A2Dominion Housing Group Limited (202010178)

REPORT

COMPLAINT 202010178

A2Dominion Homes Limited

30 June 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 the landlord’s handling of:
1. The resident’s reports of damp and mould.
2. Repairs to the plumbing in the property.
3. The resident’s requests for new storage heaters.
4. Window repairs.
5. The associated complaint.

Jurisdiction

What we can and cannot consider is called the Ombudsman’s jurisdiction. This is governed by the Housing Ombudsman Scheme. When a complaint is brought to the Ombudsman, we must consider all the circumstances of the case as there are sometimes reasons why a complaint will not be investigated.
After carefully considering all the evidence, in accordance with paragraph 42 of the Housing Ombudsman Scheme, the following aspect of the complaint is outside of the Ombudsman’s jurisdiction.
1. The landlords handling of the resident’s reports of damp and mould.
While the resident raised the issue with this service, there is no evidence that he made a formal complaint to the landlord about it. Accordingly, the landlord has not yet had the opportunity to respond to these issues and the matters are outside the Ombudsman’s jurisdiction under paragraph 42(a) of the Scheme which states ‘The Ombudsman cannot consider complaints that in the Ombudsman’s opinion are made prior to having exhausted a member’s complaints procedure, unless there is evidence of a complaint-handling failure and the Ombudsman is satisfied that the member has not taken action within a reasonable timescale.’

Background and summary of events

Background

The resident is a tenant of the landlord and the tenancy began on 25 August 2018. The resident lives in a one bedroom flat with a wet room, located on the third floor. The landlord states it has no recorded vulnerabilities for the resident or any members of his household.
Section 3.4 of the landlord’s repairs policy states when booking a repair, the landlord will assign one of two repair priorities. Urgent – with a response time of 24 hours and Standard – with a response time of the next available appointment that is convenient with the customer.
Section 4.3 of the landlord’s repairs policy states wherever possible it will provide all contractors with the necessary information needed to carry out the repair including any resident requirements.
The landlord’s repairs policy has a matrix of repairs it would be responsible for and timescales the repairs should be completed in. The policy states the timescales for repairs to dripping or leaking toilets, dripping or leaking taps, showers and containable leaks from pipework inside the home would be responded to as a standard priority. Uncontainable leaks and leaks from hot water cylinders would be classed as an urgent priority.
Section 8.1 of the landlord’s complaint procedure states it has a two stage complaint process. The complaints policy does not make it clear to the resident when they should expect a response from the landlord at either stage.
Section 11.1 and 11.2 of the landlord’s complaint policy states when an escalation to stage two is made the landlord will consider if the stage two is sent to a service director to review or a panel to review.
Section 11 of the landlord’s compensation policy states there may be circumstances where an offer of compensation may be offered. Its policy sets out the maximum awards of compensation it will pay.
The landlord was requested to provide evidence regarding repairs carried out at the property and in particular, in relation to any window and storage heater repairs at the residents property. The landlord has not responded to this request so this report will focus on the evidence provided from correspondence between the resident and the landlord plus internal landlord communications.

Scope of the Investigation

The resident in his complaint has informed this Service that the defects to the windows have been ongoing for several years and that this has been reported to the landlord. The Housing Ombudsman Scheme states that the Ombudsman will not investigate complaints which, in the Ombudsman’s opinion, were not brought to the attention of the landlord as a formal complaint within a reasonable period, which would normally be six months of the matters arising. There is no evidence that any formal complaints raised by the resident about the defects to the windows have previously either exhausted the landlord’s complaint process and/or that any such complaint was referred to the Ombudsman at the time.
This investigation report will therefore consider events from 2020 onwards on the basis of what the Ombudsman considers to be a reasonable period in light of the provisions of the Housing Ombudsman Scheme and considering the available evidence of repair reports and communication with the resident until the final complaint response in September 2021. Any reference to events relating to earlier than 2020 are for context only.

Summary of Events

On 26 September 2018, the landlord raised a repair order stating the windows in the lounge and bedroom were blown in. It is not clear from the landlord’s records how many windows these repairs were for. The landlord’s contractor visited the property on 7 November 2018 and ordered materials required to complete the window repairs. The landlord’s contractor attended the property on 6 December 2018 and states it inspected windows in the lounge, kitchen and the bedroom and carried out repairs.
A request was made on 18 December 2018 by the landlord’s contractor for an appointment to assess the lounge and bedroom heaters as these were not working. The contractor also stated a new air vent on the bedroom window and handle on the kitchen windows were still required. On 28 December 2018 the landlord requested for an electrician to attend to check the storage heaters. The landlord’s records state the contractor visited the resident’s property on 7 February 2019 and reset the thermostat on the heaters.
On 23 September 2020 the landlords records show it logged a repair for a leak that was from a pipe connected to the back of a toilet and the leak could not be contained. Its records show an operative attended on 23 September 2020 but no notes of the visit were available. The landlord called the resident on 29 September 2020 and confirmed the job was completed.
The resident wrote to the landlord on 8 December 2020 following a visit by the landlord’s contractor. The resident stated the landlord’s contractor had visited the property that day to fix the shower and gulper unit in the property. The resident says he was told by the contractor he was unable to complete the required works as he was a mixed tradesman and did not sort out electric showers and plumbing. The contractor had looked at the taps and concluded they needed replacing but he could not do those either as he was sent to work on the shower only. The resident stated the contractor said it would have helped if the landlord’s customer service centre had listed more detail about the required works. The contractor raised an urgent repair for the shower works to be rebooked. The resident stated he was frustrated at the landlord sending tradesmen to his property not able to complete the works. The resident told the landlord he was unable to shower or wash again which had been the case for some time.
On the same day the resident sent a formal complaint to the landlord. The resident stated:
1. The windows in his property were poor as they did not seal or shut properly, they were very loose and hollow around the window edges due to being wooden frames and air was going into the property very easily.
2. The waterpipes in the building block had recently been replaced and the pipework had been plumbed the wrong way into the systems in his flat resulting in an incorrect flow of water which was not adequate to have a shower. This had been ongoing for two months.
3. The toilet system in the property kept leaking and was being fixed by applying silicone which only lasted temporarily. As the toilet pipework system was boxed in, access to it resulted in cosmetic damage. The toilet system and shower did not flow properly due to the same pipework issues.
4. The storage heaters in the property were very old and he did not use them because of the high cost of running them. The resident stated he had no reviews of the heating system since he had moved into the property.
On the same day, the resident also wrote to his Council and MP about the landlord and sent a copy to the landlord. The resident stated he had made a complaint previously in 2019 and although that complaint was over one year old he did not consider it closed and wanted to make the Council, MP and landlord aware he considered this to be a continuation of the previous complaint.
On 11 December 2020 the landlord wrote to the resident and acknowledged the complaint had been received and stated a response would be issued within 10 working days.
The landlord raised a repair request on 14 December 2020 for low water pressure in the cold water tap in the bathroom and for replacement of taps in the kitchen and bathroom. The repairs were completed on 23 December 2020.
On 18 January 2021 the resident wrote to the landlord and stated he had written to the landlord on 8 December 2020 and had not had a response from it. The resident stated to the landlord the windows were still an issue and that he had an unannounced visit from a contractor to measure the windows but he was not aware they were visiting the property and they had no identification. He advised that he asked for the visit to be rebooked, as he was working from home at the time, but said he had not been contacted since.
On 27 January 2021 the landlord issued its stage one complaint response. In the response the landlord stated:
1. A repair was raised on 12 November 2020 as there was low cold water pressure in the bathroom making it difficult to use the shower. Its operative attended on 3 December 2020 and due to the nature of the repairs it needed to be passed to the landlord’s subcontractors.
2. The subcontractors attended on 8 December 2020 and concluded the waste pressure was ok but the shower and taps were at fault which were replaced on 10 December 2020. The landlord apologised for the resident being left without access to the shower for two months.
3. A benchmark representative attended the resident’s property on 18 December 2020 to carry out a kitchen and bathroom survey and stated the kitchen and bathroom was on the next planned upgrade programme.
4. Its cyclical works team advised the works to the pipework, distribution and pumps at the property were being investigated.
5. The windows were due to be replaced as part of its cyclical upgrades programme.
6. Its records indicated the storage heaters issue had not been raised with the service area prior to the complaint being made and was not a service failure. The issues would need to be raised as a repair or service request through its contact centre.
7. The landlord offered the resident £100 in compensation for the time and trouble pursuing the matters and £50 for poor communication by the landlord.
8. It committed to completing any outstanding repairs relating to the complaint by 25 February 2021.
9. The landlord stated its staff had received further training in relation to record keeping as a result of the complaint.
The resident responded to the landlord on the same day and stated:
1. The water pressure issues were present in September 2020 following changes in the pipework and he was at the time told by the landlord’s contractor to allow time for the pressure to build up. The resident gave the pressure time to build up but stated he reported the issue on 12 November 2020 after no change and it took the landlords contractor until 3 December 2020 to attend the property.
2. The taps had been due to be fixed on 4 December 2020 but no one attended from the landlord and after contacting the landlord, he was advised that due to a communication error it would be 7 December 2020. However, on 7 December 2020 no contractor turned up. The resident spoke to a contractor on site working on another property and asked if his property was to be done and was told no. The contractor he spoke to agreed to visit the next day and look at the taps. On inspection the next day, the contractor concluded the taps were not affecting the water issue and that the blockage likely caused was scrap pieces getting into the pipework when it was changed in September 2020. The contractor also informed the resident the tundish on the water tank had failed.
3. After informing the contractor the electric shower, the water pump and the taps in the kitchen or bathroom were not working the resident was advised by the contractor to log emergency repair requests which he did and was given three separate job numbers for plumbing work, water pumps and the shower.
4. A multi skilled plumber was sent to do the works the next day on the shower and taps however on arrival told the resident he could not do the works on the shower as he was not a qualified electrician and did not have the taps in his van.
5. An electrician arrived on 10 December 2020 to complete the works on the shower but was told the landlord was trying to put off replacing the shower for further inspection to be carried out. Following more discussions between the resident, landlord and contractor the shower was replaced.
6. On the same day three senior persons for the landlord arrived and were happy the shower was replaced and promised the taps and tundish would be replaced the next day. No further contact was had from the landlord until the resident chased the landlord on 21 December 2020. At the same time, he advised the landlord there was a leak from the sink after it was taken apart to test the pressure.
7. On 22 December 2020 the resident was contacted for a supervisor to inspect the taps which he stated would have been for a sixth time and refused the inspection and stated he wanted them replaced as replacements had already been agreed on 10 December 2020.
8. The taps were replaced on 24 December 2020 and the leak from the sink was repaired at the same time.
9. The tundish had been replaced on 20 January 2021.
10. On 21 January 2021 the resident was informed that the kitchen was due to be replaced in 2030 and bathroom in 2041 as they were in good condition or too young. He was shocked to hear that given the number of repairs he had needed in the two and half years he had lived at the property.
11. He disputed the storage heaters as not being service failures as he was raising the age, energy efficiency, costs to run them and the possibility they contained asbestos as advised by the landlord’s contractor. He stated nothing had been done with the storage heaters since he moved in and was not aware of any service records or reports on the condition or safety of them. His complaint was about the concerns mentioned. He was told in a response to his MP that the landlord was instructing the planned works team to review the performance of the heaters and make a decision as to whether they should have been replaced. A copy of this response has not been seen by this service.
12. The complaint about the windows was the same as the storage heaters in regards to safety and efficiency causing cold nights and escape of heat adding to heating costs. He was aware the landlord planned to start replacing windows in March 2021.
13. Requested he was moved to another property.
On 2 March 2021 the landlords contractors attended the resident’s property to repair a leak from the back of the toilet. It was recommended by the contractor that the toilet be removed completely, and all new rubbers be fitted as they looked very worn. A new toilet was installed on 5 March 2021.
On 17 March 2021 the resident informed this Service that the complaint was still open, and he had not had a response from the landlord since January 2021.
On 15 July 2021 the resident contacted the landlord to report an uncontainable leak was coming from the hot water tank. The landlords contractor attended the same day and stated the job required an unvented plumber as the contractor was not qualified to touch the tank or the pipework.
On 28 July 2021 the landlords records show the tundish, pressure valve and inlet valve were replaced. The repair notes state the contractor could not test the hot water as it wasn’t up to pressure.
The landlord issued its stage two response on 1 September 2021. In the response the landlord stated a member of its staff had been in touch with the resident and stated:
1. The issues around the bathroom had been corrected and there were no outstanding issues.
2. The windows were being replaced in October / November 2021.
3. Storage heater replacement was not an option at that time but would be looked at for future works.
4. Offered the resident an additional £50 compensation for poor communication while the repairs were in process.
The resident responded to the landlord on 6 September 2021. The resident said the landlord had shown lack of empathy and acknowledgement in its response and the level of compensation offered did not reflect the length of time the repair issues were outstanding and the poor communication from the landlord during this time.
The landlord responded the same day to apologise that the resident felt the response was generic and assured the resident the content of the reply was written with a focus on his circumstances. The landlord stated it had offered the maximum compensation it was able to do under its compensation policy for detriment and communication failure but did offer an additional £75 for poor repairs on the pipework at the resident’s property bringing the total offer of compensation to £275.

Post Complaint

On 9 December 2021 the resident informed this service the landlord had replaced the windows in his lounge and bedroom and would be replacing the windows in the kitchen and bathroom in early 2022.
On 17 May 2022 following contact being made with this service the landlord contacted the resident. The landlord stated it had reviewed the resident’s complaint and offered an increase in compensation. It increased the offer to £450 consisting of £150 for length of time, £100.00 for poor communication, £100 for complaint response delays and £100 for stress and inconvenience.

Assessment and findings

The landlord’s handling of repairs to the plumbing in the property

This investigation has had to rely on the information provided by the resident regarding certain repairs, as the landlord has not provided copies of its repair logs in relation to the shower and pipework issues between September 2020 and December 2020 although it does refer to these works in its complaint responses.
From the correspondence between the resident and landlord and the complaint responses issued by the landlord it is clear the pipework was changed in September 2020 and following this the resident reported there was water pressure issues at the property. The resident states he was told by the contractor in September 2020 to wait for the pressure to build up due to further refurbishment works being completed within the accommodation. It is not clear how long the resident was told to expect to wait for the pressure to build. The resident waited until 12 November 2020 and reported the issue to the landlord. The landlord took three weeks, until 3 December 2020 to visit but the contractor, the landlord accepts, was unable to complete the works and it passed the works to subcontractors. The landlord has not provided any repair logs relating to this repair so this Service is unable to verify any of the actions taken by the landlord or its contractors.
The resident states he was told a contractor would visit on 4 December 2020 and 7 December 2020 and no contractor from the landlord arrived on either date. There is no evidence the landlord informed the resident the contractors would not be attending. A contractor did arrive on 8 December 2020 and following an inspection was unable to complete the works requiring a further visit on 10 December 2020 when the shower was replaced. This meant the resident had at least five appointments within a month that resulted in either a contractor not arriving at the property or being unable to complete the works required. The taps were replaced on 24 Dec 2020 and the tundish on 20 January 2021
From the time the repairs were requested on 12 November 2020 the landlord took 29 days to replace the shower, 43 days to replace the taps and 43 days to replace the tundish. It is noted however the resident states he was advised in September to wait to report the water pressure issues which resulted in a longer delay for the repairs to be completed.
The landlord’s repairs policy does not state what timescale a standard repair should be completed in. Section 3.4 of its repairs policy states the next available appointment that is convenient with the customer. This Service would suggest that an acceptable period of time for a standard repair would be 28 days. Although the shower was replaced close to this, it is noted the shower was the residents only means of washing due to the property having a wet room. The repairs to the taps and tundish are not considered to have been repaired within a reasonable timescale.
The information provided to this Service in the form of the resident’s accounts and the landlord emails, confirm the resident was visited on repeated occasions for inspections to take place on the same repair issues. The resident and landlord records also show the resident was visited by contractors who were either not qualified to complete the required works or had not been given enough information by the landlord to be prepared for the works required. The resident would have been understandably upset that his requests for repairs were delayed in being completed because of this. The landlord not having a stated timescales for repairs in its repairs policy means it is difficult for residents to understand when repairs are expected to be completed by the landlord.
The landlord should keep clear records of the information provided by the resident when a repair is reported. The landlord should have records and notes from either its previous visits to the property and / or of the reported repair to be completed to limit the need for repeated visits to the property. It is understandable that the resident would feel frustrated with being told to have contractors visit his property for inspections when previous inspections have not been acted on.
The residents accommodation has a wet room, this would mean the shower is the only facility the resident can use to wash. The landlord does acknowledge it left the resident without a fully functioning shower for two months. The landlord has not provided evidence in this case that it considered the resident’s situation at the time the repairs were requested or offered any further support to the resident.
When the stage one complaint response was issued the resident was offered £150 compensation for the delays he experienced which was increased to £200 in the stage two response. The landlord, reviewed the compensation offered by it in its stage two response and offered an additional £75 for poor quality of work. The landlord stated this was for the pipework issue but does not elaborate any further.
Given the number of repairs visits to the resident which resulted in work not being able to be completed and the length of time the resident was unable to shower (around two months) the offer of £275 is not considered to be appropriate.
After the complaint had been received by this Service, the landlord did conduct a review of the complaint in May 2022. It stated this was done to review if it needed to engage with the resident to resolve the issues without need for a formal investigation. The landlord increased the total offer of compensation to the resident to £450. The landlords offer included £100 for its complaint handling leaving a remaining amount of £350. This amount is not sufficient to cover the delays, failed visits and period of time without adequate washing facilities. An amount of £450 for the landlords handling of plumbing repairs at the property is considered appropriate.

The landlords handling of the requests for new storage heaters

The resident has complained about the landlord refusing to repair or replace the storage heaters at the property. The records provided by the landlord show an appointment was raised with the landlord in December 2018 as the storage heaters were reported as not working and the landlord’s contractor visited the property in February 2019 to reset the thermostats. However no further evidence has been provided that issues with the storage heaters were raised any further by the resident to the landlord until the complaint made by the resident in December 2020.
The landlord when made aware of the resident’s concerns in his complaint in December 2020, stated in its stage one response the resident had not raised it as a service issue and to do so if he wished for the storage heaters to be looked at. When the resident made the request to escalate the complaint, he informed the landlord he had concerns regarding asbestos in the heaters and that he had not seen the landlord carry out safety checks in the time he had lived at the property. The complaint made the landlord aware the resident had concerns about the heaters and it could have assisted the resident in progressing a repair or service request. In the stage two response the landlord stated the heaters were not scheduled to be replaced at that time. The landlord has not evidenced it took any action to investigate if the heaters were in working order, if they needed to be replaced or had conducted any safety or maintenance checks.
Although the landlord states the issues had not been raised prior to the complaint and could not be considered in its complaint response, the landlord had the opportunity to act on the resident’s concerns. It could have offered to review the history of checks carried out on the heaters and if required, carry out an inspection to ascertain the condition of the heaters. Instead, it put the onus on the resident to make a further service request. The landlord should have done more to support the resident once it was aware of his concerns.

The landlord’s handling of window repairs

The resident reported repairs to the windows in December 2018 that were completed the same month. There are no other records of the resident reporting window repairs until the complaint made in December 2020. The landlord in the stage one response stated the windows were due to be replaced as part of a cyclical works programme. The landlord did not show it considered the reports made by the resident in the stage two escalation request that they were potentially not safe. In the stage two response the landlord acknowledged the resident felt the windows were damaged and unsafe but repeated that the windows would be replaced later that year. As with the storage heaters, it did not evidence it had taken any action to consider the resident’s concerns about safety or, to see whether any repairs were required to the windows in the interim before the replacements were carried out.

The landlords handling of the complaint

The resident made the complaint to the landlord on 8 December 2020. The landlord provided its stage one response on 27 January 2021. This was 34 working days later and 24 working days longer than the timescales in its complaint policy.
The resident requested the complaint be escalated to stage to on 27 January 2021. No acknowledgment or contact was received from the landlord regarding the complaint and the resident contacted this Service in May 2021. The landlord issued the stage two response on 1 September 2021. This was 151 working days after the escalation request was made. Although the landlord does not state in its complaints policy how many working days it would respond within, this Services complaint handling code states a response at stage two must be issued within 20 working days. The landlords response time of 151 working days is significantly beyond this timescale.
In the stage two response no explanation was given to the resident for the delay in issuing the response. It failed to apologise to the resident for the delay.
The resident in his response to the stage two response stated he felt the response was generic. The stage two response in particular did not go into any detail regarding the investigations the landlord had made or outcomes it had determined. The landlord in its stage one and two responses included a paragraph stating its staff would be trained. It is noted the wording use in both responses was very similar and this would not have helped reassure the resident his complaint was being considered on an individual basis.
When responding to the complaint it is important each response to the resident is specific to the individual complaint. The use of standard paragraphs may not give the resident confidence their complaint was being investigated on a personal level.
The landlord stated it could only offer up to a maximum amount of compensation under its compensation policy. The compensation policy does state the maximum amounts it will pay for time and trouble or stress and inconvenience and these are each capped. The landlord needs to consider each individual complaint point and make a determination without restriction on the level of compensation it can offer. This ensures the complaint is investigated fully and if appropriate the resident be appropriately compensated.
The landlords complaint policy does not provide timescales that the resident should expect for their complaint to be issued with a response. This is not compliant with this Services complaint handling code which states a stage one complaint should be issued within ten working days and at stage two within 20 working days. It is noted the landlords website does state it will aim to provide a response to a complaint within 10 working days but fails to state at what stage(s) this relates to. The landlord has issued its response significantly above these timescales. There is no evidence the landlord kept the resident informed of any delays during the complaint’s process and did not offer any apology or explanation to the resident for the delays in either of its complaint responses.
The landlord’s decision to review the complaint in May 2022 demonstrates its willingness to learn from the complaint. However this was eight months after the original complaint had completed its internal complaint process. The offering of compensation for stress and inconvenience and complaint response delays which it had not offered compensation for in either of its original complaint responses indicate it had not fully considered these at the time of the original complaint.
The landlord offered £100 in compensation for its complaint handling. This is considered an appropriate offer of compensation given the delays the resident incurred especially at stage two of the response and the lack of an apology to the resident for the delays.
This Service acknowledges that the landlord following a review of the complaint increased its offer of compensation to £450. However the landlord’s actions regarding the repairs and complaint handling are still considered to be maladministration as it took the landlord eight months after issuing its final complaint response to offer this to the resident so cannot be considered an offer of reasonable redress.

Determination (decision)

In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration in the landlord’s handling of the plumbing repairs at the property.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was service failure in the landlord’s handling of the request to replace the storage heaters.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was service failure in the landlord’s handling of the window repairs.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration in the landlord’s handling of the complaint.

Reasons

The landlord, on repeated occasions, sent contractors who were either unable to carry out the required works or, were not informed of the works required. This resulted in delays to the residents repairs being completed. The resident was left without adequate washing facilities for a two month period.
The landlord failed to act on the information it received in the complaint about the resident’s safety concerns about the storage heaters.
The landlord failed to act on the information it received in the complaint about the resident’s safety concerns about the windows.
There was a delay in the issuing off the stage one response and significant delay in issuing the stage two response. In both responses the landlord failed to apologise for the delay or offer an explanation for the delays.

Orders and recommendations

Orders

Within four weeks of the date of this report the landlord is to pay the resident £750. This includes the £450 offered by the landlord. This consists of:
1. £450 for the delays in repairs.
2. £100 for handling of the reports about the storage heaters.
3. £100 for the handling of the reports about the windows.
4. £100 for the handling of the complaint.
If the landlord has already paid the resident the £450 it offered, this is to be deducted from the £750 awarded.
The landlord is to undertake a full inspection of the storage heaters in the property to ensure they are in safe working order and arrange for repair or replacement if necessary.

Recommendations

That the landlord takes steps to ensure contractors report back any advice given at repairs visits to minimise the risk of contradictory information being given to residents and repeated visits being required.
Review its complaints policy to insure it is compliant with this Services Complaint Handling Code.