Milton Keynes City Council (202229797)

REPORT

COMPLAINT 202229797

Milton Keynes City Council

21 March 2024

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 the resident’s:
1. Reports of leaks in her property.
2. Request for remedial works and damages.
3. Formal complaint.

Background

The resident is a secure tenant of the landlord, which is a local authority. She occupies a 2-bedroom maisonette property with an upstairs bathroom and downstairs toilet.
The resident made a formal complaint to the landlord on 1 August 2022. She said she had complained for years about leaks from the downstairs toilet but the situation was now serious as she could smell toilet waste. Contractors had attended but refused to acknowledge the scale of the problem, which she considered related to the main pipe between the property and the above neighbouring property. She also reported that, despite the landlord erecting scaffolding outside her property for 3 months, nothing had been done and she was still experiencing leaks though her ceiling.
The complaint was acknowledged on 15 August 2022 and responded to on 21 October 2022. The landlord apologised for the delay in responding. It noted that the contractor had spoken to the resident to schedule repairs and a final appointment had been arranged for 2 November 2022.
The leak from the toilet was resolved on 2 November 2022. According to the contractor, this was due to a cracked pipe going into the soil stack. Remedial work commenced on 16 November 2022 to rectify damage caused during the leak and repair work.
On 13 December 2022 the resident made a further complaint, which the landlord logged and considered at stage 2 of its complaints procedure. She requested new flooring for her stairs, the downstairs toilet, the hallway, and the upstairs corridor, which had been damaged due to the leaks and by contractors during works. She also asked that the ceilings be painted to remove water marks caused by the leaks. She referenced the upheaval she had experienced due to ongoing issues with leaks over a number of years.
On 29 December 2022 the resident reported that water was coming up through her bath plug. The landlord’s contractors attended the same day and unblocked the drain, but the resident reported that the issue persisted on 27 January 2022. She continued to report the problem throughout February 2022 and expressed to the landlord that the contractors had been verbally abusive and impatient with her.
The landlord responded to the stage 2 complaint on 23 February 2023. It acknowledged the resident had reported that ‘fleas and rice’ were coming up through her bath plug but said the contractor’s supervisors found no evidence of drainage issues when they attended. It encouraged her to take pictures of any further problems to assist its understanding and directed her to make an insurance claim for any damages. It did not uphold the complaint as it said no further work was required.
The resident emailed the landlord on 23 and 25 February 2023 and said she felt she was not being listened to. She questioned how it could determine that repairs had been completed without attending to see for itself. She accused the landlord of taking sides with the contractor and questioned why she should claim on insurance for damages. She added that her toilet seat had been broken and believed it was the landlord’s responsibility to fix this. The landlord responded on 27 February 2023, explaining that it would not consider the complaint further as there was no evidence the outcome would change.
On 31 March 2023 the resident reported a leak through her ceiling, which was affecting the light and smoke alarm. The landlord attended the same day to make the electrics safe. A follow up appointment was attended on 3 April 2023, when the leak was identified to be caused by issues with the rainwater drain, which was rectified.
On 29 May 2023 the resident once again reported that dirty water was coming into her bath and asked that the landlord help. A request was also made the following day, by a councillor, on the resident’s behalf. The resident emailed pictures to the landlord which showed debris and dirty water in the bath, and noted it sometimes contained curry oil, or noodles and rice, and smelled of urine. The landlord’s contractors attended the following day to inspect. The contractor observed the problem and conducted a jet wash to the soil stack. The issues persisted, with contractors attending on several occasions throughout June and July 2023, when a further jet wash and exploratory works were undertaken. A non-return valve was fitted on 2 August 2023, following which, the resident reports, there have been no further issues.

Assessment and findings

Scope of Investigation

In her stage 1 complaint, the resident reported that she had experienced leaks dating back to 1999 and she felt the landlord’s contractors were reluctant to acknowledge the scale of the work required to resolve the situation.
The landlord’s repair log evidences that works were conducted following reports of the sink and bath being blocked in 2017, and leaks involving the toilet waste pipe, which were reported on 4 occasions between 2018 and 2021. Further work was conducted on the soil pipe in January 2022 and the resident’s upstairs bathroom was fully renewed in March 2022.
The Ombudsman cannot comment in any detail on the action taken by the landlord in relation to these incidents. Nor can it determine the cause of the leaks, whether the issues were linked, or the scope of works required. The Ombudsman will only consider complaints which were brought to the attention of the landlord and this Service within a reasonable period, which is normally within 6 months of the matters arising. This is so that the landlord can consider the issues whilst they are still ‘live’ and whilst the evidence is still available to fully investigate them (reflected at paragraph 42(c) of the Scheme).
As a result, this investigation is focused on the landlord’s actions from April 2022 onwards. However, giving context to the current complaint, it is recognised that similar issues presented multiple times since at least 2017 and that the ongoing nature of the situation caused much distress, inconvenience, and upheaval for the resident.

Landlord’s handling of reports of leaks

Section 11 of the Landlord and Tenant Act 1985 requires landlords to make repairs to the structure and exterior of the property, as well as to installations including pipes. This obligation is acknowledged in the landlord’s Tenant Handbook, in which the landlord states it is responsible for the services and equipment that supply water. The Tenant Handbook identifies both ‘emergency’ and ‘routine’ repairs, which are to be responded to within 4 hours, or 28 days, respectively.
The resident reported an issue with her toilet on 5 April 2022 and the job notes indicate this involved a leak and an issue with the flush. The precise nature of the leak is unknown, as is the priority classification the repair was given. However, the landlord’s contractors attended the following day and, according to the job notes, resolved the issue. The landlord is considered to have acted reasonably in taking responsibility for the repair and attending promptly.
Following the resident’s report of ‘uncontainable’ leaks around her toilet on 27 July 2022, the landlord raised this as an ‘emergency repair’ and attended the same day, out of hours. The Tenant Handbook identifies burst pipes as an example of an emergency repair. It was again, therefore, appropriate that the landlord assumed responsibility and attended as a priority.
There are no details of any works conducted that day, but the job notes show follow on works were ordered with ‘routine priority’, to be completed within 28 days. The resident noted in her stage 1 complaint of 1 August 2022, that the situation persisted and she was experiencing leaks almost every day, which smelt like toilet water. The contractor next attended to conduct work on the pipes on 12 August 2022.
The Tenant Handbook identifies ‘minor leaks’ from waste or supply lines as routine repairs. If we consider that the leak was minor, the landlord could be considered to have acted in accordance with its policy timeframes. However, given the resident reported smelling waste, the situation could have been considered more urgent.
In the Tenant Handbook the landlord also acknowledges its responsibility to conduct certain repairs within set timeframes, as outlined by the government in the ‘Right to Repair Scheme’. Blocked or leaking foul drains, soil stacks or toilets are ‘qualifying repairs’ which should be resolved within 1 day, subject to conditions such as the cost of the repairs. Under the Scheme, the landlord is required to compensate the resident for the repair should it not conduct works within prescribed timeframes.
Ultimately, the Ombudsman cannot determine whether the water from the leak was foul, and therefore whether the repair qualified. However, the landlord had information from the resident that suggested this was the case on 1 August 2022 and it is the Ombudsman’s opinion that the landlord should have acted more promptly to investigate and rectify the situation.
The resident did not consider the situation resolved following the visit by contractors on 12 August 2022. The contractor updated the landlord on 22 August 2022 that it was closing the complaint, as it had been unable to contact the resident since 15 August 2022. The landlord emailed the resident on 25 August 2022, and she responded on 26 August 2022, explaining she was on holiday and that both she and her son had informed the contractor of this. She reported that the situation had worsened and asked that the landlord keep the case open and contact her son who was staying in the property. Given the issue was ongoing, it is considered hasty of the contractor to have closed the case after 1 week, without trying other means of contact such as writing to the resident.
The resident reported a further leak around the toilet on 27 August 2022 which, according to the job notes, appeared to be related to a blockage causing the pan to overflow. The landlord responded appropriately, categorising the job as an emergency, and contractors attended the same day, out of hours. The contractor found the toilet was not overflowing but isolated it and requested a follow up appointment.
The leak with the downstairs toilet appears to have been identified and resolved on 2 November 2022. This was some time after the contractors attended on 27 August 2022 and the resident’s first report in July 2022. The circumstances around the leak and whether it remained ongoing during this period are unknown, as are the full reasons for the delays. However, the job notes indicate that the resident cancelled appointments on 14 and 15 September 2022. There was an appointment scheduled for 26 September 2022, and a job raised on 11 October 2022, however it is not known if contractors attended on these days.
In the absence of information about what action was taken, and given appointments were cancelled by the resident, we cannot hold the landlord wholly responsible for delays during this period. However, it is recommended that, going forward, the landlord keeps full and clear records of its activities regarding repairs, including dates of attendance.
At some point during this period the resident also experienced leaks with water coming through her ceiling. It is not clear from the job notes when this occurred, or when action was taken to address it. The contractor acknowledged the issue had occurred, in an email to the landlord of 3 January 2023, and explained that water had flooded in under the balcony doors due to blocked guttering. In its stage 2 response the landlord confirmed this had been resolved.
This appears to have been a re-occurring issue. The resident reported that she had experienced leaks to her ceiling in her stage 1 complaint and referenced that scaffolding had been erected but no action taken by contractors. Again, it is difficult to assess the landlord’s actions here as no job notes have been provided about this.
A landlord should have systems in place to maintain accurate records of repair reports, responses, inspections, investigations, and communications. Good record keeping is vital to evidence the action a landlord has taken and failure to keep adequate records indicates that the landlord’s processes are not operating effectively. The landlord’s staff should be aware of a landlord’s record management policy and procedures and adhere to these.
On 29 December 2022 the resident reported that the bath in her upstairs bedroom was blocked. This was dealt with as an emergency appointment and the job notes indicate the bath was unblocked and the issue was resolved. The landlord’s responsiveness and resolution of the situation at this juncture was appropriate and in line with its policy.
However, on 27 January 2023 the resident reported that dirty water was coming up through her bath plug. The contractor’s manager attended on 31 January 2023, when the resident claims she showed them pictures and videos of the problem and she forwarded these to the landlord the same day. She also expressed that ‘rice and fleas’ were present in the water and reported that contractors had, once again, tried to unblock the drains the previous week but this had not resolved the situation. The Ombudsman has seen a copy of a video which shows water in the bath, but it is not clear if this was the same video, and it does not appear to confirm the reported problems.
In its stage 2 response the landlord claimed the contractors had found no evidence of drainage problems. It is not clear what investigations and work took place during the visit on 31 January 2023, or throughout this period. The Ombudsman does not consider it satisfactory if no exploratory work was undertaken, simply because the water was not present in the bath at the time of the visit and considers the landlord should have taken the resident’s concerns seriously and investigated. In the absence of information evidencing the issue and the landlord’s exploration of it, it is not possible to say that it took appropriate action at this juncture. Again, the landlord is reminded to ensure better record keeping evidencing its actions going forward.
The resident also mentioned, in her email of 31 January 2023, that the contractors who had attended that day had been impatient with her when it took her time to explain the problem due to her limited English and she accused them of bullying. She sent further emails throughout February 2023 expressing her frustration with the situation, which she considered ongoing, and the way she had been treated, saying she felt she was not being listened to.
This included an email sent on 13 February 2023, which was registered as a complaint, in which she said there was dirty water coming from the taps and she could smell urine. In her further email of 21 February 2023, she stated water was coming through the bath from the above property and that it stunk. The landlord rejected the complaint as she already had one open. Other than this reply, there is no evidence the landlord responded to the resident, prior to its complaint response of 23 February 2023.
The Ombudsman considers this a significant failure on the part of the landlord. It not only neglected its responsibility to take the resident’s concerns seriously and investigate and rectify the issue, but it demonstrated a total lack of communication. This did not afford due respect to the resident, who already felt she was not being listened to. Her mounting frustration was evident from her communications during this time. In her email of 25 February 2023 she spoke about the impact this was having on her health and said she deserved to live in safe and decent conditions.
She also asked to be moved due to the stress of the situation, which she had expressed in previous correspondence on several occasions. The landlord’s decant policy says it may be applicable to move residents temporarily in circumstances where extensive works are required, or there is loss of services or amenities of a longer-term nature. It is not clear the works fell within the category of extensive or long-term, though it is reasonable that the resident considered them to, given the issues had presented repeatedly over years.
In its stage 2 response, the landlord said it did not uphold the complaint as no further work had been identified. However, as discussed, there is no evidence that it made further inspections despite ongoing reports from the resident. It noted she had been advised to send videos and pictures of the issue, but she had already done so on 31 January 2023 and, regardless of this, her reports should have been sufficient for it to investigate further.
In its response, the landlord also failed to acknowledge that the resident had experienced long standing issues with leaks and drainage problems, through no fault of her own, and the detriment this had caused her. Nor did it address her reports of being abused and feeling like she had not been listened to. The Ombudsman considers the landlord’s response inadequate in addressing the crux of the resident’s grievances and lacking in sympathy for her situation and the distress caused.
The resident responded and asked that the job be inspected by the landlord, so that it could independently assess the issues. The landlord stated it was unable to escalate the complaint as there was no evidence the outcome would change. This was another missed opportunity to respond meaningfully to the situation. The resident had requested on multiple occasions that the landlord conduct an independent inspection rather than simply agree with its contractors about what was required (where the issues remained ongoing). This was also ‘strongly recommended’ by the contractor itself, in an email to the landlord of 3 January 2023. The Ombudsman considers that this would have been a reasonable and proportionate step for it to have taken, at least to evidence it took the resident’s concerns seriously and to demonstrate fairness in its assessment of the situation.
The resident reported a leak through her ceiling on 31 March 2023. The landlord appears to have responded with appropriate urgency to this issue in accordance with the timeframes identified in its policies and procedure. It appropriately categorised this as an emergency repair and attended the same day, with follow up work to identify and resolve the leak taken shortly afterwards.
On 29 May 2023, the resident once again reported that dirty water was coming into her bath. The landlord responded appropriately in conducting inspections and repairs to the drains from May 2023, and acted with due urgency. However, this came far too late given the resident had reported these issues with no reply on several occasions in February 2023. The landlord recognised that the water was foul, which indicates this was in fact a qualifying repair and should have been addressed at the earliest opportunity. The resident stated, in her email of 31 May 2023, that now it had been shown she was not lying and she expressed sadness that her complaints had not been taken more seriously.
Overall, there were multiple and significant failures in the landlord’s handling of the resident’s reports of leaks, which amount to severe maladministration. The landlord failed to act appropriately to reports about the leaks, most significantly in relation to reports about the drainage problems with the bath from 31 January 2023. This resulted in the resident enduring unsanitary conditions, which went unaddressed from February to May 2023, causing much distress to the resident as expressed in her emails to the landlord on multiple occasions.
The landlord failed to take appropriate measures, such as independently inspecting the property, and at times was not solution focussed, moving to close down the complaint or conclude the matter was resolved despite reports from the resident to the contrary. It also demonstrated a lack of respect in failing to acknowledge the resident’s distress, show empathy for her situation, take seriously her concerns about the way she felt she had been treated by contractors, or even to respond to her reports.
The Ombudsman expects landlords to demonstrate our dispute resolution principles when handling complaints. These are – to be fair, put things right and learn from outcomes. While the resident has confirmed the leaks have now been resolved, the landlord has not acknowledged its failings, offered appropriate remedy with regard to the distress caused, or demonstrated how it will learn from its mishandling of the situation.
The landlord should reflect on the failings identified and write a letter to the resident, apologising for these failures and explaining how it intends to ensure they are not repeated. The Ombudsman also considers compensation to be appropriate, given the impact upon the resident. The landlord does not have a compensation policy specifying amounts it can award, however is guided by the Local Government and Social Care Ombudsman guidance. In line with this Service’s remedies guidance, the Ombudsman considers an offer of £800 to be appropriate, reflective of the distress and inconvenience caused to the resident, and time and trouble spent in chasing the issue.
Going forward, where issues are raised about the demeanour of contractors, or a resident refutes the account of work needed or undertaken by them, the landlord should ensure this is considered impartially and conduct appropriate enquiries.
The landlord should also ensure it retains complete and auditable records so that it can be held accountable for the actions it does or does not take.

Landlord’s handling of requests for remedial works and damages

Following repairs to the toilet leak on 2 November 2022, remedial works were undertaken to rebuild the upstairs bathroom (which had been impacted by works) and the downstairs toilet. This included reinstating the bath, tiling, painting, and laying vinyl floor. The job notes indicate this work was completed on 16 November 2022.
On 13 December 2022 the resident made a stage 2 complaint in which she noted her stairs carpet had been ruined by contractors walking up and down. She said her toilet carpet had been damaged by leaks and the carpet in the upstairs corridor also needed replacing, though it is not clear if this was due to leaks, or it was damaged during repair works. She also requested that the ceiling be painted where there were water marks from leaks.
The landlord replaced the flooring in the hallway in January 2023, due to mould growth, but the flooring in the upstairs corridor was not replaced. The contractor emailed the landlord on 3 January 2023, in response to the issues raised in the complaint. It did not consider the stairs carpet needed replacing as it had been assessed and no damage was found to have been caused. It added that it used protection measures during work. It gave no explanation as to why it considered the corridor carpet did not need replacing, nor about water marks caused by leaks. The landlord directed the resident to make an insurance claim in its stage 2 response.
The Ombudsman cannot determine whether the landlord damaged the carpet during works, but it would have been appropriate for its contractors to have evidenced the protective measures put in place, or its assessment that the carpet had not been damaged. For instance, by taking photographs of such measures. The landlord is responsible for keeping the home in a reasonable state of repair, and should damage be caused due to issues outside of the resident’s control, such as a leak, or in conducting repairs, it should put this right.
While it is appropriate for the landlord to direct claims for damages to its insurer, the Ombudsman considers it would have been fair to have first properly considered the damage itself. It could have conducted its own inspection, as recommended by the contractor in its email of 3 January 2023, and as frequently requested by the resident.
The contractor denied that the downstairs toilet floor required replacement, but acknowledged it needed sealing, which it said it had scheduled to do on 15 December 2022, but the resident had not been at home. The job notes show this work was completed on 13 January 2023. It is reasonable to assume this job was considered routine and should have been completed within 28 days. While there was a short delay in scheduling the repair to the floor, the contractor outlined in its email of 3 January 2023 that it had struggled to contact the resident. It therefore took appropriate action here and cannot be held responsible for the delays caused by scheduling difficulties outside of its control. Photographs taken of the completed job indicate it was done satisfactorily and the resident did not raise further issues about this flooring.
Following a further leak, caused by issues with the rainwater pipes on 31 March 2022, additional damage was done to the ceiling. Works were scheduled, which included applying stain block, but the job notes indicate more time was needed. There are no follow up notes, so it is not clear whether this remedial work was concluded. The resident remains dissatisfied that the downstairs bathroom and upstairs ceiling need painting due to water marks caused by leaks. The landlord is directed to inspect and remedy the damage as appropriate.
The resident also raised that she needed a new toilet seat, claiming this had been damaged during works. This was not specifically expressed as part of her formal complaints, but was requested in an email of 25 February 2023. Job notes from the visit attended on 6 April 2022 contain pictures of a broken toilet seat and state a new one is needed. The landlord should make enquiries to determine whether this was actioned and, if not, ensure it is replaced.
Overall, there were failings in how the landlord handled the resident’s request for damages and remedial works which amount to maladministration. It should inspect the property and rectify evidence of water marks, and provide a new toilet seat. It should assess the carpets and consider its liability for replacing these. In line with the Ombudsman’s remedies guidance, the landlord is also ordered to pay compensation to the resident of £100 for delays in inspecting and rectifying these issues. This is in acknowledgment of the inconvenience and frustration caused to the resident of living in the home with ongoing remedial requirements for an extended period.

Complaint handling

The landlord has not provided a copy of the Complaints policy that was in affect at the time of the resident’s complaint, however its actions have been assessed against its current policy, dated 2023, and this Service’s Complaint Handling Code (Code).
The resident emailed the landlord on 1 August 2022 to complain about the ongoing issues with leaks. There were initial delays in acknowledging the complaint and the landlord only did so after 11 working days, on 15 August 2022. The landlord’s policy and the Code specify this must be done within 5 working days. The complaint should also have been defined within the acknowledgement, to ensure understanding of the issue and the outcomes the resident was seeking.
The landlord responded to the complaint on 21 October 2022. The response was brief, simply stating that the contractor had liaised with the resident to conduct repairs and an appointment had been scheduled for 2 November 2022 to complete works. This response did not address the points raised in the complaint, which referred to the resident suffering from leaks for many years, both to the toilet and through her ceiling. Again, the response did not define her complaint, or the decision on the complaint, as the Code requires it to.
While the landlord apologised for the delay in its response, it offered no explanation for this and no redress, as would have been appropriate in the circumstances. The response came after 58 working days. The Code requires that stage 1 responses are issued within 10 working days. Extensions of up to 10 working days can be granted in certain circumstances. The landlord notes in its policy that it currently aims to respond within 20 working days and is working towards reducing this timeframe in line with the expectations of this Service. In any case, this was a significant delay and there is no evidence the landlord communicated the delays or managed the resident’s expectations about this.
The resident made a further complaint on 13 December 2022, in which she raised new issues. This was considered to be an escalation of her original complaint, thought it was allocated a different reference number. The stage 2 response came after 50 days, on 23 February 2023. Again, this was significantly delayed. The landlord’s policy allows it 20 working days to provide a response, which can be extended by up to 10 days in complex cases. It offered no acknowledgment or apology for its delays at this stage.
The resident had continued to express dissatisfaction about the ongoing leaks and remedial works in several emails in January and February 2023. One email, sent on 13 February 2023, was registered as a new complaint, but rejected as the complaint of 13 December 2022 was still open. The resident’s complaint raised new concerns about the way contractors had treated her. The landlord should have investigated this as a new complaint or addressed this issue within its stage 2 complaint response.
The resident was unhappy with the landlord’s response and communicated this. The landlord confusingly responded on 27 February 2023, saying it would not escalate the complaint to stage 2 as it did not consider the outcome would change. There was additional confusion in how complaints were categorised. It is difficult to discern, from the information provided, how the landlord had considered some of the resident’s correspondence to be formal complaints, and others not. It also gave complaints different reference numbers, which made it difficult to establish whether a complaint was considered a new complaint or an escalation.
Overall, there were failings in the landlord’s handling of the formal complaint which amount to maladministration. It delayed in responding to her complaints, did not fully acknowledge or address her grievances within its responses, and there was confusion in how the complaints were logged and dealt with. It should offer compensation for the inconvenience and frustration caused by this. The Ombudsman considers an award of £150 to be proportionate in line with its remedies guidance. The Ombudsman will be issuing new complaint handling guidance in the coming months and asks the landlord to review its complaint handling policy in line with this guidance, with particular reference to timeframes for responding to complaints, and complaint handling principles guiding how a complaint should be considered and responded to. The landlord should also self-assess against the Code.

Determination

In accordance with paragraph 52 of the Scheme, there was:
1. Severe maladministration in the landlord’s handling of the resident’s reports about leaks in the property.
2. Maladministration in the landlord’s handling of the resident’s:
  1. Request for remedial works and damages.
  2. Formal complaint.

Orders

Within 4 weeks of this report:
1. The landlord must pay the resident £1,050 compensation (£800 for distress caused by its handling of the resident’s reports about leaks, £100 for its handling of the resident’s request for remedial works and damages, and £150 for issues in its complaint handling).
2. The landlord should write a letter to the resident, acknowledging and apologising for the failures identified in this report and explaining how it intends to ensure these are not repeated.
3. The landlord should provide the Ombudsman with its plan to ensure that it will conduct internal inspections where residents raise evident concerns about the work of operatives or their assessment of the repairs.
4. The landlord should inspect the property, rectify water marks, and provide a new toilet seat. It should also assess the carpets and consider its liability for replacing these. It should update the Ombudsman on the outcome of this inspection.

Recommendations

The landlord is recommended to:
1. Review the Ombudsman’s spotlight report on Knowledge and Information Management and self-assess against its recommendations. Going forward it should ensure that complete and auditable records are kept showing what action it has taken in relation to repair works.
2. Review the Ombudsman’s spotlight report on Attitudes, Respect and Rights, and consider its recommendations.
3. Review its complaint handling policy in line with the guidance and requirements outlined in the Ombudsman’s updated Code, which comes into effect from 1 April 2024. It should also endeavour to bring its complaint response times into alignment with the Code.