Southwark Council (202010225)

REPORT

COMPLAINT 202010225

Southwark Council

23 August 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 regarding:
1. The landlord’s response to the resident’s reports of damage caused to his kitchen ceiling and its handling of the repair to his shower/wet room.
2. The landlord’s complaint handling.
3. The landlord’s response to the resident’s request to be either compensated for a damaged carpet or for the carpet to be replaced.

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 39(i) of the Housing Ombudsman Scheme, the following aspect of the complaint is outside of the Ombudsman’s jurisdiction:
1. The landlord’s response to the resident’s request to be either compensated for a damaged carpet or for the carpet to be replaced.
Paragraph 39(i) of the Housing Ombudsman Scheme states that ‘the Ombudsman will not investigate which ‘concern matters where the Ombudsman considers it quicker, fairer, more reasonable or more effective to seek a remedy through the courts, a designated person, other tribunal or procedure’.
In correspondence with this Service, both parties have confirmed that the resident has lodged a claim with the landlord’s insurers regarding the damaged carpet and this Service understands the claim is still being considered.
The Ombudsman cannot make decisions on liability in the same way that an insurer can, as it is not within our role or powers to do so. This Service will therefore not consider this aspect of the resident’s complaint as, in the Ombudsman’s opinion, it is being more appropriately dealt with through another procedure, via the landlord’s insurer’s consideration of the matter.

Background and summary of events

Background

The resident resides in a four-bedroom house and has done so since 2015. He is a secure tenant of a Local Authority.
The landlord operates a two-stage complaints process, with a ‘Complaint’ phase and a ‘Review’ phase. Its policy states that the landlord may close a complaint at the Complaints phase if the landlord had not identified any service failure, or if there is no prospect of changing its decision at the Review stage. It advises that it aims to issue responses within 15 working days at the Complaint stage and within 25 working days at the Review stage.
Within the landlord’s Repairs Guide, it advises that repairs deemed as ‘Urgent’ should be attended to within three working days. Urgent repairs include ‘sink, drain or any toilet not draining’. Repairs that are determined as being ‘non urgent’ are described as routine repairs the landlord’s contractors will attend to within 20 working days, although the Guide also notes that ‘non urgent’ works will sometimes include planned major works which may have a ‘reasonable delay before we start work as long as there will be no serious risk to health and safety’.
For reasons of clarity, this Service notes that various pieces of evidence refer alternately to ‘the shower’ and ‘the wet room’. The resident has confirmed to this service that these are references to the same installation.

Scope of Investigation

While this Service notes the resident has expressed dissatisfaction with the standard of works carried out by the landlord when installing a wet room in his property in 2017, this investigation has not been provided with evidence that he had reported this to the landlord prior to the complaint lodged in June 2020.
Paragraph 39(e) of the Housing Ombudsman Scheme states that the Ombudsman will not consider complaints which, in the Ombudsman’s opinion, were not brought to the attention of the member as a formal complaint within a reasonable period, which would normally be within six months of the matters arising.
As the substantive issues become historic it is increasingly difficult for an independent body, such as the Ombudsman, to conduct an effective review of the actions taken to address them. In view of the time periods involved in this case, taking into account the availability and reliability of evidence, the Ombudsman’s jurisdiction, and the landlord’s approach to this issue, this investigation will focus on the landlord’s response to the repair issues raised following receipt and acknowledgement of the complaint.

Summary of Events

During the summer of 2017, the resident had a new wet room installed by contractors working for the landlord. Landlord records note that the contractor ‘returned to make good’ following the installation, but in correspondence with the landlord and with this Service, the resident has claimed he has been unable to use the wet room in the three years since it was installed. The landlord has advised it has no record of the resident raising any repair issues regarding the wet room until he logged a complaint in June 2020.
On 5 June 2020, the resident contacted the landlord by phone to make a complaint. The landlord has advised this Service that records of the call itself are not available, but internal correspondence from 9 June 2020 shows that it recorded the resident as having reported the following:
1. Adaptations work that had been carried out in 2017 had been of poor quality and he had been asking for them to be checked for the past three years.
2. He had been told he would be reimbursed £300 to renew his carpet following the works, however the landlord’s contractors eventually refitted the old carpet and did a poor job, leaving an overhang on the stairs over which he had just tripped and injured his arm.
3. The screed was also of poor quality (it was not stated which floor was being referred to) and was creating a further trip hazard.
4. After the wet room was installed above his kitchen, a crack appeared in the ceiling which was filled in. He stated cracks had reappeared and been filled in twice more and were now appearing again.
The landlord contacted the resident by phone on 10 June 2020 and, in a follow up email sent the same day, confirmed it understood his complaint to be regarding ‘work to the adapted bath’ and ‘damage to the carpet’. It advised it had referred the information to its Adaptations Team to investigate and to check their previous records, and that it would ‘arrange action to look into the work concerns’. The landlord also noted that it would be difficult for it to investigate issues the resident had raised from over a year ago, but it would contact him again once it had received relevant information.
On 24 June 2020, the landlord provided its Stage One complaint response via a brief email which, although it advised was ‘in response to your complaint’, did not make clear that it was a formal complaint response. However, the landlord has since confirmed to this Service that this did constitute its formal response at Stage One. It advised its email was a follow-up to a voicemail left for the resident the same day, although this Service has not seen any records that indicate what the landlord advised the resident in its voicemail. In its email, the landlord advised that a surveyor from its Adaptations Team would contact him to ‘address any concerns regarding works’ and that the Adaptation Team was also ‘checking records to verify what occurred three years ago’, although it again noted this was ‘proving difficult’ as the contractor who allegedly damaged the resident’s carpet no longer worked for the landlord.
In August 2020, the landlord arranged for a contractor to conduct a survey at the resident’s property. It gave the contractor a brief to ‘inspect the threshold and confirm if it is a tripping hazard; inspect plumbing in the bathroom and identify if there is (sic) any defects; to inspect kitchen ceiling and identify if it is defective’.
The survey was carried out on 3 September 2020 (the report stated the contractor attended on ‘3-8-2020’ but this Service believes this to be a simple typing error as the landlord had not yet engaged the contractor at that time). The landlord also attended the survey virtually, via video call. The contractor provided the landlord with a full survey report on 16 September 2020, which noted the resident had reported ‘a catalogue of complaints’, of which it gave a summary:
1. ‘Poor installation of level access shower room on first floor leading to repeated flooding of wet room and damage to kitchen ceiling below’.
2. ‘Poor installation of WC to existing bathroom in first floor at rear leading to damage of existing laminate and damage to kitchen ceiling.’
3. ‘Damage to landing and stairs carpet during installation (burn marks during hot works).’
4. ‘Inadequate repair and relay of landing carpet during works (apparently due to removal of carpet to facilitate levelling to level access wet room)’.
5. ‘Damage to existing basin vanity suite during installation’.
6. ‘General dissatisfaction with quality of works carried out and intense frustration at length of time for their expectations of resolution’.
In addition to the complaints summarised above, the contractor’s report provided the following conclusions relating to matters covered by its brief (Paragraph 18):
1. It noted the ‘pressing issue is to determine whether or not any structural defects exist (in the property)’ before remedial works should be carried out.
2. Regarding the threshold and reported trip hazard, it advised there was no immediate risk, and the issue could be resolved with a new threshold ‘as and when the carpet dispute is resolved’.
3. Regarding the plumbing and reported defects in the wet room, it noted that ‘the shower is serviceable, but should be subjected to regular household maintenance to prevent blocking’. It recommended the joist structure under the shower former be investigated ‘to determine if it is stable and robust’ along with the joists in the resident’s bathroom. It advised that new silicone sealing was required on an area of low-level boxing to prevent future water ingress.
4. It noted the movement in the shower former would not pass the landlord’s current inspection standards, but it did not present any risk. It remarked that, to remedy the issue to the resident’s satisfaction ‘would entail complete removal, repair and renewal of the wet area, if not the entire floor subject to what is found on closer inspection’.
5. Regarding the kitchen ceiling, the contractor noted ‘there are cracks running across the width of the kitchen’ but it was not possible to establish the cause ‘without removing either the ceiling itself or the first floor above it’. It also noted the cracks appeared to be below the first-floor bathroom, rather than the wet room, as the resident had stated, but the cracks ‘may be age related’ as the property was old.
6. It also noted that the resident requested installation of a downflow heater in the bathroom.
Internal landlord correspondence on 22 October 2020 confirmed the resident had contacted it to request his complaint be escalated to Stage Two of its complaints procedure. Internal emails note that the escalation request regarded the wet room installation in 2017 and that, since the resident’s initial complaint, while a further inspection had taken place and works agreed, he had not had any further update. However, this Service has not seen any records that indicate when the works had previously been discussed or agreed with the resident.
On 23 October 2020, landlord correspondence indicated it had attempted to contact the resident to discuss progress on the agreed works, which it listed as ‘remove/replace both the bathroom floor and shower former’ and ‘replace the thresholds in the property to remove any trip hazards’. It noted its surveyor would be awarding the works to a contractor.
Further internal correspondence on 27 October 2020 indicated that the landlord had now contacted the resident to provide an update and that it had also requested a quote from its contractor for the following works:
1. To supply and fit new downflow electric heater in bathroom.
2. To replace floor covering with coving and new wider threshold.
3. To replace shower former to match existing size.
4. To rake out and re-silicone all broken and damaged silicone.
Further internal landlord correspondence from 25 November 2020 noted ‘adaptation works have been programmed’ and stated that a start date for the works had been requested. However, on 16 December 2020, a subsequent internal email exchange noted that the resident had contacted the landlord that day to advise he was ‘not happy with the works agreed’. Later the same day a further email from the landlord’s surveyor indicated the resident had advised he expected additional work to be carried out, such as tiling in the bathroom and a repair to the kitchen ceiling. The surveyor commented that the contractor had attended the property on two occasions and did not find a leak or refer to any defective tiling in their report. The email confirmed that works were now put on hold ‘until (the resident) agrees for works to proceed’.
On 30 November 2020, in internal correspondence regarding the landlord’s investigation of the Stage Two complaint, a staff member from the landlord’s Resident Services team advised they had referred ‘issues deemed related to repairs’ to its Disrepair Team, following a tenancy check on 20 February 2020. However, details of the repair issues raised by the resident were not included.
On 20 January 2021, the landlord issued its Stage Two response. It apologised that its response was overdue and outlined it understood the complaint to be regarding the wet room installed by the landlord in 2017 when works were not carried out to an acceptable standard and works subsequently agreed not being completed. It noted that the resident had particularly raised the following issues:
1. Cracks to the kitchen ceiling allegedly caused by the floor above.
2. The wet room leaks and the floor tray ‘moves’.
3. Carpet not being secured under a threshold bar and therefore causing a trip hazard.
4. Carpet was damaged by a contractor and therefore needed to be replaced.
Regarding the ceiling and bathroom floor, the landlord advised it would not need to remove any flooring but that it had identified an ‘imperfection in a joint’ in the kitchen which had been ‘dealt with as part of internal re-decoration’. It also advised that it had not identified a leak from the bathroom, rather the shower drain had been blocked. The landlord confirmed that it had agreed to do the works set out in Paragraph 20 of this report and clarified that these were the only works that had been recommended following its inspection. It also clarified that it had not found any record of the resident reporting any repair problems relating to the wet room prior to making his complaint in June 2020 so it would not be able to investigate any issues regarding its installation in 2017.
Regarding the resident’s carpet, as noted above, the query over whether the landlord would replace this or offer compensation for the alleged damage caused falls outside the scope of this investigation. However, the landlord did advise that it was willing to attend and install a threshold bar as the resident had stated that it currently posed a trip hazed.
The landlord concluded that it did not uphold the resident’s complaint. It advised that its surveyor had ‘confirmed what works are required in your property’ although it noted that ‘this does not meet your expectation’. The landlord clarified that its position was that it was only required to carry out ‘necessary works’ and it would do these, if the resident agreed, as soon as the Covid-19 lockdown restrictions in place at the time had ended.

Post-complaint events

On 4 February 2021, the resident reported a leak, reportedly from his shower, that was coming through the kitchen ceiling. The landlord responded the following day and advised that it had forwarded the matter to its Repairs Team. In subsequent correspondence with the resident, the landlord advised that the leak would be attended to on 11 February 2021 and that it would be treating the reported leak separately to the matters covered within his complaint, which would be ‘done after lockdown restrictions have eased’.
On 11 February 2021, correspondence between the resident and landlord indicates that the leak was attended to as arranged. In a subsequent email, the landlord also advised that its Adaptations Team had now agreed to attend to carry out the work proposed in Paragraph 20 ‘as an emergency providing that you confirm and agree to the works schedule raised’. The landlord later sent a further email, outlining a more detailed schedule of works, and again advised it would request the Adaptations Team to contact the resident, if he confirmed that he agreed to the works.
Although this Service has not seen any records that confirm when, or how, the resident agreed to the works schedule or when the works took place, the landlord’s contractor sent it an email on 1 April 2021 which confirmed all scheduled works had been done and noted that ‘(the resident) is very happy with the refurbishment’.
Following the refurbishment, on 15 April 2021 the resident reported further cracks in his kitchen ceiling. Further to that, on 19 April 2021, he reported a leak from his shower. Landlord repair records show that repair orders were raised, first for the ‘shower unit to be repaired or replaced’ and then to ‘attend and replace shower unit’, although records do not indicate when the works were completed.
On 10 May 2021, the landlord contacted this Service to advise that it had carried out another inspection of the resident’s kitchen ceiling on 7 May 2021 following his report of further cracks appearing. It advised that its operative had identified additional issues with the ceiling, noting that ‘the resident has had several leaks from the wet room above the kitchen, which has caused a 2LM crack and bowed a section of the ceiling’. The operative also noted the resident was ‘worried that the bowed ceiling could come away/fall into the kitchen, his concerns in my opinion are justified’. Following this inspection, the landlord raised a work order to carry out necessary repairs and make good.

Assessment and findings

In its initial response to the resident in June 2020, the landlord advised it would not be able to investigate the issues he raised regarding the standard of work carried out by its contractors when they completed a wet room installation in 2017. This was a reasonable position for it to take and in line with its Complaints Policy, which states that it will not normally consider complaints made more than twelve months after the issue arose. This is also in line with the Ombudsman’s approach to complaints brought to this Service as set out in paragraph 12 above. Although it would not consider the issues raised from 2017, the landlord did advise it would response to the other matters raised by the resident and also advised it would arrange for a surveyor to contact him and assess the situation. This was an appropriate response. However, it is noted that the resident’s Housing Officer advised that he had raised repair issues on behalf of the resident in February 2020, although the nature of these repairs was not outlined. That there are no records of any repairs being reported or raised in February 2020 raises concerns over the landlord’s record keeping as well as the communication between different departments.
However, it is noted that, while the landlord initially responded promptly to the resident, it passed the repair issues on to its Adaptations Team. While this Service acknowledges that its Adaptations Team may have been best placed to lead on the issue as the installation of a wet room in 2017 would clearly have been an adaptation, as the resident was now raising the matter three years later, in the Ombudsman’s opinion, the landlord should have treated the matter as a repair issue under its repair responsibilities. This would have meant the landlord was able to respond in line with the procedures set out in its Repairs Guide and provided the resident with greater clarity regarding when inspections and works would be carried out or progressed. This Service has also not been provided with any policies relating specifically to the time within which the landlord aims to respond to, and action, adaptations related repairs. The landlord’s decision also meant the repair records provided to this Service during this investigation are effectively incomplete as they do not include most of the works agreed and carried out by the Adaptations Team and the landlord’s contractor following the resident’s complaint. While the landlord did provide email correspondence with the resident and its internal correspondence, which include detailed schedules of works, there is no full audit trail for the works that were agreed and ultimately carried out.
After acknowledging the resident’s complaint regarding repair issues in his wet room/shower and cracks in his kitchen ceiling, the landlord did not carry out an inspection until 3 September 2020, three months later. In the Ombudsman’s opinion, this was a protracted length of time for it to complete an inspection. While this Service acknowledges that landlords had many additional pressures and restrictions caused by the coronavirus pandemic last year, it is noted that Government guidance at the time (June-September 2020) did not prevent landlords entering resident’s properties and, from the correspondence available to this investigation, the landlord did not cite any reason for the delay in arranging an inspection at the resident’s property.
The landlord’s contractor carried out an inspection in September 2020 and, following the brief it was given by the landlord, made recommendations regarding the work it believed would be required. However, after receiving the contractor’s report on 16 September 2020, the landlord did not go ahead and request a quote for works until 27 October 2020, six weeks later and after the resident had requested a complaint escalation, lodged partly because he had not received further updates on the progress of works following the inspection. In the Ombudsman’s opinion, this was also a protracted delay, and, while again it is acknowledged that it was operating against the backdrop of the coronavirus pandemic, this Service has not seen the landlord give any reason for why it did not begin the process of progressing the works sooner. This was not appropriate as it caused the resident further delay, and also meant he was prompted to take the time and trouble to chase the landlord for an update.
Having requested a quotation from its contractor in October 2020, it is noted that the works then did not take place until April 2021, almost six months later. Again, the information made available to this investigation regarding the progression of the repairs is incomplete and, to establish a timeline of events, this Service has been reliant on the landlord’s email correspondence, both internal and with the resident and its contractor. It is acknowledged that, during the period under investigation, Government guidance regarding coronavirus changed as the UK entered lockdown. Therefore, in January 2021, when it responded to his complaint at Stage Two, the landlord acted reasonably when it advised the resident that it was only able to carry out emergency works at that time, and that the repairs would begin once restrictions were lifted.
It is also acknowledged that there was some disagreement between the landlord and the resident regarding the scope of the works, despite the landlord’s correspondence indicating that these had been agreed as early as September 2020. It is noted that, following a conversation with the resident in December 2020, the landlord’s surveyor stated that the works were ‘on hold’ until the resident agreed to them. While this Service understands the challenges landlord face if residents do not agree to works, due to the landlord’s lack of clear repair logs, it is not clear if this decision was communicated to the resident. Although the landlord advised the resident in later emails that the works would only progress if he agreed to the scope of works, there is again a lack of a coherent audit trail regarding the communication they had with the resident and there is little evidence of his responses within the correspondence provided to this Service. This was not appropriate and as a result there is insufficient evidence that the landlord communicated effectively with the resident and kept him updated on the status and progression of the works.
From the information available to this investigation, the works were eventually completed before 1 April 2021. It is noted that the landlord had initially advised the resident that the works would not be able to take place until lockdown restrictions had ended. However, on 11 February 2021 it advised him that its Adaptations Team had agreed to carry out the works as an emergency and they would therefore be done sooner. This was a reasonable action for the landlord to take and indicated that it was prepared to be flexible and sought to prevent any further delay. However, although the exact date that the works were carried out is not evidenced within the landlord’s records, in the Ombudsman’s opinion, taking all the circumstances of the case into consideration, even though they were reportedly completed before 1 April 2021, this was still an unreasonable delay. The landlord has also failed to provide any satisfactory explanation for this delay to the resident. This was not appropriate.
The Ombudsman notes that, following the end of the landlord’s complaints procedure, but before it was able to complete the works it had committed to doing, the resident reported a further leak in February 2021., The landlord responded appropriately and promptly, attending the following week to resolve the issue. It was also reasonable for it to advise that it would treat the leak separately and to seek to resolve that issue prior to progressing the other outstanding works referred to above.
The landlord has also demonstrated that, following the works being completed and the completion of its complaint process, it has continued to communicate with the resident regarding further reported issues with his kitchen ceiling. Although these reports post-date the end of the complaints procedure, the Ombudsman considers it appropriate to briefly comment on these, given the history of this case. In correspondence with this Service, it advised it carried out a further inspection at the resident’s property in May 2021 and identified further issues with the ceiling for which it has now raised further repair orders. Its response to these further reports appears to have been reasonable and proportionate, although this Service has not seen confirmation that the repairs raised have now been completed.
With regards to its complaint handling, the landlord did not respond to the resident’s Stage One complaint appropriately. Its response at Stage One was via a brief email which did not make clear it was a formal response or provide advice on how the resident was able to escalate his complaint. This was not appropriate and meant the landlord did not act in accordance with its Complaints Policy. While the response advised that its Adaptations Team would contact him, it did not provide any clear timeframes for doing so, nor did it provide a chronology of events or a clear outcome as to whether the complaint had been upheld or not. The landlord also reasonably advised that it would prove difficult to establish the events which occurred during the installation of the wet room in the resident’s property in 2017 due to the length of time that had passed. However, it did not make clear whether it would ultimately provide a response to this or, if so, how it would do so since it had already provided its Stage One response. This was not appropriate and further meant that its complaint response lacked clarity. Although the response refers to a voicemail left for the resident, there are no records to indicate what information the landlord passed to the resident in this message, which means it is unable to demonstrate what advice it provided, or if it referred to any further actions or outcomes. This was not appropriate and not in keeping with the Ombudsman’s Dispute Resolution Principles.
The resident requested that his complaint be escalated in October 2020. Within his escalation request, he also raised the issue that he had not received further updates from the landlord following an inspection at his property the following month. The landlord provided its Stage Two response in January 2021, some four months later and significantly outside its 25-working day target. Although the landlord did apologise for the time taken to provide its response, it did not provide any reason for the delay other than that there had been ‘issues with staff’. From the information seen by this investigation, there is no evidence that the landlord had kept the resident updated regarding the progression of its complaint response or that it had provided him with any updated target time. This was not appropriate. However, it is also noted that the landlord’s communication with the resident from the time it issued its Stage Two response was much improved and it sought to clarify his desired outcomes, provide more regular updates, and manage his expectations.
Within its Stage Two response, the landlord noted that the resident was additionally concerned with regards to the fact works agreed had not been completed. However, it does not address this within its response, rather addressing individual repairs and providing further details on the assessments it had carried out and the work that had been agreed. The landlord did not provide any information regarding why the work was yet to be progressed or provide any reasons for why the resident had not been kept updated. This meant that the resident’s complaint was not addressed appropriately.

Determination (decision)

In accordance with Paragraph 54 of the Housing Ombudsman Scheme, there was service failure by the landlord in relation to its response to the resident’s reports of damage caused to his kitchen ceiling and its handling of the repair to his shower/wet room.
In accordance with Paragraph 54 of the Housing Ombudsman Scheme, there was service failure by the landlord in relation to its complaint handling.

Reasons

While the landlord’s position that it could not investigate the circumstances regarding the original installation of the wet room/shower in the resident’s property was reasonable given the length of time that had passed and that it could not find a record of the resident previously raising concerns, once it was made aware of further issues following receipt of the resident’s complaint in June 2020, there were protracted delays in how it responded. There was an initial delay in arranging and carrying out an inspection and, following that, a further delay in arranging the works that had been identified. There was then a further delay before the works were carried out at some point before April 2021, over nine months after the resident’s original complaint. While the Ombudsman does acknowledge that there were complicating factors, including the ongoing situation regarding coronavirus and lockdown restrictions and apparent disagreement between the landlord and resident over the scope of works, there is no evidence that the overall delay was unavoidable.
The landlord’s Stage One response provided to the resident was brief, did not make clear whether it constituted a formal response, did not offer clarity regarding the actions it would take and the overall outcome of the complaint. It also did not offer him advice on his escalation rights. While the landlord apologised for the delay in providing its Stage Two response, it did not provide appropriate updates on the progress of the complaint or any clear reasons for the late response. It also did not fully address the complaint he had raised.

Orders and recommendations

Orders

The landlord is ordered to pay £350 compensation to the resident within four weeks of the date of this report, consisting of:
1. £250 for the delay in carrying out an inspection and subsequent delays with raising and progressing the repairs identified.
2. £100 for not issuing its Stage One complaint response in accordance with its complaints policy and for the delay in issuing its Stage Two response.

Recommendations

The landlord should consider producing a separate policy around how it carries out works under its adaptations programme or, if one already exists, it should consider incorporating it into its current repairs policy, so residents are given greater clarity around repairs standards and target times.
The landlord should share the Ombudsman’s Complaint Handling Code with staff members who deal with complaints to ensure that they respond to complaints in accordance with best practice.