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We were appointed by Weaver Vale Housing Trust (WVHT) to conduct a review of the ‘big five’ areas of property compliance in order for them to understand their compliance position across gas safety, electrical safety, fire safety, asbestos management and water hygiene. Principally WVHT wanted to know what it needed to do in order to demonstrate full statutory property compliance where required. Our work with WVHT commenced with a Compliance Health Check review for the ‘big five’ areas of compliance. This included the production of a Compliance Roadmap to assurance in respect of electrical safety, asbestos management and fire safety. This piece of work was followed by a compliance summary and compliance review. We were then asked to carry out a further compliance review, with a particular focus on data management and record keeping for the ‘big five’ areas of property compliance.

The Challenge

We discovered that WVHT had a good approach to compliance, but it had a number of elements which required strengthening in relation to electrical safety, fire safety and asbestos management. Firstly, WVHT had no process maps in place for any of the five compliance areas under review, therefore, they could not evidence the end to end process of delivering their compliance programmes. Whilst this does not mean that there were no processes in place, it makes it infinitely more difficult to evidence assurance to an external party such as ourselves. The reason being that the process maps can be utilised as a check and balance to ensure that the approach they outline is what is being delivered in reality. Additionally, WVHT had no procedure documents in respect of fire safety, electrical safety or water hygiene and those for asbestos were outdated. We always recommend that procedure documents are produced for all compliance areas in conjunction with the development of process maps in order to provide a detailed supporting narrative of the end to end process. Furthermore, all of the policy documents were light in content and were missing some of the key information that is required to provide clarity on regulation, legislation and approved codes of practice. We would always recommend that policies are produced with the full involvement of leaders (in this case the Executive Management Team – EMT), in order for them to can agree on the policy principles to be applied.

What We Did

The Compliance Health Check: Firstly, we identified that WVHT’s current approach to compliance had been developed over a number of years via a bottom-up approach, whereas we always recommend that a top-down approach is used in order to achieve higher levels of clarity on what WVHT is required to do to achieve full compliance. We drew on our compliance expertise to compare their approach with regulation, legislation and approved codes of practice and produced a summary of their current position in relation to robust compliance management. Compliance Roadmap: Based on our findings from the Compliance Health Check, we took a ‘first principles’ approach to provide WVHT with a roadmap to compliance for fire safety, asbestos management and electrical safety. Firstly, we supported WVHT to identify all assets that should be included on the compliance programmes for fire safety and asbestos management. Following this, we ensured that these asset lists were updated with all of the verified information to provide an understanding of the scale of any compliance gaps for these two areas. This resulted in WVHT commissioning new fire risk assessments and asbestos management surveys to all assets found to no longer be valid. Next, we delivered compliance awareness training to the Board and leaders and a policy principles workshop to cover all five areas of compliance. This provided them with a clear understanding of their obligations and allowed us to develop five new fit for purpose policies. Following on from this, the final series of workshops involved the sign off and approval of the process maps and supporting procedures, and the development of excel spreadsheets for fire safety and asbestos management to enable compliance reporting going forward. Following both the Compliance Health Check and Compliance Roadmap, we were asked by WVHT to carry out a further compliance review, with a particular focus on data management and record keeping covering the ‘big five’ areas of property compliance. WVHT had made considerable improvements to the data management arrangements over the previous 12 months but still had a small number of issues in the validity of some of the electrical compliance records, which WVHT addressed immediately.

Our Achievements

WVHT has made significant improvements since our first piece of work with them in 2017, and as a result, can now clearly demonstrate how it manages, monitors and reports on its property compliance obligations. We are fully confident that they will continue to achieve full compliance with regulation, legislation and approved codes of practice in respect of the five areas subject to review.