London & Quadrant Housing Trust (L&Q) (202212263)

REPORT

COMPLAINT 202212263

London & Quadrant Housing Trust

29 March 2023

Our approach

The Housing Ombudsman’s approach to investigating and determining complaints is to decide what is fair in all the circumstances of the case. This is set out in the Housing Act 1996 and the Housing Ombudsman Scheme (the Scheme). The Ombudsman considers the evidence and looks to see if there has been any ‘maladministration’, for example whether the landlord has failed to keep to the law, followed proper procedure, followed good practice or behaved in a reasonable and competent manner.

Both the resident and the landlord have submitted information to the Ombudsman and this has been carefully considered. Their accounts of what has happened are summarised below. This report is not an exhaustive description of all the events that have occurred in relation to this case, but an outline of the key issues as a background to the investigation’s findings.

The complaint

The complaint is about:
1. the landlord’s response to the resident’s reports of a leak in the property.
2. the landlord’s complaint handling.

Background and summary of events

The resident has been a leaseholder of the property since 2013. The property is a ground floor one bedroom flat.
The landlord has no recorded vulnerabilities for the resident, however she was pregnant at the time of the repair.
The resident’s lease agreement states that:
1. the resident is responsible for:
  1. notifying the landlord as soon as possible of any repairs required to communal areas
  2. keeping the property in a good state of repair
  3. insuring the property appropriately
2. the landlord is:
  1. responsible for maintaining, repairing and decorating the main structure of the building and all external parts
  2. responsible for the pipes, sewers and drains
  3. not liable for any damage suffered by the leaseholder for any defect in any tank or pipe, or for any damage to the resident’s property due to the bursting or overflowing of any pipe or drain in the building
  4. responsible for covering the insurance relating to communal areas.
The landlord operates a two stage complaint policy which states:
1. at stage one, residents will receive an acknowledgement within five working days, and a full response will follow within ten working days
2. if the resident is unhappy with the response, they can request to escalate to the next stage. The complaint will be reviewed by another member of staff and a final written decision will be sent within 20 workings days. If there is likely to be a delay, then the landlord will explain why and write again within a further ten working days. Any delays will be agreed with the resident.
3. after confirming its decision in writing, it will monitor progress until all outstanding actions are complete.
The landlord has a compensation policy which states that it offers:
1. compensation if it fails to follow its policies and procedures, and this results in a negative impact for the resident
2. compensation for failure to deal satisfactorily with repairs that are its responsibility, and where the resident is continuing to live in poor conditions longer than is reasonable
3. discretionary payments where residents have suffered undue stress or upset because of its failure to respond to complaints within specified timescales
4. to consider refunding an insurance excess as a goodwill gesture if it has been negligent in its handling of a repair.
The landlord’s policy sets out statutory compensation for the ‘right to repair’, which it states is for secure tenancies, however at its discretion can be used for other tenure types. The purpose of the right to repair scheme is to get specific qualifying repairs done quickly that relate to health and safety, and affect an individual property or the communal area. This includes attendance to a blocked or leaking foul drain or soil stack.
The landlord has a repair policy which states that it is responsible for repairs and maintenance within communal areas. These include drains and repairs to soil stacks. The landlord advises that it will attend within the following timescales:
1. for routine repairs, at the “earliest mutually convenient opportunity”
2. for emergency works where there is an immediate danger, within 24 hours
3. for emergency works which occur out of hours, within four hours. The out of hours service will ‘make safe’ the immediate risk, and then raise follow on repairs.
The landlord has a vulnerable residents policy, which urges staff to consider whether a resident has a condition that may place them at greater risk in their home. It encourages staff to consider that they “think, respond and record” how they feel that the residents condition may affect them, how they should respond and how they should record this information so that all colleagues are aware.
On 15 June 2022, the resident contacted the landlord to advise there had been a leak of faeces from a sewage pipe that was coming into her property, and that she was pregnant. It raised a job with a 24 hour priority.
Meanwhile, the resident made an emergency call out to a private plumber. He attended, and was there for approximately four hours, charging the resident £370. The accompanying engineers report stated that:
1. the leak had been coming from the storage room, which had an access hatch to a stack drainage access fitting
2. the water was gushing out any time the sink was used from the flats above and the engineer unblocked the stack as it was overflowing
3. the blockage was caused by fatty deposits and some building work waste being flushed down the drain.
Later that day, the landlord’s drainage clearance specialists attended the property and cleared the blocked stack, which ran through the resident’s property from above. They used CCTV and were able to confirm that they had cleared the blockage, but a full descale to the stack was required to clear the mass of fat that had been deposited. This was noted on the landlord’s system, but no records were seen that this was communicated to the resident at the time.
On 20 June 2022 the resident emailed the landlord to complain. She advised that:
1. on 15 June 2022, she found significant damp in her cupboard and her belongings had been damaged. She had tried to clear this before starting her work from home. At around 11.15am she heard a “huge gushing” sound from above her flat. When she went to investigate she saw water coming through a hatch in her hallway and spilling onto her floor. The water was dirty and smelt badly, and despite her best efforts she was unable to stem the leak by herself
2. she tried to contact the landlord by phone but got cut off. Whilst trying to get through to the landlord again, she made contact with an emergency plumber online who said he could come to the flat immediately. She agreed to this as she was scared that if she did not, she would “soon be waist deep in sewage”
3. at around 11.30am she was able to get through to the landlord by phone. She explained that she was 18 weeks pregnant, and felt she was in “extreme risk”. The call handler advised that somebody would attend by 5pm
4. the plumber arrived shortly afterwards and made enquiries as to who was in the flats above to advise them not to use their sink or toilet. He was in the property for approximately five hours, and advised her that the problem was caused by people flushing fats and other substances down the drain
5. she had to call the landlord at 4pm and again at 6.30pm to chase where their plumbers were from her earlier call. Each time she called, she was informed that she was on the job list however the operatives may not get to her until the following day. She advised that she spoke to a manager but no notes had been placed on the system that she was pregnant
6. eventually an operative attended at 8pm. He advised that the system would need flushing out the following day and a new cap fitted to reseal the pipe. He confirmed, like the private plumber, that the issue was caused by other residents flushing fatty deposits down the drain. He said that the landlord should write to the other residents about this, and reassured her that she was not at fault
7. the following day starting from 8am, she had to call the landlord eight times to establish when someone would be coming to attend the job the operative mentioned the previous evening. Each time she called, the landlord said their systems were updating, and that she should call them back a little later. At 1.30pm, the landlord confirmed the job was raised as a 24 hour call out. Her work was disrupted and her partner had to come over to help
8. at 3.45pm an operative attended and removed some of the plasterboard within the property, in order to access the pipe fixing. He left the wall covered with a black bin bag, and advised her that the landlord would need to investigate further and make good the damage. A manager called later in the day to confirm this, and advised that the landlord would be in touch once the full report came through from the operative.
9. she heard nothing back after a few days, so had to chase the landlord again. She was advised that the damage to the property would have to go via building insurers, at a cost of £350 in excess. This was because the landlord would only repair the communal areas.
In summary of her complaint, the resident said that:
1. she felt her landlord had failed to act in a timely manner
2. she had been left in a “constant state of stress and anxiety” in a flat that was damp and smelt of dirty water
3. her internal and external walls have been affected with black mould, and that plaster was falling off (she included photographs of this)
4. the landlord had failed to investigate or manage its drains which had a direct impact on her property
5. she had to pay for a plumber, which she said she could not afford, to attend to an emergency caused through no fault of her own. She is unhappy that she had to pay a further £350 and make a claim via the buildings insurance to rectify the damage. She would have to borrow money for this
6. the landlord had failed to write to other residents, to warn them about flushing inappropriate material down the sink
7. being 19 weeks pregnant, this had significantly impacted her mental and physical wellbeing. She felt “distraught” at the lack of action or consideration that the landlord had placed on her situation.
As a resolution to her complaint, the resident said that she wanted:
1. the landlord to rectify damage caused to her walls. She wanted the damp treating, and the walls replastered
2. compensation for the £370 she spent on an emergency plumber, as the landlord failed to attend in a timely manner. She said she felt it had failed to properly maintain the drains, which could have prevented the issue happening in the first place
3. compensation for the £350 building insurance excess she now had to pay
4. the landlord to “take ownership” and create an action plan for residents to be informed as to when they can expect drains to be monitored and cleared on a regular basis.
On 27 June 2022, a local councillor emailed the landlord to raise an enquiry about the resident’s case. They advised that the resident was “desperate” and needed “intervention urgently”. No evidence was seen of a response by the landlord.
On 28 June 2022, the landlord’s records demonstrate that the resident’s insurers emailed to confirm that there was brown water saturation to the property which smelt and was causing a health and safety hazard. As the resident was five months pregnant, it advised she would require alternative accommodation whilst the reinstatement works were carried out.
On 28 June 2022, the resident contacted the landlord by phone and advised that;
1. her insurers informed her it would have to cancel an appointment booked for that day because the landlord had not carried out its own inspection of the drains
2. the walls were still damp and the drains are still blocked. This had been confirmed to her by a local water company
3. she had been advised to leave the property until the works were rectified
4. she had not had any communication from the landlord, and was very dissatisfied with how it had dealt with her complaint.
On 1 July 2022, the landlord contacted the resident to acknowledge her complaint and discuss it in further detail. The same day, it raised a job to further inspect the drainage, recording it as a “P1” priority. A drainage specialist attended on the same day.
On 5 July 2022, the resident contacted the landlord. She said;
1. she had received no response or acknowledgement to her complaint
2. no one had made contact with regards to when works would commence at the property. This was delaying repair works. The landlord was required to attend to inspect and insure no further issues were present, but it had not done this
3. she had been advised by her insurers that her property was unsafe to reside in, and she has had to move out. When she spoke to the landlord the previous week, she was assured that the issue had been escalated to senior management, yet no one had contacted her
4. her insurers had said that the works were likely to take three months or more. She said that living “out of a suitcase” was having a negative effect on her physical and mental wellbeing, and she was concerned about the effect on her unborn child
5. she had to attend A&E twice in the previous week because her eyes and skin were inflamed due to the stress, and the bacteria she had come into contact with from the leak. She had since been diagnosed with seborrheic dermatitis
6. she was 21 weeks pregnant, and the stress had “taken over her life”. She had not been able to take all of her belongings from the property, and had been financially impacted by having to pay for a property which she was unable to live in.
On 5 July 2022 the landlord issued its stage one response. It advised that:
1. the resident did not report that the water had been “gushing out” or that the leak was uncontainable, at the time of the incident
2. it attended within the 24 hour hours after the resident reported that there had been a leak at the property, and that this was within the expected timeframe for a leak of this nature
3. on 1 July 2022, the drains specialist attended the property and confirmed to the resident that the pipes had been cleared, and no follow up works were required
4. it would be writing to her neighbouring residents to remind them that any plaster or foreign objects should not be put through the drains
5. it would not be offering a refund of service charges for the period of time that the resident was staying away from her property whilst follow on works were being carried out by the resident’s insurer. The resident could ask her insurer to liaise with the landlord’s insurer regarding any liability claims
6. it apologised for the delay in responding to the resident’s complaint. It advised if she remained dissatisfied then she could escalate her complaint to the next stage.
On the 5 July 2022 the resident’s insurers asked the landlord what the status was with regards to its investigations into the drainage.
On 7 July 2022 the resident emailed the landlord and said that;
1. her complaint had not been dealt with correctly she said she had been left with no action taken to resolve the issues she was complaining about
2. she had not received confirmation in writing that the landlord had completed its investigations into the drains, and as a result, her insurance company were unable to commence works to repair the property
3. the member of staff dealing with her complaint had very little understanding of the severity of the issues, and appeared not to care what she had to say.
On 11 July 2022 the resident wrote to the landlord again to request an escalation of her complaint. She advised that with regards to the job notes about the leak that:
1. she had made it clear to the landlord that the water was “gushing out” and that it would have been clear that she was distressed by this, as she had been scared when she tried to stem the water flow
2. at the time of her reporting the issue, she was 19 weeks pregnant. She advised that whilst the call handler responded empathetically, she had to chase the landlord later in the day who advised they could not attend until around 8pm
3. she took the decision to appoint her own emergency plumber because she was scared and did not want to “wait hours” for the landlord to act
4. the plumber struggled to contain the water, to the extent he was there for several hours. The resident felt that the landlord had not taken this into account
5. she wanted £370 reimbursed to her for the plumbers visit as she felt that the landlord not acted in a timely manner, putting her at risk.
The resident advised she was dissatisfied by the landlord’s response to the drains being clear on the 1 July 2022. She said that:
1. nobody had contacted her on this date to inform her that the drains had been cleared
2. prior to this, on 28 June 2022, her building insurers attended to inspect the damage caused and advised that her property was “not safe for habitation”. They informed her that they were not satisfied that the drains were cleared, and she was advised to move out of the property immediately
3. she informed the landlord immediately of this concern, and was told the matter would be escalated to a manager to make contact, however nobody got back to her
4. the insurer also contacted the landlord the same day to ask for confirmation the drains had been cleared, but received no response and this had caused further delays to the repairs.
The resident said she was not happy that the landlord was not willing to consider a refund of her service charges. She said that the insurers had been trying to contact the landlord for several weeks without a response. This had delayed significant works to the property, and the situation was impacting her health and financial wellbeing.
The resident highlighted that the landlord had advised a letter would be sent to all residents however this had still not been done a month after the incident, which she felt highlighted that it had again failed to act in a timely manner.
In conclusion, the resident advised that she felt that the landlord had failed to provide a duty of care and had not followed its own complaint procedure. She advised that she had experienced a significant amount of inconvenience, caused by delays and lack of communication. She was also still unable to live in her home which was causing her significant distress as she was 22 weeks pregnant.
On 12 July 2022, the landlord emailed the resident’s insurers and confirmed that its drainage company had attended the property to check the blockage used CCTV on 1 July 2022. During this visit it was able to confirm that the blockage had cleared. As a result, works to the property could commence.
No record was seen of any further correspondence between the landlord and the resident about the issue, until the resident contacted the landlord again on 24 September 2022. She summarised the events that took place following the leak, and requested that the landlord apologise and reimburse her for the cost of the emergency plumber, and the insurance excess she had to pay.
On 5 October 2022, this Service wrote to the landlord and advised that it was required, in accordance with the Housing Ombudsman’s Complaint Handling Code (CHC) to respond to the resident’s request for an escalation to stage two of its process, by 19 October 2022.
On 6 October 2022, the landlord wrote to the resident to acknowledge her request to escalate her complaint.
On 19 October 2022, the landlord responded at stage two of its process. It advised the resident that:
1. on 13 July 2022, the landlord’s insurers responded to the resident’s insurers and advised that the blockage had been cleared and they were satisfied that the problem had been resolved. The resident’s insurers confirmed that as a result, the internal repairs could commence
2. in accordance with her lease, the resident was responsible for all interior repairs to the property and therefore the landlord would not be assisting with any outstanding repairs, redecoration or reimbursements as a result. It advised the resident to claim for these issues through her own insurer
3. if she remained dissatisfied she could contact the Ombudsman.
The same day, the resident responded to the landlord. She advised that:
1. she felt the landlord’s conclusion was flawed, and she did not accept it
2. she understood her responsibilities as a leaseholder in her home. However she is not responsible for the upkeep or maintenance of the communal areas, and it is the landlord who was responsible for maintaining the drains
3. the leak had not been an isolated incident, there had been previous issues affecting another neighbour
4. the landlord had failed to write to all the residents about flushing foreign substances in the six months after the incident
5. the property had been unhabitable for six months and she had to “uproot” her life whilst pregnant. This has caused her extreme stress, and affected her mentally, physically and financially
6. she would be escalating her complaint to the Ombudsman.
The resident informed this Service that:
1. the landlord’s response was unsympathetic and took no responsibility for the incident, which happened through no fault of her own
2. the initial call she received from the complaint handler from the landlord was rushed and it did not feel like they had properly investigated the matter
3. she was seeking an apology, financial compensation and reassurance that the landlord will correctly maintain the drains in future so that this does not happen again.

Assessment and findings

The landlord’s response to the resident’s reports of a leak in the property

The landlord was responsible for attending to the resident’s reports of a leak within an appropriate timeframe. It suitably recognised that the repair was urgent, and attended the property in approximately 9 hours, which was within the 24 hour timeframe for an emergency repair in accordance with its repair policy.
In its stage one response, the landlord advised that it was not aware that the water was uncontainable at the time that she first reported the repair. The resident disputes this. The Ombudsman is therefore unable to conclude whether the resident was clear that the water ingress into her home was significant.
However, the landlord’s repair records show that it was aware that faeces were present in the property, and that the resident was pregnant. This made her more vulnerable to the effects of a sewage leak, and caused her significant distress. There was no evidence that the landlord provided any reassurance about what she could do whilst she waited for its operatives to attend. The landlord failed to “think, respond and record” as referenced in its vulnerable residents policy, and made no service adjustments which considered whether it could attend the property within a quicker timeframe.
It was understandable that the resident contacted a private plumber to minimise the risk she was presented with, whilst she waited for the landlord to attend. Both the private plumber, and the operative of the landlord were able to confirm that the blockage was caused by other residents flushing fatty deposits down the drain. Whilst these actions caused the leak, it was not something that the landlord could have reasonably foreseen.
The lease agreement does not set out any specific obligations for the landlord to regularly inspect the drains. Its obligation under the terms of the lease was to respond to reports of disrepair, and it did so in this case. No evidence was seen which demonstrated that blocked drains was a recurring issue, or that the landlord fell short of its repair responsibilities.
Once it was established that the cause of the issue related to residents’ actions, it would have been appropriate for the landlord to have written to everyone in the block to warn them of the consequences of continuing to do this. The landlord recognised that this was an appropriate action within its complaint response. Despite reassuring the resident that a letter would be sent, no record of a warning letter has been seen. By not sending the letter, the landlord has not learnt from the outcomes and is risking the situation happen again. It has also failed in its commitment to the resident by not completing an agreed action as part of its complaint response.
The landlord’s records demonstrate that it attended the day following the leak to review the situation and concluded that the issue had been resolved. The attendance was prompt and in line with its repairs policy, but the resident had to call the landlord eight times that day to have the appointment confirmed. The landlord did not demonstrate that it had taken ownership of the repair and the amount of times she had to chase was unreasonable. Furthermore, once it did attend, the landlord did not communicate the outcome of the visit to the resident and she had to chase it again for an update.
When the resident emailed the landlord on 28 June 2022 to advise that she believed the drains were still blocked, a job was not raised until 1 July 2022, a further four working days. This was an unreasonable delay and outside of the expected timeframes within the landlord’s complaint policy. Once the repair was raised, it was flagged as a “P1 priority” and the landlord attended the same day. This demonstrated that the landlord appropriately considered the job to be an urgent priority. However it is of concern that there was a delay of four days in raising the repair, and no explanation has been given as to why this delay occurred.
It is not disputed that the resident was responsible for repairing the damage to the inside of her property through her insurance, as is specified in the lease agreement. The level of damage in her home was significant, to the point she had to decant from her property for a significant period of time whilst pregnant. This caused her great distress and it was therefore important that the landlord liaised closely with her insurers to allow for an efficient process to enable repairs to commence as soon as possible.
However it did not do this, and there were delays in the landlord communicating with the resident and her insurers. This hindered the ability to commence works within the property as soon as possible. Records show that both the resident and her insurers had to chase for confirmation that the CCTV drainage inspection had taken place. The resident was pregnant and stressed, having to leave her home at short notice. The delay in the landlord’s communication contributed to the resident’s distress in an uncertain time.
When investigating the complaint in accordance with 52(f) of the Scheme, the Ombudsman has considered whether the landlord treated the resident in an unsympathetic manner. In doing so, there was afinding of maladministration in the landlord’s handling of the resident’s report of a leak. Whilst it attended to the initial call out within the 24 hours specified in its repairs policy, it failed to show empathy and did not take into consideration the resident’s personal circumstances.
In the weeks following the incident, the landlord failed to communicate effectively with the resident and her insurers, and failed to follow through on assurances made in its complaint responses. In doing so, it failed to learn from outcomes and put things right for the resident.

Complaint handling

There were failures in the landlord’s complaint handling. The resident did not receive any acknowledgement to her complaint, and had to chase it for a response. A local councillor also asked the landlord for an update, however no response was seen until it contacted the resident on 1 July 2022 to discuss the matter further. This was five working days outside of when she could have expected an acknowledgement as per the landlord’s complaint policy.
A stage one response followed two working days outside of the timescale specified in its complaint policy, and the landlord appropriately apologised for the delay.
The landlord confirmed that the drains had been cleared and no further works from the landlord were required. It acknowledged that the leak had been caused by foreign substances being flushed down the sink by other residents, and appropriately offered to write to the residents to warn them of this. However it did not give any indication as to when the letter would be sent, and no evidence was seen that the letter was ever subsequently written.
The Ombudsman’s Complaint Handling Code (CHC) makes clear that any remedy offered must reflect the extent of any failures, and in making any commitments to the resident, it should not promise anything that cannot be delivered. There was a failure of the landlord to follow up on assurances given in its complaint response to write the letter and send it to residents in a timely manner.
The landlord’s response to the resident that she was not entitled to any refund of service charges for not staying in the property was correct, as per the conditions of the lease agreement. Whilst it was able to demonstrate that it had attended to the leak within the 24 hour timescale expected, it did not acknowledge the stress the resident had experienced. Its response lacked empathy and understanding of the resident’s frustrations, and it did not apologise for the inconvenience she experienced.
The resident made it clear that she was dissatisfied with the landlord’s response on 7 July 2022, however she did not receive a timely response to her request for an escalation. She had to chase the landlord a number of times for a response, to the extent that she contacted the Ombudsman. The Ombudsman had to intervene and a stage two response followed on 19 October 2022, 73 working days later and therefore significantly later than is set out in the landlord’s complaints policy.
Despite assuring the resident at the start of the stage two response that it would utilise the Ombudsman’s Dispute Resolution Principles – “Be fair, Put Things Right and Learn from Outcomes” as part of its review, there is limited evidence that the landlord did this. Its review summarised what had taken place up until the resident requested an escalation of her complaint, to the extent that it copied verbatim all of the stage one response, over several pages. This action was unnecessary and did not demonstrate that the landlord fully understood the resident’s request for an escalation.
Where the landlord had made no attempt to contact the resident to discuss or confirm her reasons for an escalation of her complaint, it was unable to respond to her effectively. Its response did not demonstrate that it had investigated the matter further or conducted its review independently. It failed to address all that the resident was expecting in terms of a resolution, and its response focussed solely on whether it felt the resident was entitled to any contribution towards her repairs. This was not the only resolution the resident was seeking, and by failing to address all the points that she raised, the landlord failed to appropriately conclude her complaint.
When putting things right for the resident, landlords are encouraged to acknowledge where things have gone wrong, provide an explanation and apologise where appropriate. Under the circumstances, the landlord was required to apologise for the significant delay in responding to the resident. Its response fell considerably outside of the timescales expected in line with its policy and the CHC. It is unreasonable that the landlord offered no apology for its delay in responding and did not acknowledge its complaint handling failures.
Overall there was maladministration in the handling of the resident’s complaint. The resident experienced significant delays and the landlord demonstrated a lack of empathy towards her by not engaging with her during the complaints process. Its stage two response failed to conduct an independent review, apologise or put things right for the resident.

Determination (decision)

In accordance with paragraph 54 of the Housing Ombudsman Scheme, there was maladministration by the landlord in respect of its response to the resident’s reports of a leak in the property.
In accordance with paragraph 54 of the Housing Ombudsman Scheme, there was maladministration by the landlord in respect of its complaint handling.

Reasons

The landlord failed to utilise its vulnerable residents policy and consider its principles of “think, respond, record”. It did not show empathy to the resident’s situation or recognise that she was more vulnerable to a sewage leak, given that she was pregnant at the time. Its delayed communication prolonged the resident’s insurers starting works to the inside of her property, causing her further inconvenience and distress at an uncertain time.
There were significant delays in the landlord’s complaint handling at stage two. Its final response lacked empathy and understanding for the inconvenience she had experienced. It also failed to put matters right or learn from outcomes where it did not demonstrate it had carried out the actions it had promised at stage one.

Orders and recommendations

Orders

Within four weeks of the date of this report, the landlord is ordered to:
1. write to the resident to apologise.
2. pay the resident £450 compromising:
  1. £250 for the distress and inconvenience caused in the handling of the resident’s report of a leak.
  2. £200 for the inconvenience, time and trouble caused by the landlord’s complaint handling.
3. write to all residents in the block to warn them of the consequences of flushing foreign substances down the sink, as referenced in its stage one complaint response.
4. conduct a review of this case, giving consideration to reviewing its complaint policy and any associated staff guidance to demonstrate learning from the outcome of this complaint. This review should be completed with reference to the Ombudsman’s Complaint Handling Code and must include:
  1. ensuring that all elements of a complaint are fully investigated
  2. ensuring that complaints are escalated in accordance with its policy and the Code
  3. ensuring that when engaging with residents, staff understand the individual circumstances of each complaint and are empathetic, even when a service failure is not found.
5. demonstrate how it will promote and retrain staff on its vulnerable residents policy and give consideration to adding pregnancy flags to its customer relationship management system.