Complaints Policy

Table of contents 

Version 0.5 January 2024

1. Scope

2. Purpose and objectives

3. Policy statement

4. Policy

5. Compliance

6. Sustainability

7. Responsibilities

8. Equality and diversity

9. Related documents

10. Legislation and regulation

11. Review

1 - Scope

  • This policy applies to all customers who reside in properties owned or managed by Sovereign Housing Association Limited and/or Sovereign Living Limited only. Customers who reside in properties owned or managed by Sovereign Network Homes and its subsidiaries should refer to the applicable policy. 
  • Any reference to ‘we,’ ‘our,’ ‘us’ refers to former Sovereign (SNG). When we use ‘you’ and ‘your’ we mean any resident or customer set out above.

2 - Purpose and objectives

  • We are committed to providing our customers with an exemplary service. While we endeavour to be reliable, responsive, respectful, and resourceful, we may not always meet our customer’s expectations.
  • Sometimes things go wrong, and customers don’t receive the service they expect, or we fall short of the standards we’ve promised. This policy explains how we’ll make it easy for customers to tell us when things have gone wrong and how we’ll try to resolve them. It aims to ensure we:
  • Effectively manage and resolve customer complaints. 
  • Have a fair and effective complaint escalation and review process. 
  • Learn from customer feedback to evaluate and improve our services.
  • This policy has been developed in line with the Housing Ombudsman Complaint Handling Code and our regulatory and legal duties.

3 - Policy statement

  • We hope that a customer never has to let us know something has not gone well or that they have been let down by us. But if it happens, we need to make it right.
  • When a customer tells us about an issue, we’ll try to sort it out there and then. If we can’t resolve problems there and then, we shall agree what actions need to be taken, and by when. We shall keep customers updated on what we are doing using a communication method that best suits them. 
  • We expect and empower everyone to do what they can to prioritise the issues our customers face and to fix them as quickly as possible. 
  • We shall consider the root cause of an issue so we can stop it happening again. 
  • Complaints relating to safeguarding shall be resolved through the measures set out in our Safeguarding policy. 
  • We shall not close a complaint until we have tried everything that we believe can reasonably bedone to resolve it, or until we have an agreed action plan in place. When we know the outcome or have an agreed plan in place, we shall communicate to the customer about all the issues that have been raised.
  • Building and maintaining our customers’ trust is at the heart of our approach and we will make sure customers feel we’re taking their issues seriously.

4 - Policy

4.1 - What is a complaint?

  • We use the Housing Ombudsman definition of a complaint: ’An expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, affecting an individual resident or group of residents.’
  • While customers may not use the word ‘complaint,’ if it is evident that they are dissatisfied, we will always give them the option to make a complaint. 


4.2 - Raising complaints in good time

  • We ask for complaints to be made within six months of the matter arising and, unless there is a good reason for doing so, we may not be able to consider complaints made after this time. 


4.3 - Stage 1 complaints

  • When we first receive a complaint, it is known as a ‘Stage 1’. The complaint will be acknowledged and logged within 5 working days of receipt.
  • We aim to agree a solution with the customer within 10 working days of logging a complaint. If this isn’t possible, such as where a complaint is complex, we may need a further 10 working days and we shall let the customer know why. 


4.4 - Stage 2 complaints 

  • A complaint can only be taken to Stage 2 after it has received a Stage 1 response. If a customer is unhappy with a decision received at Stage 1, they have the right to have the decision reviewed. This is known as a ‘Stage 2’ complaint.
  • A senior manager (overseen by a director) will review how the complaint was handled and the decisions made. 
  • If a customer would like their Stage 1 complaint reviewed, they should request this within one calendar year from the date of our Stage 1 response. 
  • We aim to have a decision on Stage 2 complaints made within 20 working days. As with Stage 1 complaints, we sometimes need extra time to make the right decision, so we may take up to a further 10 working days. If we need to do this, we will let the customer know why. 


4.5 - Using a third party or representative to raise a complaint

  • We understand that some customers may want someone else to make the complaint for them and we support this. We will still handle these complaints in line with our policy. 
  • To make sure we protect our customers’ best interests, we need them to complete a letter of authority telling us who can act on their behalf. A template for this is available by contacting our Complaints team (sovereignresolutionteam@sovereign.org.uk) or calling 0300 5000 926.


4.6 - Anonymous complaints and confidentiality

  • We’re not able to record or investigate anonymous complaints. An anonymous report relating to one of our services, a member of staff or a customer will be reported to a Director/Head of Service/Senior Manager depending on the information disclosed for the service area for follow up and investigation if appropriate.
  • Confidentiality: All members of staff are required to adhere to our code of conduct and maintain confidentiality as appropriate to the circumstances. Our Complaints Specialists should seek support when handling a complaint of a sensitive nature or if asked not to disclose the identity of the complainant. We need to manage the expectations of our customers, ensuring we can adhere to our complaints process for investigation and resolution and have regard to our duty of care to our customers, employees, and 3rd party contractors. 
  • It may not be possible to fully investigate a complaint without disclosing the identity of the complainant, and if so, we’ll ask the complainants permission to do this. While we respect our customers’ right to confidentiality, if we don’t have this permission, we may not be able to investigate fully. 


4.7 - How we’ll try to put things right

  • We’ll always try to put things right and that usually means getting the customer back to where they should have been before they had a problem. 
  • For most problems, a genuine apology and putting things right straight away is where it ends. Sometimes, if it has taken us longer than it should have to get something sorted out or if the problem keeps happening, we may offer compensation.
  • Our Complaints team are fully trained and are supported by experts from across former Sovereign (SNG). Our training ensures that we are best placed to manage our customers’ complaints in an impartial way and with empathy. 

The things we’ll look at will be: 

  • the customer’s situation, for example, if they need additional help.
  • how much the customer has been disrupted.
  • how long it’s taken to put right.
  • if there’s been distress and/or inconvenience.

If a service goes wrong:

  • We’ll make it easy to tell us what’s happened.
  • We’ll make sure that we understand what’s happened from the customer’s viewpoint and look for a solution that works for them. 
  • We’ll be clear about what we can and will do, and then do it. 
  • We’ll tell the customer who will help them if the issue is complex.
  • We’ll keep in touch until everything is sorted out.


4.8 - When we can’t reach an agreement 

  • When we’ve done all, we reasonably can to resolve a complaint, but a customer is still unhappy, they can refer the matter to the Housing Ombudsman Service. In the instances where we don’t consider or escalate a complaint, customers will be informed of their right to take their complaint to the Housing Ombudsman.
  • Customers have one year from the date of our Stage 2 response to raise the matter with the Ombudsman. They can also ask a designated person, such as a councillor or MP, to act on their behalf. We will still handle such complaints in line with our policy. 


4.9 - Housing Ombudsman Service 

  • The Housing Ombudsman Service is a free and independent dispute resolution service. Customers can contact the Housing Ombudsman service at any point during the complaint procedure. 
  • The Ombudsman can’t formally investigate while complaints are going through our internal process but may be able to give advice and support to help reach a resolution. 
  • The Ombudsman will contact us to get the facts of the case from our point of view and then make a final decision.

Housing Ombudsman Service

Housing Ombudsman Service, PO Box 152, Liverpool L33 7WQ

Email: info@housing-ombudsman.org.uk

Phone: 0300 111 3000


4.10 - Other complaints handling avenues

If you have purchased a home from us and remain unhappy, you will need to contact the Consumer Code for Home Builders rather than the Housing Ombudsman Service:

Consumer Code for Home Builders

Consumer Code for Home Builders Limited, Westgate House, Royland Road, Loughborough, Leicestershire LE11 2EH 

Email: enquiries@consumercode.co.uk

Phone: 0345 608 9797


For shared owners and long leaseholders who have complaints about service charges and the terms of their leases:

First Tier Tribunal (property Chamber) Southern region

Residential Property, Havant Justice Centre, The Court House, Elmleigh Road, Havant, Hampshire PO9 2AL 

Email: rpsouthern@hmcts.gsi.gov.uk

Phone: 01243 779394


Complaints over debt advice for third party creditors only:

Financial Ombudsman Service

Make a complaint on the Financial Ombudsman Service website

Financial Ombudsman Service, Exchange Tower, London E14 9SR

Email: complaint.info@financial-ombudsman.org.uk

Phone: 020 7964 1000


4.11 - Complaints we may not consider or escalate

  • While we welcome complaints and we don’t normally restrict the number of complaints or level of contact made by our customers, there may be circumstances under which we may not consider or escalate complaints.

4.11.1 - Service requests 

  • Often a customer’s concerns can be resolved at ‘first point of contact’ and will not need to go through our two stage complaints process. These are known as ‘Service Requests.’
  • Unless a customer asks us to, we won’t register a service request as a complaint in the first instance. If the customer is unhappy with how we dealt with the matter, we will log this as a complaint. In line with our definition, the customer does not have to use the word ‘complaint.’ 

4.11.2 - Court proceedings

  • If the complaint concerns matters that are or were subject to formal court proceedings, we may not be able to investigate.

4.11.3 - Matters outside our control 

  • Where the complaint concerns matters outside former Sovereign (SNG) control, such as a Local Authority responsibility, we will not be able to investigate. 


4.12 - Working with our involved residents to shape our services 

Complaints highlight to us which services are working well and which need a closer look. The residents in our Scrutiny Coordination Group play an important role in this as they:

  • consider feedback from our customers.
  • help us learn from what has gone wrong.
  • complete scrutiny activities.
  • make sure that we put measures in place to fix things.
  • check that we act on recommendations that come out of a scrutiny.

Working with residents in the scrutiny group allows us to hear first-hand about our customers’ experiences. As a result, our residents’ views are the starting point for any changes we make. Find out more about how we engage with customers this way. Working this closely with our residents makes sure that the way we handle complaints is fair and transparent to all.


4.13 - Unreasonable customer behaviour

  • We may occasionally receive complaints from customers whose behaviour and/or frequent contact prevents us resolving the complaint or adversely affects the ability of our teams to help other customers. 
  • In these cases, we’ll speak with them to understand why they keep contacting us. We’ll also liaise with external agencies to find out if they need support. 

We will explain clearly what we have done to resolve the complaint and decide what we will do the next time they contact us about the same issue. This could be to: 

  • acknowledge the contact but not offer any additional responses. 
  • ask them to only contact one named employee.
  • ask them to only contact us using a channel of our choice.
  • ask them to contact us at mutually agreed times. 

We’ll review customers we manage this way each year. If a customer wants to challenge the way they’re managed, they can ask us to review it. The Head of Complaints will undertake this review and will only do this once. 

5 - Compliance

  • We will ensure all complaint handling staff are trained and aware of the complaints policy and of our commitment to excellent service delivery standards.
  • We record all complaints, regularly monitor our progress in handling them, and measure our performance against targets.
  • Performance on complaints and how complaints have been used to improve services is reported to our involved residents, so that they can hold us to account and recommend improvements.
  • We shall carry out an annual self-assessment against the code to ensure our complaints handling remains in line with its requirements.

6 - Sustainability

  • At former Sovereign (SNG), we recognise the critical importance of sustainability in our operations and services. We are committed to embracing sustainable practices that contribute to environmental protection, social equity, and economic viability.

7 - Responsibilities

SNG (Sovereign Network Group) Executive Board - Ultimate responsibility for determining and directing SNG’s response to service failures and Ombudsman complaints.

CCO (Chief Customer Officer) and CCO LT (Leadership Team) - Provides assurance to the Board on the effectiveness of complaint and compensation policies, Ombudsman decisions and strategies to improve services and reduce service failures.

Resident Board Partnership (RBP) - Provides feedback on SNG’s approach to complaints and collates customer feedback on past issues.

Customer Operations Director - Responsibility and ownership over the Complaints Policy and related process.

All colleagues and contractors - All colleagues should be aware of this policy. Colleagues dealing with compensation and/or complaints must read this policy and comply with this policy.

Customers - Please read this policy carefully, along with our ‘Compensation Policy’. Let us know if you need any assistance with understanding this policy or making a formal complaint or compensation claim.

We encourage you to contact us as soon as an issue arises. We will endeavour to redress the problem before a formal complaint is required and there may be discretion to offer some form of compensation depending on the circumstances.

If you are unhappy with our proposed solution or wish to formally complain about the service failure, please follow the steps on our website (link) or talk to a customer agent for guidance.

If you are still unhappy once the formal complaints process has concluded, a complaint should be made through the Housing Ombudsman website Opens in new window.

It is important that formal complaints are raised with us within 12 months of the incident occurring.

8 - Equality and diversity

  • We will apply this policy consistently and fairly and will not discriminate against anyone based on any relevant characteristics, including those set out in the Equality Act 2010.
  • We’ll be transparent about our responsibilities around equality and treat everyone fairly and respectfully, regardless of their: age, gender, marital status, sexual orientation, disability, religion, race, nationality, ethnicity, or national origin.
  • We’ll make sure our services and workplaces are as inclusive and accessible as possible and take seriously any concerns that we’ve not acted in a fair way, dealing with them as quickly as we can.
  • We have a ‘reasonable adjustments’ policy that describes how we can give extra support to those customers who need it. Customers can get a copy of this by contacting our Complaints team (sovereignresolutionteam@sovereign.org.uk) or calling 0300 5000 926. 
  • Adjustments may include letters or information in another format or language. For example, recordings of complaint letters to listen to instead of reading. Making sure customers are not excluded is important to us. Find out more about Sovereign’s commitment to inclusivity.

9 - Related documents

This Policy is supported by the following documents

10 - Legislation and regulation

The legislation listed in this policy is not intended to cover all legislation applicable to this policy. To comply with clause 1.1 of the Regulator of Social Housing’s Governance and Financial Viability Standard, which requires adherence to all relevant law, SNG will take reasonable measures to ensure compliance with all applicable legislation by reviewing policies and procedures and amending them as appropriate. Any queries relating to the applicable legislation should be directed to the policy owner.

  • Housing Ombudsman Complaint Handling Code
  • Consumer Rights Act 2015
  • Equality Act 2010
  • Data Protection Laws (GDPR and Data Protection Act 2018)
  • Regulatory Framework for Social Housing (Regulator of Social Housing)

11 - Review

This document will be reviewed annually, or sooner if significant changes occur in the relevant legal or operational landscape.