Decision

Great Places Housing Group Limited (L4465) - Regulatory Judgement: 25 September 2024

Updated 25 September 2024

Applies to England

Our Judgement

	Grade/Judgement	Change	Date of assessment
Consumer	C2 Our judgement is that there are some weaknesses in the landlord delivering the outcomes of the consumer standards and improvement is needed.	First grading	September 2024
Governance	G1 Our judgement is that the landlord meets our governance requirements.	Assessed and unchanged	September 2024
Viability	V2 Our judgement is that the landlord meets our viability requirements. It has the financial capacity to deal with a reasonable range of adverse scenarios but needs to manage material risks to ensure continued compliance.	Assessed and unchanged	September 2024

Reason for publication

We are publishing a regulatory judgement for Great Places Housing Group Limited (Great Places) following an inspection completed in September 2024.

This regulatory judgement confirms a consumer grading of C2, a governance grading of G1 and a financial viability grading of V2.

Prior to this regulatory judgement, the governance and financial viability grades for Great Places were last updated in December 2023 following a stability check, to confirm grades of G1 and V2. This is the first time we have issued a consumer grade in relation to this landlord.

Summary of the decision

From the evidence and assurance gained during the inspection it is our judgement that there are some weaknesses in Great Places delivering the outcomes of the consumer standards and improvement is needed, specifically in relation to our Safety and Quality Standard. Based on this assessment, we have concluded a C2 grade for Great Places.

Our judgement is that Great Places meets our governance requirements. Great Places has provided evidence to demonstrate the effectiveness of its governance arrangements and that it continues to effectively manage the risks of its activities, allowing it to deliver its strategic and charitable objectives. Based on this assessment, we have concluded a G1 grade for Great Places.

Our judgement is that Great Places meets our financial viability requirements and has the financial capacity to deal with a reasonable range of adverse scenarios. Great Places has exposure to financial risks that it needs to manage. These include the development and sale of new homes and meeting its planned expenditure on improving the quality and energy efficiency of its existing homes. Its stress testing demonstrates that financial capacity is built into its business plan and Great Places has provided appropriate assurance that it has access to sufficient liquidity and adequate funding in place. Based on this assessment we have concluded a V2 grade for Great Places.

How we reached our judgement

We carried out an inspection of Great Places to assess how well it is delivering the outcomes of the consumer standards and meeting our governance and financial viability requirements, as part of our planned regulatory inspection programme. During the inspection, we considered all four of the consumer standards: Neighbourhood and Community Standard, Safety and Quality Standard, Tenancy Standard, and the Transparency, Influence and Accountability Standard.

During the inspection we observed a board meeting and a presentation to the board by the tenant scrutiny panel, spoke to tenants, held meetings with Great Places including with its non-executive directors and reviewed a wide range of documents provided by Great Places.

Our regulatory judgement is based on all the relevant information we obtained during the inspection as well as analysis of information received from Great Places through its regulatory returns and other regulatory engagement activity.

Summary of findings 

Consumer – C2 – September 2024

During the inspection Great Places provided evidence-based assurance that it has appropriate systems in place to ensure the health and safety of its tenants in their homes and associated communal areas. However, there are weaknesses in Great Places’ approach and oversight of health and safety risks. Great Places is aware of areas for improvement that we identified during the inspection, which include the quality of information used to understand and monitor remedial actions and compliance. Great Places has an appropriate system of gathering assurance over its approach in this area and had identified these issues prior to the inspection. Despite these weaknesses we gained assurance that Great Places has systems and processes that work to ensure the health and safety of its tenants.

There is evidence that Great Places keeps an accurate record of the condition of its homes through physical surveys and has a process for keeping this information up to date. Great Places has a plan to improve this information through increasing the number of its homes with a recent stock condition survey. Great Places uses the information it has of the quality and safety of its tenants’ homes to make decisions on future investment to maintain and improve homes.

Great Places has demonstrated that it provides an effective and timely repairs service to tenants. There is evidence it takes action to improve the service and outcomes for tenants when issues occur. Great Places has identified that its repairs service is a significant cause of the complaints it receives and as a result has made changes to the way tenants can engage with the repairs service.

When tenants make complaints, Great Places has shown it has made service improvements in response. It has processes that mean its board is updated on the type of complaints received and there is an approach in place to ensure learning from complaints.

We gained assurance that Great Places prioritises the safety and security of its communities. It has sought external assurance over its approach to managing anti-social behaviour and hate incidents and made changes to improve its oversight of anti-social behaviour performance to allow scrutiny in this area. Great Places provided evidence to demonstrate how it works in partnership with relevant organisations to deter and tackle anti-social behaviour in its neighbourhoods.

Great Places’ allocations policy sets out its approach to ensuring all properties are let in a fair and transparent way, with the most recent policy approved by the board after being reviewed by tenants. We saw evidence of Great Places ensuring tenants are supported in sustaining their tenancies.

Overall Great Places’ approach is delivering the outcomes of the consumer standards in relation to the Transparency, Influence and Accountability Standard. Great Places has put in place training and development of its staff to further develop a culture of fairness and respect. It demonstrates an active approach to considering tenants’ diverse needs in the design and delivery of services and presented appropriate assurance that the tenant information it holds is used to support the delivery of fair and equitable services.

Great Places provides a wide range of opportunities for tenants to influence and scrutinise its strategies, policies and services. There are clear arrangements in place through which Great Places hears from tenants. There is also evidence that feedback from tenants has directly and positively impacted service delivery. Great Places has provided appropriate assurance that it makes effective use of its performance data to shape services and provides a range of information to tenants to support effective scrutiny.

Governance – G1 – September 2024

Based on the evidence gained from the inspection there is assurance that Great Places’ governance arrangements enable it to effectively manage its risk and adequately control the organisation, allowing it to deliver its objectives. Great Places’ board demonstrated that it provides challenge on performance against the organisation’s strategic targets and consideration of risk appetite in strategic decision making.

Great Places has provided appropriate assurance that its board proactively reviews its approach to delivering against its purpose and regularly considers alternative options to ensure it is achieving value for money in making best use of resources.

Great Places was able to provide evidence that it has established and maintains clear roles, responsibilities and accountabilities within its leadership and governance structure. The relationship between its board and committees is working in line with its delegations to strengthen assurance in key areas of risk and compliance.

Continuing governance improvement is evidenced through annual effectiveness reviews and in-depth periodic external governance reviews. The most recent external review took place in February 2024 and recommendations have informed an action plan being monitored by the board.

Board member skills, experience and knowledge are aligned with the activities of the organisation and there is a structured approach to developing and appraising skills to support succession planning. We have seen evidence of this through board observation, meetings with non-executive directors and the executive team as well as reviewing relevant documents including meeting minutes.

Great Places has a risk management and control framework that aligns to its strategic risks. There is evidence of robust discussion and board challenge of the controls and assurance on strategic risks and of risks being managed effectively in practice.

Great Places’ board actively seeks and gains an appropriate level of assurance across a range of areas. There is evidence of how this assurance has been used to make improvements including on the approach to anti-social behaviour, stock condition information, and damp and mould.

Board ownership of stress testing, mitigation strategies and wider governance over risks through regular and structured review of golden rules is evident. Reporting to board provides sufficient detail for the board to ensure effective oversight.

Viability – V2 – September 2024

Based on the evidence gained from the inspection we have concluded that there is appropriate assurance that Great Places’ financial plans are consistent with, and support, its financial strategy. Great Places has appropriately evidenced that it has an adequately funded business plan, sufficient security in place to support its financial plans, and Great Places is forecast to continue to meet its financial covenants under a wide range of adverse scenarios. Great Places’ board has effective oversight of covenant compliance with regular reporting in place on actual and projected covenant performance.

Great Places continues to meet our viability requirements and has financial capability to deal with adverse scenarios. Its recent financial performance indicates it has delivered a sustainable financial position throughout a period of economic uncertainty, and it continues to forecast generating a positive operating margin. However, in the short term Great Places plans to continue significant investment in its current homes and this restricts the capacity available to respond to a wide range of financial risks.

In addition to this investment, Great Places anticipates being able to generate surplus from the sale of some of its assets, including homes developed for sale. While it is not reliant on these sales, they represent an uncertain cashflow for the organisation and a risk to delivering the planned financial position. We have assurance that Great Places has reporting and oversight in place to manage the risks of its sales programme.

Background to the judgement

About the landlord

Great Places is an exempt charity registered under the Co-operative and Community Benefit Societies Act 2014. Over half of its income is from social housing lettings with the rest of its income from shared ownership sales and market sales.

Great Places is the RSH registered parent in the group, which includes Great Places Housing Association and Plumlife Homes Limited. All are non-profit registered providers of social housing. Great Places has a further nine unregistered entities in the group, of which two are fully owned subsidiaries.

Great Places operates across 47 local authority areas, primarily across the North West, Yorkshire and Humber, and the East Midlands. Its largest property holding is across Greater Manchester. It owns and manages around 21,000 social housing homes. The majority are general needs and affordable rent properties, with the remainder including Low Cost Home Ownership and supported housing or housing for older people.

At 31 March 2023, the group employed 809 full-time equivalent staff. Group turnover for the year ended 31 March 2023 was £167.8m. Great Places plans to develop around 6,000 homes between 2024 and 2029.

Our role and regulatory approach

We regulate for a viable, efficient, and well governed social housing sector able to deliver quality homes and services for current and future tenants.

We regulate at the landlord level to drive improvement in how landlords operate. By landlord we mean a registered provider of social housing. These can either be local authorities, or private registered providers (other organisations registered with us such as non-profit housing associations, co-operatives, or profit-making organisations).

We set standards which state outcomes that landlords must deliver. The outcomes of our standards include both the required outcomes and specific expectations we set. Where we find there are significant failures in landlords which we consider to be material to the landlord’s delivery of those outcomes, we hold them to account. Ultimately this provides protection for tenants’ homes and services and achieves better outcomes for current and future tenants. It also contributes to a sustainable sector which can attract strong investment.

We have a different role for regulating local authorities than for other landlords. This is because we have a narrower role for local authorities and the Governance and Financial Viability Standard, and Value for Money Standard do not apply. Further detail on which standards apply to different landlords can be found on our standards page.

We assess the performance of landlords through inspections and by reviewing data that landlords are required to submit to us. In Depth Assessments (IDAs) were one of our previous assessment processes, which are now replaced by our new inspections programme from 1 April 2024. We also respond where there is an issue or a potential issue that may be material to a landlord’s delivery of the outcomes of our standards. We publish regulatory judgements that describe our view of landlords’ performance with our standards. We also publish grades for landlords with more than 1,000 social housing homes.

The Housing Ombudsman deals with individual complaints. When individual complaints are referred to us, we investigate if we consider that the issue may be material to a landlord’s delivery of the outcomes of our standards.

For more information about our approach to regulation, please see Regulating the standards.

Further information

• Regulating the standards

• Regulatory standards for landlords