customer Service.
Training for investigating officers has raised awareness of this criteria. 
Within our complaints procedure, there is a section included for investigating officer responsibilities. 		  
5.9 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. Yes We have measures in place to ensure that all complaint responses are handled in line with the timescales set out in this code. It is noted, that should the response fall outside these timescales, we will agree with the resident suitable intervals for keeping them informed about the complaint. (section 7.4)  
5.10 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. Yes We have an equality and diversity section included within our Complaints and customer feedback policy. 
Our in-house system provides alerts for specific customer needs and our Complaints and Customer Feedback Team have access to this information.
We hold a record of any disabilities and reasonable adjustments on our Customer Relationship Management system (CRM).
Where a resident requires support to manage their tenancy, an alert is also added and a case raised on our in house system. These cases are regularly reviewed by our tenancy team and checked every 6 months in conjunction with the Housing Manager to ensure the alert is still valid. Support needs are also checked when tenancy audits are completed. 		  
5.11 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. Yes Outlined within our Complaints and Customer Feedback Policy are circumstances where escalation is not warranted. (section 7.2)
We will always contact the customer to explain the reason for the complaint not progressing and provide support where possible and advise them of their right to contact the Housing Ombudsman at this stage. 		  
5.12 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. Yes Once a complaint is received a dedicated complaint case is raised on our Customer Relationship Management (CRM) system and this creates a unique case reference number which is included within the complaint acknowledgment letter. All correspondence and documents are recorded under this complaint case and this case will remain active until all outstanding actions of the complaint are completed.  
5.13 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. Yes Our aim is to resolve complaints at the earliest opportunity, in accordance with our Complaints and Customer Feedback Policy. Investigating officers/ seniors are given full autonomy to investigate complaints and offer resolutions where necessary. As part of our internal process, stage 1 letter responses are also checked and signed off by a senior member of staff before being issued. (section 7.4)  
5.14 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. Yes We have included options to address unreasonable behaviour within our Complaints and Customer Feedback Policy. (section 8)  
5.15 Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010. Yes We have included options to address unreasonable behaviour within our Complaints and Customer Feedback Policy. (section 8)
As per our policy, we will ensure that we are meeting the requirements of the Equality Act 2010 and we will always consider the needs and circumstances of the customer when investigating a case to ensure the most appropriate course of action is followed.		  

Complaints Stages - Stages 1 and 2

Stage 1

Stage 1

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/ Explanation
6.1 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. Yes Following the complaint being logged and acknowledged, the investigating officer will contact the complainant via telephone, unless contact has been requested in an alternative form. 
This provides the opportunity for the investigating officer to consider all factors and determine if further investigations are required. If it is determined that further investigations may result in additional time being required, the investigating officer will follow the complaint extension process. This is outlined within our Complaints and Customer Feedback Policy. (section 7.4)		  
6.2 Complaints must be acknowledged, defined and logged at stage 1 of the complaints procedure within five working days of the complaint being received. Yes This timescale is included within our Complaints and Customer Feedback Policy, website and leaflet. (Section 7.4)
During 2024/25 we logged 99% of complaint cases within the five working days set out by the Housing Ombudsman code.		  
6.3 Landlords must issue a full response to stage 1 complaints within 10 working days of the complaint being acknowledged. Yes This timescale is included within our Complaints and Customer Feedback Policy, website (Including information for extensions) and leaflet. (section 7.4)
All investigating officers have received training on this requirement, and we have introduced internal control measures to mitigate the risk of being non-compliant in this area. 
During 2024/25 we responded to 95% of stage 1 complaints within 10 working days (From the cases that were extended, 94% of these cases were responded to within the extended timeframes for stage 1 complaints set by the Housing Ombudsman Code) 		  
6.4 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. Yes Following the complaint being logged and acknowledged, the investigating officer will contact the complainant via telephone, unless contact has been requested in an alternative form. 
This provides the opportunity for the investigating officer to consider all factors, including consideration of the complexity of the case. The investigating officer is also responsible for keeping the complainant updated with progress of the complaint as agreed. If during this part of the process it is noted that additional time is required, the investigating officer will follow the complaint extension process, which includes making a phone call to the complainant.
This call is then followed up with a holding letter to the complainant. 
This is outlined within our Complaints and Customer Feedback Policy (section 7.4)
Our holding letter also includes a section to explain in detail why complaint has been extended. 		  
6.5 When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman. Yes As part of our internal complaints procedure, we require customers to be contacted by phone or preferred method, when extending a complaint. This is then followed up with a holding letter, which includes the details of the Housing Ombudsman. 
This is outlined within our Complaints and Customer Feedback Policy (section 7.4)		  
6.6 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. Yes We aim to respond to complainants within the timeframe set within this code.
(Unless an extension is required and then a holding letter with a new response date will be provided) 
All follow up actions relating to the complaint are logged under the complaint case on our Customer Relationship Management (CRM) system. Updates on follow on works and action required by dates can also be added to these actions on the system. 
We hold a weekly complaint meeting with any staff who have complaint cases or complaint actions due in the week to ensure target action dates are met. 
Any additional correspondence to the complainant, including phone calls, emails are also recorded under this complaint case.
This is included in our Complaints and Customer Feedback Policy (section 7.4)		  
6.7 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. Yes Our complaint response letter includes a section which requires the investigating officer to list and address all points raised in the complaint. This was also reiterated to investigating officers at internal complaints handling training that has been held.  
6.8 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. Yes This point is included within our Complaints and Customer Feedback Policy (section 7.4)  
6.9

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. 
 Yes These criteria are included in our complaint response letter template and have been reiterated to investigating officers at complaint handling training that has been held.  

Stage 2

Stage 2

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/ Explanation
6.10 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. Yes As per our Complaints and Customer Feedback Policy, if a stage 2 escalation request is denied, we will confirm this in writing to the complainant, outlining the reason for this decision. We will also share details of the Housing Ombudsman Service at this stage. 
The Complaints and Customer Feedback Team also record any refusals to log a stage 2 and the reason why. (section 7.4)		  
6.11 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. Yes This timescale is included within our Complaints and Customer Feedback Policy, website and leaflet. (Section 7.4)
During 2024/25 we logged 99% of complaint cases within the five working days set out by the Housing Ombudsman code.		  
6.12 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. Yes As part of our complaint’s procedure, if required, the Complaints and Customer Feedback Team would contact the customer to ensure there is an accurate understanding of the stage 2 escalation.
Following the complaint being logged and acknowledged, the investigating officer will contact the complainant via telephone, unless contact has been requested in an alternative form. (section 7.4)		  
6.13 The person considering the complaint at stage 2 must not be the same person that considered the complaint at stage 1. Yes As per our policy, the investigating officer at Stage 2, would not have been involved within the investigation of the stage 1 complaint. (section 7.4)  
6.14 Landlords must issue a final response to the stage 2 within 20 working days of the complaint being acknowledged. Yes This timescale is included within our Complaints and Customer Feedback Policy, website (Including information for extensions) and leaflet. (section 7.4)
All investigating officers have received training on this requirement, and we have introduced internal control measures to mitigate the risk of being non-compliant in this area. 
During 2024/25 we responded to 98% of stage 2 complaints within 20 working days (From the cases that were extended, 100%% of these cases were responded to within the extended timeframes for stage 2 complaints set by the Housing Ombudsman Code).		  
6.15 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. Yes Following the complaint being logged and acknowledged, the investigating officer will contact the complainant via telephone, unless contact has been requested in an alternative form. 
This provides the opportunity for the investigating officer to consider all factors, including consideration of the complexity of the case. The investigating officer is also responsible for keeping the complainant updated with progress of the complaint as agreed. If during this part of the process it is noted that additional time is required, the investigating officer will follow the complaint extension process, which includes making a phone call to the complainant to advise the reason for the extension. This call is then followed up with a holding letter to the complainant. (section 7.4)		  
6.16 When an organisation informs a resident about an extension to these timescales, they must be provided with the contact details of the Ombudsman. Yes As part of our internal complaint’s procedure, we require customers to be contacted by phone or preferred method, when extending a complaint. This is then followed up with a holding letter, which includes the details of the Housing Ombudsman. 
This is outlined within our Complaints and Customer Feedback Policy (section 7.4)		  
6.17 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. Yes We aim to respond to complainants within the timeframe set within this code.
(Unless an extension is required and then a holding letter with a new response date will be provided) 
All follow up actions relating to the complaint are logged under the complaint case on our Customer Relationship Management (CRM) system. Updates on follow on works and action required by dates can also be added to these actions on the system. 
Any additional correspondence to the complainant, including phone calls, emails are also recorded under this complaint case.
We hold a weekly complaint meeting with any staff who have complaint cases or complaint actions due in the week to ensure target action dates are met. 		  
6.18 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. Yes Our complaint response letter includes a section which requires the investigating officer to list and address all points raised in the complaint. This was also reiterated to investigating officers at internal complaints handling training that has been held.  
6.19

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. 
 Yes These criteria are included in our complaint response letter template and have been reiterated to investigating officers at complaint handling training that has been held.  
6.20 Stage 2 is the landlord’s final response and must involve all suitable staff members needed to issue such a response. Yes We adopt a two stage formal complaints process and our stage 2 cases are reviewed by a Head of service or director. This is outlined within our Complaints and Customer Feedback Policy (section 7.4)  

 

Putting Things Right

Putting Things Right
Code Provision Code Requirement Comply: Yes/No Evidence Commentary/ Explanation
7.1

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. 
 Yes All these points are included in our response letter templates. As part of our internal procedure, complaint responses are reviewed by a senior member of staff prior to the final response being issued.  
7.2

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

 Yes This is reflected in our internal complaints procedure and all investigating officers have received further training on this requirement and this area is being closely monitored by our Executive Team and Senior Management Team.  
7.3

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.

 Yes Our complaint response letters have a section to include timelines for follow on actions. 
All follow-on actions from a complaint can be raised separately and monitored by the investigating officer. Updates on follow on works and action required by dates can also be added to these actions on the system. 
Follow up actions are tracked under the complaint case and only marked off when the action has been completed.
We hold a weekly complaint meeting with any staff who have complaint cases or complaint actions due in the week to ensure target action dates are met. 		  
7.4

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

   Our response letters have a dedicated section to outline compensation awarded. We have reviewed our remedies guidance in line with the Housing Ombudsman Service. 
We have a compensation policy to support our management of cases which can be located on our website.		  

Self Assessment, Reporting and Compliance

Self Assessment, Reporting and Compliance

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/

Explanation
8.1

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. 
 Yes The Annual Complaints Performance and Service Improvement Report is located on our website.   
8.2 The annual complaints performance and service improvement report must be reported to the landlord’s governing body (or equivalent) and published on the on the section of its website relating to complaints. The governing body’s response to the report must be published alongside this. Yes Our governing body’s response to the Annual complaints performance and service improvement report is available on our website –The Annual Complaints Performance and Service Improvement Report   
8.3 Landlords must also carry out a self-assessment following a significant restructure, merger and/or change in procedures. Yes Noted and will adhere to as required.  
8.4 Landlords may be asked to review and update the self-assessment following an Ombudsman investigation. Yes Noted and will adhere to as required.  
8.5 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. Yes Noted and will adhere to as required.  

Scrutiny and Oversight: Continuous Learning and Improvement

Scrutiny and Oversight: Continuous Learning and Improvement

Code Provision

Code Requirement

Comply: Yes/No

Evidence

Commentary/ 
Explanation
9.1 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. Yes We have included a section in our complaint response letters to remind investigating officers to include any wider service learning rather than just individual learning from the case. 
We a have a live learning tracker in place, which is actively monitored at Executive level and Customer Experience Committee. This ensures transparency and provides ongoing visibility into the actions taken to address and learn from complaints. This tracker helps to look at wider service improvements.		  
9.2 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. Yes As part of our complaint response template letters, we include a section for learning and report on these areas in our customer feedback reports. Learning from complaints is also published on our dedicated learning page on our website.
We also hold a lesson learnt project with members of our Resident Voice and Influence Panel to help develop this area. This project group meets 4 times and year and focus on top complaint trends and themes. 
This point is covered in our Complaints and Customer Feedback Policy (section 9)
We will be including learning from complaints in our staff briefings. 		  
9.3 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. Yes Performance against complaints is reported directly to our Executive Team as well as our Services Committee and Board. 
We have commenced a lesson learnt project with members of our Resident Voice and Influence Panel to help develop this area. This project group meets 4 times and year focus on top complaint trends and themes. https://estuary.co.uk/lessons-learnt-project-group
We also have a dedicated learning page on our website.
Complaints are discussed at both team and contractor meetings.
This point is covered in our Complaints and Customer Feedback Policy (section 9)		  
9.4 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. Yes Our Assistant Director of Customer Services and Director of Customer Services represent this area at a senior level, including representation at our governing bodies.  
9.5 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’). Yes The MRC is the Chair of our Customer Experience Committee and member of the Group Board. They have been advised of their role and provided with the guidance issued by the Ombudsman Service.  
9.6 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. Yes Our Customer Experience Committee and Board receives regular updates on our complaints handling performance through our Customer Feedback reports. The MRC has access to senior representatives and relevant staff and information if required.  
9.7

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.
 Yes Our Customer Experience Committee and Board receives quarterly updates on our complaints handling performance through our Customer Feedback reports. These reports include data on complaint volumes, trends, updates regarding Ombudsman investigations, determinations and/or CHFOs. Reports also include learning from complaints. Annual Complaints Performance and Service Report to be reviewed by MRC and Group Board in June 2025.  
9.8

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. 
 Yes As part of Staff Annual Appraisals, all staff now have an objective set to reflect effective complaint handling. This will be promoted throughout the year and audits will be carried out by our People and Organisational Development Team to ensure compliance.