Accent Housing Limited (202006312)

REPORT

COMPLAINT 202006312

Accent Housing Limited

22 November 2021

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 allegations of non-compliance with policies set out by the Department for Levelling Up, Housing and Communities (DLUHC) and the Regulator of Social Housing (RSH), as well as guidance from HouseMark.
2. The process by which the landlord calculated its service charge and its suggestion that the service charge costs are fixed.
3. The alleged introduction of new services without proper tenant consultation.
4. The landlord’s decision to charge residents for the maintenance of communal lights.
The Ombudsman has also considered the landlord’s handling of the resident’s complaint.

Background and summary of events

Background

The resident has been an Assured Non-Shorthold tenant, in respect of the property, since 9 August 2006.
The property is a one-bedroom flat located on the ground floor.
As part of the resident’s complaint, he has made reference to a document produced by HouseMark entitled “Managing Your Service Charges Effectively” and published in 2013. HouseMark is a provider of performance improvement and value for money solutions, jointly owned by the Chartered Institute of Housing (CIH) and the National Housing Federation (NHF).
Following an earlier complaint about an increase in the level of service charge, and a request for information relating to the service charge costs, this Service assessed the resident’s complaint on 9 October 2017 under reference 201702371.
While it was determined that the resident’s dissatisfaction with the level of service charge was outside of this Service’s jurisdiction, consideration was given to the resident’s dissatisfaction that the landlord had not provided him with proof of the service charge costs. Through back-and-forth intervention, this Service was able to arrange for the landlord to share this. The investigation was therefore closed as the landlord had satisfactorily resolved the matter and the resident had confirmed for this Service that this resolved his complaint.
The Ombudsman notes, from the landlord’s final response at this time however, that the landlord explained to the resident that a fixed service charge regime was in place. This meant that the landlord estimated the cost of providing services at the beginning of each financial year, and subsequently all tenants paid a fixed charge throughout this time until the budget was reconsidered for the next financial year. The landlord explained that this differed from variable service charges.

Scope

Despite the evidence seen, the resident has explained to this Service on several occasions that his complaint does not concern the level of service charge increase, but rather the landlord’s considerations in arriving at its new budget. This distinction is important as under paragraph 39(g) of the Housing Ombudsman Scheme, the Ombudsman will not investigate complaints which concern the level of rent or service charge, or the amount of the rent or service charge increase. This report will make no comments in regard to the level (or percentages, as set out by the resident) of increase. Should the resident seek to challenge the reasonableness of the amount requested by the landlord, he will therefore need to obtain independent advice or may wish to pursue this via the First Tier Tribunal (FTT).
Additionally, while the resident has raised with this Service that the landlord failed to act in accordance with the policies set out by the DLUHC (formerly known as the Ministry of Housing, Communities and Local Government) and RSH, this Service is unable to comment on whether a breach had occurred. Rather, this investigation will look at the landlord’s actions in response to the resident and whether an appropriate and reasonable explanation was given to the resident to satisfy that it was acting appropriately.

Legal and Policy Framework

Policy Statement on Rents for Social Housing

As part of the resident’s complaint, he asserted that the landlord had failed to comply with sections 2.35, 2.36 and 2.37 of the Policy Statement on Rents for Social Housing, published by the DLUHC. The Ombudsman has noted these sections below for context:

S.2.35

“Registered providers are expected to set reasonable and transparent service charges which reflect the service being provided to tenants. Tenants should be supplied with clear information on how service charges are set. In the case of social rent properties, providers are expected to identify service charges separately from the rent charge”.

S.2.36

“Service charges are not governed by the same factors as rent. However, registered providers should endeavour to keep increases for service charges within the limit on rent changes, of CPI + 1 percentage point, to help keep charges affordable”.

S.2.37

“Where new or extended services are introduced, and an additional charge may need to be made, registered providers should consult with tenants”.

The Rent Standard – April 2020

The resident also made mention to section 3.1 of the Rent Standard which details the specific expectations for social landlords. This explains that “Registered providers must comply in full with all the requirements and expectations set out in this Rent Standard. They must additionally comply with all the requirements and expectations of the Rent Policy Statement on the setting, increase and decrease of rents and service charges”.

Summary of events

On 20 February 2020 the resident contacted the landlord to establish whether it had noted his concerns regarding the increased service charges for the following year.
Following a further prompt from the resident, the landlord confirmed for him on 26 February 2020 that it would seek to offer a reply by the end of the week. It apologised for the delay.
In further correspondence on the same day, the resident explained that he had hoped that the landlord would amend the service charge to a more realistic amount, as there had been a significant increase in charges from the previous year. The resident set out the proposed increases as a percentage for the landlord.
On 2 March 2020 the landlord wrote to the resident. It acknowledged that the overall service charge had increased notably and explained that this was as it had identified more costs. The landlord explained:
1. Costs for ground maintenance, cleaning, and window cleaning had been increased in accordance with their contracts.
2. Costs for tree management had been reduced as a programme of tree works was being set up and there was not as many trees as was once thought.
3. Costs for fire safety had increased due to the need to meet increasing demands. The number of call outs in the previous year (to reset alarms) had increased.
4. TV costs (such as aerial equipment) had increased as in 2019/20 the landlord had spent £450 on aerial repairs. It now sought to recover this amount.
5. Costs for sundry expenses had increased as £500 had been spent in the first half year and, in 2018/19, £751 was spent but not recovered.
6. Costs for communal electricity had increased based on previous use and potential cost increases.
7. There were costs for rubbish clearance and skip hire. £82 had been spent on this in the first half of 2019/20 but without having a budget.
On 21 May 2020 the resident wrote to the landlord. He expressed that the costings for the lighting did not reflect value for money. He requested the NHF Schedule of Rates (SoR) as he found the costings to be unreasonable.
The landlord acknowledged the resident’s correspondence on the same day and advised that it would come back to the resident to provide a response.
With no further update by 8 June 2020 however, the resident chased the landlord. He acknowledged that the landlord had engaged in dialogue with him (although the Ombudsman has not seen records of this), but expressed that he was clearly still unhappy with its response. He requested that the landlord make it clear whether it could resolve his concerns so that next steps could be considered.
The landlord responded to the resident on the same day. It apologised for the delay but advised that it believed it had responded to the vast majority of the resident’s queries. The resident was asked to outline the concerns that remained unanswered.
The resident subsequently explained (still on the same day):
1. He believed that the service charge was unreasonable, especially with regards to sundry expenses and TV costs.
2. While he had been advised that the service charge was fixed, his tenancy agreement explained “the term rent refers to the sum of the net rent and service charge set out above or as varied from time to time in accordance with this agreement”. This did not suggest that the service charge was fixed, and the charges varied from year to year.
3. The tenancy agreement stated a right to consultation for charges likely to have a substantial effect on tenants.
4. He did not understand why the landlord did not need to comply with the RSH on service charges.
On 9 June 2020 the landlord wrote to the resident. It explained:
1. Sundry and TV costs were based on either known expenditure and by reviewing the historic costs. Budgets were reviewed year on year to take into account reducing or increasing costs.
2. In respect of the fixed/variable charges, it had explained this on the phone, and in previous years. A fixed service charge regime was operated but this did not mean that the charges never changed. It meant that the service charge was fixed for the year it was set. Where the budget for the year was set above the actual cost, a refund was not given, however conversely where it was set below the actual cost, there was no additional charge. This was why it was important to seek value for money.
3. It did comply with the regulatory standards surrounding service charges.
On 12 June 2020 the landlord wrote to the resident and advised that as it had responded to the outstanding queries, it did not propose to engage in further discussions on the matter. It therefore sought to “draw a line under…[the]…matter”.
Following receipt of further correspondence from the resident however (which this Service has not seen), on 19 June 2020 the landlord advised that it would address his outstanding queries in one wrap up email. It advised:
1. The budget for the sundry and TV costs was based on previous years spend, not on previous years estimates. These amounts were what was paid to the relevant contractor. While it had not included some charges in previous years or charged significantly less (as was the case in 2018/19), equipment had still been maintained and the additional costs to itself had not been passed on. The resident had therefore benefited from the low costs. It highlighted that the new cost for sundry expenses was less than £3 a month for the resident and less than £2 a month for the TV aerial. These were not considered to be unreasonable estimates.
2. The budget for fire safety had increased by approximately £100, and the charge to the resident was in the region of £3.50 per month. It explained that it needed to focus on fire safety to ensure that testing regimes met the legal and regulatory requirements. It did not consider this new cost to be unreasonable.
3. While it was required to consult the resident about new services likely to have a substantial effect, pest control and skip hire were not new services. Skip hire / rubbish removal was £5 a year for the resident and pest control was dealt with under the sundry expenses. This cost was not unreasonable.
4. Costs for communal lights could vary for a number or reasons, such as location, whether a repair was required, or a replacement needed. Costs were based on an agreed SoR and were therefore in accordance with this.

The landlord concluded that as it had responded to all of the resident’s outstanding concerns, it did not propose to engage in any further discussions on the matter.

As it was unclear whether a stage two response had been provided to the resident under the landlord’s complaints process, this Service advised the landlord on 18 January 2021 to provide the resident with a final response. The landlord subsequently contacted the resident on 19 January 2021 requesting that he set out his outstanding concerns.
On 20 January 2021 the resident set out that in order to resolve his complaint, he required the landlord to:
1. Comply with the DLUHC on its “Policy Statement on Rents for Social Housing”, particularly sections 2.35, 2.36, and 2.37.
2. Comply with the RSH’s Rent Standard (April 2020), particularly section 3.1.
3. Acknowledge that the service charges were not fixed, as they varied each year.
4. Refrain from attempting to recover costs from previous years while calling the charges fixed.
5. Accept that the tenancy agreement stated that charges would be varied and not fixed.
6. Supply the NHF schedule of rates to demonstrate value for money.
7. Comply with the guidance issued by HouseMark, which stated the rules and best practice on service charges.
8. Refrain from introducing new services without consultation.
9. Accept responsibility for the communal lighting as per the tenancy agreement.
10. Produce the TV aerial, call out and light units replacement costs from NHF schedule of rates.
On 26 January 2021 the landlord wrote to the resident with its final response. It explained:
1. In respect of section 2.35 of the Policy Statement on Rents for Social Housing, it believed that it set reasonable and transparent service charges. The budget set every year reflected both known and historical costs, enabling it to set budgets most accurately. It had also reviewed how service charges were set out and the resident had been issued with a booklet which identified service charges separately from the rent (which the Ombudsman has seen).
2. In respect of section 2.36 of the Policy Statement on Rents for Social Housing, it did try to keep the service charges as low as possible. It understood that the resident was frustrated with the service charge increase of approximately 20%, but explained that this was done after its review had identified that it had not been historically charging for a number of services (such as pest control and rubbish removal) which were being provided.
3. In respect of section 2.37 of the Policy Statement on Rents for Social Housing, it had not introduced any new services. Rather, it had carried out a review of services and identified several which it had been providing but not charging for. Charges were subsequently introduced accordingly. The landlord accepted that it should have communicated this to residents, to provide clarity when the new service charge budget was provided. It therefore apologised for this.
4. With regards to compliance with the RSH, it considered that it complied with the Rent Standard. This had already been discussed with the resident and would not be commented on again.
5. Its policy on service charges outlined its approach towards the fixed/variable costing regime. It accepted that the wording could be confusing and advised that it would look at rewording this. It reiterated, however, that the service charge costs within the year did not change.
6. While it did not seek to recover costs from previous years, it did review costs in order to set appropriate budgets for upcoming years.
7. Upon reviewing the resident’s tenancy agreement, it found that the agreement was silent on the issue of how service charges were set. There was no reference to whether the charges were fixed or variable. Given the challenges, however, it had added an explanation of fixed charges to its booklet for rented customers and a copy of this would be provided.
8. It apologised that the SoR had not previously been shared and attached it to its final response.
9. While the HouseMark document was an old document (published in 2013), it advised that there was no “one size fits all approach to setting and making service charges”. The landlord explained that this also held no regulatory weight, however it was still satisfied that it had complied with the spirit, if not the letter, of the guidance.
10. Within the same HouseMark document, it was highlighted that “subject to the lease or tenancy agreement, service charges for both tenants and leaseholders may include items such as cleaning and lighting of common parts”. Its approach was therefore in accordance with this.
11. It was unclear on the information the resident was requesting, in respect of the TV aerial, call out, and light unit replacement costs. It had shared invoices previously (and could provide copies if required). It signposted the relevant areas of the SoR document for the resident’s analysis nonetheless and highlighted that the costs may not be the actual costs paid due to the individual adjustments applied to contracts.

The landlord concluded that as a gesture of goodwill and given the fact that the service charge had significantly increased from the previous year, £500 would be allocated to carry out estate improvements.

Assessment and findings

The landlord’s response to the resident’s allegations of non-compliance with policies set out by the Department for Levelling Up, Housing and Communities (DLUHC) and the Regulator of Social Housing (RSH), as well as guidance from HouseMark.

As stated above, it is beyond the remit of this Service to determine whether a breach of the policies set out by the DLUHC or the RSH occurred. The Ombudsman has, however, considered whether the landlord offered the resident a fair response following the resident’s allegations of non-compliance, and in the Ombudsman’s opinion, it did.
It was appropriate that within the landlord’s final response, it offered an explanation specific to each section of the DLUHC’s policy which it had allegedly failed to comply with, and demonstrated how its actions aligned with the expected practice.
In respect of section 2.35 of the Policy Statement on Rents and Social Housing, the landlord highlighted for the resident why it considered the service charges to be reasonable, and reminded the resident that the service charges were set out separately from the rent within the “Important information about your new rent and annual service charges” booklet.
The landlord acknowledged the resident’s disappointment with the level of increase in service charge, in respect of section 2.36, and offered an explanation for why this had occurred on this occasion. The Ombudsman cannot comment on the reasonableness of this increase as it would not be within our jurisdiction to do so.
What’s more, the landlord offered a fair response in respect of section 2.37. It recognised that while it may not have been providing a new or extended service, an additional charge was being sought (as it had not previously been charging for several services). It was therefore appropriate that the landlord apologised for not bringing the introduction of these new charges to the attention of its tenants.
The Ombudsman appreciates that both the Policy Statement on Rents for Social Housing and the relevant section of the Rent Standard covered similar ground in regard to service charges. Still, it might have been reasonable, where the resident asserted that the landlord failed to comply with section 3.1 of the Rent Standard, for the landlord to have included more detail within its final response on how it complied with this section. The Ombudsman accepts, nonetheless, that the landlord noted that it had already covered this in a previous conversation with the resident.
With regards to the guidance on managing service charges effectively, published by HouseMark, the Ombudsman cannot see that the landlord was obligated to employ this. As the landlord explained, as well as being dated, this document held no regulatory weight and therefore decisions made which were contrary to the guidance could not be considered non-compliant or indicative of a service failure. In any case, it was reasonable that the landlord confirmed for the resident that it had acted in line with both the spirit and letter of the guidance, and continued to liaise with HouseMark to support its service. It satisfied for itself that its actions were in line with the suggested practice.

The process by which the landlord calculated its service charges and its suggestion that the service charge costs were fixed.

The Ombudsman notes that the landlord explained to the resident that in arriving at its service charge costs, it considered the prices for contracts, historic expenditure (not historic estimated costs), and known expected costs for the coming year. This enabled it to estimate the budget for the year as accurately as possible and required sign off at several levels. The Ombudsman notes that this is common practice within the sector and is content that this is a reasonable approach. As the resident was concerned with the way in which this was calculated, it was reasonable for the landlord to explain this to him. The Ombudsman cannot comment on whether the level of increase / decrease this resulted in was fair / reasonable or not.
It was also reasonable that the landlord explained that costs for its contracts were agreed in line with the SoR and shared a copy of the NHF SoR, as requested by the resident. Although the provision of this information was somewhat delayed (as the resident had requested this as early as 21 May 2020), this enabled the resident to consider the benchmark for costs for services received and to assess for himself whether value for money was being sought / achieved. Where transparency was a concern, this was appropriate.
The Ombudsman can see that the resident also challenged the landlord’s service charge regime, asserting that as the charges varied from year to year, the service charge cost was not fixed. Reference was made to both the HouseMark guidance and a passage within the resident’s tenancy agreement. The Ombudsman has considered the landlord’s Service Charge policy, its responses to the resident, and the general structure of a fixed service charge regime, and is satisfied that this was appropriate, however. As had been explained to the resident in the landlord’s final response in February 2017, a fixed service charge regime did not suggest that the costs would remain the same for the duration of the tenancy, but rather that there would be no fluctuation in the monthly cost for the duration of the financial year in which the service charge budget was set. This differs from a variable regime, in which the service charge amount could be increased or decreased with one months’ notice, and in which any amount underspent or overspent would be settled at the end of the financial year.
While the resident’s tenancy agreement does indicate that “the term ‘rent’ refers to the sum of the net rent and service charge set out above or as varied from time to time in accordance with this agreement”, this did not suggest that the resident was subject to a variable regime. Rather, in the Ombudsman’s opinion, this was indicative that the rent would include the net rent and the service charge amount, with recognition that it could change year on year. As the landlord explained to the resident in its final response, the tenancy agreement was silent on the service charge regime, but the Ombudsman is satisfied that the regime was explained to the resident on several occasions.
With the above said, the Ombudsman does accept that the landlord’s communication on 2 March 2020 was somewhat unclear. While the resident had been advised that under his fixed service charge regime, no costs were recovered from previous years, the landlord’s mention of recovering costs from 2019/20 and costs from 2018/2019 might have been interpreted as it taking such action. This would have been contrary to its suggestion that it would not ask residents for the difference in cost, as it would under a variable regime, where it had undercharged them.
Through further correspondence, however, the Ombudsman is satisfied that it was explained to the resident that the costs were not being recovered as such, but that the increased costs from previous years, as well as the costs for services which were not previously charged for, were being taken into consideration in estimating the likely annual spend and setting the budget. This was fair.
The Ombudsman has subsequently determined that there was no service failure in this respect. It has also been noted that in recognition of the confusion this might have caused, and the time invested into pursuing this, the landlord made a good will gesture of £500 towards the service charge budget for the year. This was reasonable.

The alleged introduction of new services without proper tenant consultation.

The Ombudsman is satisfied that the landlord clarified for the resident that there had not been an introduction of new services. The Ombudsman can see that pest control and the removal of rubbish (which would include skip hire where necessary) were services that the landlord offered previously, although had not charged for.
Under the landlord’s Service Charge policy, it explains, however, that where there is a significant difference in charges year on year, the landlord’s Customer Partners will aim to consult with residents about potential increases or decreases. It will explain why the cost of services may have gone up or gone down, why changes are being considered, or why it has decided to start, stop or change certain services. This expectation is also reinforced by section 2.37 of the Policy Statement on Rents for Social Housing and the tenancy agreement, which details that the landlord will consult the resident before making changes in matters of housing management or maintenance that are likely to have a substantial effect on the resident.
The Ombudsman appreciates that the introduction of the new costs did not have a substantial effect on the costs for the resident, and therefore has not considered there to have been a service failure in this respect. It would have been reasonable, nonetheless, for the landlord to have advised residents of the introduction of the new costs, following its review of services. It was appropriate that the landlord acknowledged this within its final response and offered the resident an apology. This was proportionate.
The landlord has informed this Service that it has also sought to offer a clearer breakdown of the services included in some of its more generic headings (e.g. sundry costs), to offer more clarity on the services being offered.

The landlord’s decision to include the management and servicing of communal lights within its service charges.

The resident has expressed that under the terms of the tenancy agreement, the landlord should be responsible for the maintenance of the communal lights. This was not disputed by the landlord.
It is clear, however that the cost of this maintenance was one that the landlord could collect through service charges. The tenancy agreement is also clear in this regard, explaining that the landlord will offer services for the upkeep of lighting which the resident will pay a service charge for.
The Ombudsman has noted, as highlighted by the landlord, that this is additionally indicated in the HouseMark document that the resident had referred to, but also, that the landlord’s Service Charge policy supports the landlord in collecting this. Section 6 of the policy explains that day to day service charges will include heating, light, and electricity in communal areas. The Ombudsman is therefore satisfied that the landlord has acted appropriately in imposing this charge.

The landlord’s handling of the resident’s complaint.

It is clear from the evidence provided that the landlord had sought to deal with the resident’s initial concerns as a service enquiry. This was not unreasonable given that it had been in continuous dialogue with the resident about the service charges.
In the Ombudsman’s view, however, it might have been reasonable for the landlord to have begun to consider the resident’s concerns under its complaints policy when he highlighted his dissatisfaction with its responses on 8 June 2020. Upon receiving clarity on the resident’s issues later on this day, the landlord should have advised the resident that matters would be responded to at stage one of its complaints process. This would have enabled it to formally set out its position and for the resident to receive a full and formal response, which he could subsequently escalate should he remain dissatisfied.
The Ombudsman appreciates that the landlord did provide the resident with several responses and did maintain communication, seeking to address the resident’s queries. Its failure to consider the matter under its complaints procedure, however, meant that upon providing its “wrap up” email, the resident was unclear on how he could further pursue his dissatisfaction and was not signposted to the Housing Ombudsman Service.
The absence of a formal process additionally meant that when the resident brought his complaint to this Service, it was also unclear how the landlord had approached this. This Service therefore had to return to the landlord to prompt it to provide a final response, in order for the resident to refer his complaint. The Ombudsman notes that this delayed the resident in being able to seek resolution with this Service.

Determination (decision)

In accordance with paragraph 54 of the Housing Ombudsman Scheme, there was:
1. No maladministration in respect of the landlord’s response to the resident’s allegations of non-compliance with policies set out by the Department for Levelling Up, Housing and Communities (DLUHC) and the Regulator of Social Housing (RSH), as well as guidance from HouseMark.
2. No maladministration in respect of the process by which the landlord calculated its service charges and its suggestion that the service charge costs were fixed.
3. No maladministration in respect of the alleged introduction of new services without proper tenant consultation.
4. No maladministration in respect of the landlord’s decision to include the management and servicing of communal lights within its service charges.
5. A service failure in respect of the landlord’s handling of the resident’s complaint.

Reasons

The Ombudsman has arrived at the above determinations as:
1. In response to the resident’s allegations of non-compliance, the landlord provided the resident with a reasonable reply, setting out how its actions were in accordance with the specific sections of policy put forward by the resident. This was a reasonable response. It was also reasonable that the landlord clarified for the resident that while it was not obligated to act in line with the guidance set out by HouseMark, it believed that it did. The Ombudsman acknowledges that the resident may disagree with the landlord’s assertion that its actions were compliant, based on the level of increase in service charge and the way that this was set. As signposted above, however, it would be more appropriate for the resident to pursue this via the FTT.
2. The Ombudsman is satisfied that the landlord explained the way in which its service charge budgets were calculated, and that its actions were reflective of industry practice. This was appropriate given the resident’s concerns with the increase in the 2020/2021 service charge. What’s more while the resident asserted that the landlord operated a variable service charge regime, as opposed to a fixed regime as it had suggested, the Ombudsman has been unable to see any evidence of this. The Ombudsman is content that the landlord detailed how the fixed variable regime worked on several occasions, and its actions appear to have been in accordance with this. While its communication, particularly in March 2020, could have been clearer, there was no evidence of a service failure.
3. Although the landlord had introduced new costs, it had not introduced new services. Moreover, the Ombudsman cannot see that the new costs introduced had a significant impact on the costs to the resident. There was therefore no requirement for the landlord to undertake proper tenant consultation.
4. The landlord’s decision to include the management and servicing of the communal lights within its service charges was supported by the terms of the tenancy agreement, the HouseMark document, and the landlord’s service charge policy. It was therefore not unfair that it imposed this charge.
5. Despite the resident’s clear expression of dissatisfaction, the landlord failed to consider the matter under its complaints process. This was contrary to the landlord’s complaints policy and resulted in the resident being delayed in being able to bring his complaint to this Service for investigation.

Orders and recommendations

Orders

In recognition of the landlord’s handling of the resident’s complaint, the Ombudsman orders the landlord to award the resident £50 compensation.
The above payment should be made within four weeks of receiving the Ombudsman’s determination.

Recommendations

The landlord should do more to recognise expressions of dissatisfaction where they are made, and respond to matters formerly under its complaints process. This will ensure that all complaints are handled in line with its complaints policy and that complainants are given full and fair treatment. The landlord may wish to review the Complaint Handling Code, available on the Housing Ombudsman Service website, to remind itself of the Ombudsman’s expectations.