Complaints Policy

1. POLICY PURPOSE

1.1 Customer service is a key part of One Manchester’s business and we aim to provide excellent quality services for customers at all times. However, where customers are not satisfied with the level of service they have received from One Manchester (including our contractors), we understand that complaints will sometimes be made. We will investigate all complaints raised with One Manchester, in accordance with this policy.
1.2 We see complaints as a valuable source of feedback for One Manchester. We are committed to using them as a way of understanding what our customers really want and feel about the homes and services we provide and how One Manchester can improve them.
1.3 Anyone who has experienced dissatisfaction with One Manchester’s services can raise their concerns about this using this policy, or have someone else do so on their behalf as their “representative”. We will use this complaints process to resolve their dissatisfaction at the earliest opportunity and, where possible, to improve service delivery.
1.4 This policy will be published on the One Manchester website and we will send a copy of it to any customer at their request. We will publicise it where possible including in leaflets, newsletters and other correspondence with our customers and we will actively consider how best to do this with specific groups of our customers.

2. POLICY SCOPE

2.1 This policy applies to anyone using One Manchester’s homes or services, or their representatives. These people are defined in this policy as “customers”.
2.2 A customer does not have to use the word “complaint” for it to be covered by this policy. A complaint is an expression of dissatisfaction, however made, about the standard of service, action or lack of action by One Manchester, our own colleagues, or those acting on our behalf, affecting a resident or group of residents. 
2.3 Although each complaint will be considered on its own merit, there are some things that are not considered as complaints for the purposes of this policy. These are:

• a service request (explained in more detail below). If a complaint is made in connection with One Manchester’s failure to deal with a service request appropriately while the service request is ongoing, we will continue to progress the service request at the same time as considering the complaint.
• a request for information or an explanation of how a decision has been made. 
• a report regarding neighbour nuisance or disputes between neighbours or other anti-social behaviour, which is managed in line with One Manchester’s Anti-Social Behaviour Policy (unless the complaint refers to One Manchester’s failure to deal with the matter appropriately in accordance with that policy).
• dissatisfaction with the level of rent or service charges or the amount of a rent or service charge statement, which is managed in line with One Manchester’s Service Charge Policy (unless the complaint refers to One Manchester’s failure to follow that policy correctly).
• a claim for damages or personal injury, which will be dealt with as an insurance claim.
• matters where legal proceedings have been started or concluded i.e. where a case has been filed at court and including disrepair claims. For the purpose of this policy, court warning letters or notices to commence legal proceedings will not be considered legal proceedings. 
• matters relating solely to services or decisions outside One Manchester’s control.
• attempts to reopen or reconsider complaints where we have provided One Manchester’s final decision in accordance with this (or any predecessor) Complaints Policy or other relevant policy.
• demoted tenancy appeals.
• an anonymous report where the reporter will not provide a name and/or address meaning we cannot respond to them. Depending on the issue, One Manchester may still investigate outside this policy. 
• complaints by non-customers (although depending on the issue we may still investigate outside this policy).
• where the issue that is the subject the complaint took place more than twelve months ago (however we will apply discretion to this where there are good reasons for the delay in raising the complaint).

2.4 One Manchester will not treat service requests as complaints. A service request is a request from a customer requiring action to be taken to put something right, for ex-ample a request for a repair, reporting a neighbourhood issue or anti-social behaviour. We record service requests separately to complaints, and we monitor and reviews them regularly. If a service request is not dealt with appropriate, the customer can raise this as a formal complaint under this policy.
2.5 If an issue is raised with One Manchester which is not appropriate to deal with under this policy, we will write to the person raising the issue explaining why it cannot be considered under this policy and signposting them to other sources of assistance where appropriate. A person raising an issue with One Manchester which is not taken forward under this policy has the right to raise the issue with the Housing Ombudsman Service, details of which are given in section 7.

3. POLICY STATEMENT

3.1  One Manchester aims to increase its customer satisfaction by resolving complaints confidentially, promptly and fairly in a consistent manner, and to achieve continuous improvement by recording and reviewing areas of our services which cause dissatisfaction amongst One Manchester’s customers and learning from this feedback. 
3.2 The objectives of this policy are:

• To enable One Manchester to identify when something goes wrong and take appropriate action to put it right.
• To ensure that complaints are dealt with confidentially, courteously, systematically, fairly, reasonably and consistently.
• To promote a positive, no-blame approach complaints handling culture within One Manchester and with our customers.

To enable One Manchester to learn from our mistakes or services failures to improve our services, processes and systems for the benefit of our customers.

3.3 Through applying this policy, One Manchester will ensure that:

• Customers’ complaints are acknowledged, recorded and monitored, and responded to.
• Multiple complaints (for example on the same or a similar service area, from the same geographic area or from the same customer) can be responded to collectively and consistently, where appropriate.
• A customer making a complaint is kept informed of progress about their complaint at each stage, and how we are dealing with it.
• We keep customers informed of their rights of redress at each stage and their right to refer to the Housing Ombudsman’s Service as explained in section 7.

4. HOW TO CONTACT US

4.1 We want One Manchester’s complaints process to be easy and accessible. Customers and their representatives can tell us about their issues in a variety of ways:

• Digitally, via One Manchester’s website, 
• By email at complaints@onemanchester.co.uk
• By telephone on 0330 355 1000
• In person, at our drop-in’s across our areas (details of these including opening times and accessibility information can be found at Neighbourhood Hubs.
• In writing, to One Manchester’s Complaints Team at Lovell House, Archway 6, Hulme, Manchester, M15 5RN

Through a representative or an advocate (before we can investigate complaints raised this way, we will need to confirm that the person on whose behalf the representative or advocate say they are acting has nominated them to do so).

4.2 Complaints can be raised with any of One Manchester’s colleagues and our contractors, including our Chief Executive, and our board members, and they will be dealt with in accordance with this policy.
4.3 If a customer is struggling to make their complaint and would like some help to do so, we can offer extra support and guidance. We will also make other reasonable adjustments to enable a customer to fully access the complaints process in consideration of their needs. We urge customers to contact us using the methods outlined in section 4.1 to discuss any support needs or reasonable adjustment requirements they may have with us.
4.4 We will make sure that all One Manchester colleagues handling complaints receive appropriate training on dealing with these effectively and compliantly with this policy, and that they are empowered to address and resolve complaints appropriately.

5. COMPLAINTS PROCESS

5.1 We aim to resolve customer complaints promptly and our timescales for doing so are explained later in this policy. 
5.2 Sometimes it may not be possible for One Manchester to respond fully to a complaint within these timescales. We will always keep a customer raising a complaint informed if we can’t meet our stated timescales, including as to the reasons for this and which parts of their complaint it affects. We will advise them when a response can be expected and we will keep them informed at regular intervals, if the customer would like us to.
5.3 Our complaints process provides two opportunities for One Manchester to resolve customers’ complaints: ‘stage 1’ and ‘stage 2’. Customers are also free to refer their complaint to the Housing Ombudsman at any point during or after stage 1 or stage 2 if they are not satisfied with what we are doing about it, as we explain in section 7.

5.4  Stage 1 – Investigation

5.4.1 Should we not be able to respond to a service request when a customer first tells us about it, they can raise a Stage 1 complaint with us. They can do this using any of the methods set out in section 4.1 above and to any of our colleagues or contractors.
5.4.2 To process a complaint in accordance with this policy, we will need the following information:

• The customer’s full name and address
• Details of their complaint
• Copies of any correspondence or documents relating to their complaint
• How they wish their complaint to be resolved 

5.4.3 We will log a Stage 1 complaint raised with us on our system, and we will respond to the customer to acknowledge it within 5 working days from the date of the complaint being made. We will also confirm or explain:

• Any information we need to progress the complaint but don’t yet have, including that set out in section 5.4.2 above.
• If the complaint or any part of it falls outside the scope of this policy (as we explain in section 2.3 above), why we cannot take it forward.
• If we believe we need to engage with the customer in a particular way to provide reasonable adjustments to meet their needs.
• If we need to manage our engagement with the customer in relation to their complaint.

5.4.4 We will then investigate the complaint with the service area it relates to. This may include contacting the customer:

• To confirm we understand their complaint properly.
• To confirm the outcomes that they are seeking.
• If we need any clarification of any issues or areas that are unclear. 
• To check the customer is content with any alternative response timescales we need to propose (if we cannot respond to the complaint in our stated response times below).
• If the complaint has been raised by a representative of a customer, to confirm with the customer whether that person has been designated by them as their representative.    

5.4.5 We will provide the customer with a full written formal stage 1 response within 10 working days from the acknowledgement date of the complaint. This will explain, in clear plain language:

• That this is a stage 1 complaint.
• What the complaint is about.
• What our decision on the complaint is and the reasons for it.
• What remedy we are offering (if any) to put things right (if necessary).
• What the outstanding actions are, if there are any, and our plan for completing these (including by when).
• How the customer can escalate their complaint to stage 2 should they wish to do so, and/or to seek advice from the Housing Ombudsman’s Service as we explain in section 7. 

5.4.6 If it is not possible, because of the complexity of the complaint or for another good reason, for One Manchester to fully investigate and respond to the complaint within the 10-working day period, we may need to extend the response deadline. If this needs to happen, we will write to the customer to explain why this is the case and the extended timescale for responding to them with our stage 1 response. Any extension will be for a maximum of 10 further working days and in that situation we will provide our stage 1 response, covering the points above, no later than 20 working days from the date of our acknowledgement of the customer’s complaint. When we write to a customer to inform them of an extension we will remind them of their rights to refer their complaint to the Housing Ombudsman’s Service as explained in section 7.
5.4.7 Very occasionally, it may not be possible for us to meet an extended response period for a stage 1 complaint, for example if the complaint is complex and/or we need to work with external organisations to investigate it. In that case we will write to the customer to explain this and to let them know when we expect to be able to complete our stage 1 response. We will remind them of their rights to refer their complaint to the Housing Ombudsman’s Service as explained in section 7.
5.4.8 Because we will let the customer know the answer to the complaint as soon as we have it, this means that follow-up actions required to remedy the complaint may take place after our stage 1 response has been issued. Our stage 1 response will include an action plan explaining what follow-up actions are required and when we anticipate they will be completed by. 
5.4.9 If a customer raises additional complaints during the stage 1 investigation, we will incorporate these into our stage 1 response if they are related and the stage 1 response has not been issued yet, as long as this won’t unduly delay our stage 1 response. If it will result in a delay, or if the stage 1 response has already been issued, or the new issues raised are unrelated to the issues already being investigated, the new issues will be logged as a new complaint and dealt with in accordance with this policy.
5.4.10 If a customer is not satisfied with the outcome of stage 1, they can escalate the complaint to stage 2 and/or refer to the Housing Ombudsman’s Service for further advice as we explain in section 7.

5.5 Stage 2 - Review

5.5.1 If a customer is not satisfied with the outcome of One Manchester’s response to a stage 1 complaint or any follow-up actions, they can request a formal review of their complaint by a “stage 2 escalation”. Stage 2 is One Manchester’s final response.
5.5.2 A stage 2 escalation request must be made within 12 months of the date the stage 1 complaint was first made (although, as with a stage 1 complaint, One Manchester may use its discretion to accept a stage 2 escalation request falling outside this period where there are good reasons).
5.5.3 Examples of when a customer may want to make a stage 2 escalation request include:

• If all or some of the points raised as part of the complaint have not been investigated or responded to in stage 1 or where the customer feels the outcome in the stage 1 response is wrong or unfair.
• If all or some of the agreed actions have not been carried out within the specified timescales or carried out to a less than satisfactory standard. 
• If One Manchester has failed to respond to the complaint within the published timescales as set out in this policy including any notified additional time.

These are just examples, and customers are not obliged to provide a reason for wanting to escalate their complaint to stage 2. 
5.5.4 One Manchester may only refuse to consider a stage 2 escalation request where it falls within the circumstances set out in section 2.3 of this policy. If the stage 2 escalation request is rejected, we will write to the customer within 5 working days of the stage 2 escalation request providing an explanation of our decision. This will be the final response from One Manchester and the end of our internal complaints process, although the customer has the ability to refer their complaint to the Housing Ombudsman for further advice as we explain in section 7.
5.5.5 We will log a Stage 2 escalation request raised with us on our system, and we will respond to the customer to acknowledge it within 5 working days from the date of the stage 2 escalation request being made. We will also confirm or explain to the customer:

• If we are not clear, what part of the original complaint has not been resolved properly, and how we can help to resolve it?
• If the complaint or any part of it falls outside the scope of this policy (as we explain in section 5.5.4 above), why we cannot take it forward.
• If, following stage 1 or on the basis of any further information we have, we believe we need to engage with the customer in a particular way to provide reasonable adjustments to meet their needs, or in accordance with section 9, and in either case this is different to what we did at stage 1.
• To check the customer is content with any alternative response timescales we need to propose (if we cannot respond to the stage 2 escalation in our stated response times below).
• If we are not clear, we will also seek to confirm the outcome that the customer is seeking from the stage 2 escalation.

5.5.6 A senior member of our management will review the stage 2 escalation. This will be someone who has not previously been involved with the complaint. 
5.5.7 We will provide the customer with a full written formal stage 2 response within 20 working days from the acknowledgement date of the stage 2 escalation request. This will explain, in clear plain language:

• That this is a stage 2 escalation and review.
• What the complaint is about.
• What our decision on the complaint is and the reasons for it.
• What remedy we are offering (if any) to put things right (if necessary).
• What the outstanding actions are (if any) and our plan for completing these including by when.
• How the customer can escalate their complaint to the Housing Ombudsman’s Service should they wish to do so. 

5.5.8 If it is not possible, because of the complexity of the complaint or for another good reason, for One Manchester to fully investigate and respond to the stage 2 escalation within the 20 working day period, we may need to extend the response deadline. If this needs to happen, we will write to the customer to explain why this is the case and the extended timescale for responding to them with our stage 2 response. Any extension will be for a maximum of 20 further working days. In that situation we will provide our final written response, covering the points above, no later than 40 working days from the date of our acknowledgement of the customer’s complaint. When we write to a customer to inform them of an extension we will remind them of their rights to refer their complaint to the Housing Ombudsman’s Service as explained in section 7.
5.5.9 Very occasionally, it may not be possible for us to meet the extended response period for a stage 2 complaint, for example if the complaint is complex and/or we need to work with external organisations to investigate it. In that case we will write to the customer to explain this and to let them know when we expect to be able to complete our stage 2 response. We will remind them of their rights to refer their complaint to the Housing Ombudsman’s Service as explained in section 7.
5.5.10 Because stage 2 is a review of One Manchester’s stage 1 response, it is not possible to add additional complaints (not previously raised at stage 1) to the stage 2 escalation. New complaints will therefore be logged as a new complaint and dealt with in accordance with this policy.
5.5.11 Because we will let the customer know the outcome to their stage 2 complaint as soon as we have it, this means that follow-up actions required to remedy the complaint may take place after our stage 2 response has been issued. Our stage 2 response will explain what follow-up actions are required and when we anticipate they will be completed by. We will track these actions and keep the customer informed of our progress against them. 
5.5.12 If a customer is not satisfied with the outcome of stage 2, they can refer it to the Housing Ombudsman’s Service for determination as we explain in section 7.

6. REMEDIES

6.1  Where something has gone wrong and it’s One Manchester’s fault, we will look to provide an appropriate remedy. We will aim to return the customer to the position they would have been in had there not been a service failure, taking account of the fact that it did occur. We accept that in some cases, this may not be possible so we will carefully consider what other actions can be taken to put matters right. 
6.2 The remedies we may consider could include:

• an apology
• an acknowledgement where things have gone wrong 
• an explanation, assistance or reasons 
• taking action, if there has been a delay
• reconsidering or changing a decision
• amending a record or adding a correction or an addendum
• providing a financial remedy (in accordance with our Compensation Policy)
• a review of policy and procedure or practice
• additional training for colleagues.

There may be others that are appropriate, on a case-by-case basis.
6.3 One Manchester may (at its discretion) offer a remedy at any stage of the complaints process. If a customer is dissatisfied with a remedy offered (including the amount of any financial remedy), they can raise this as a stage 2 escalation.
6.4 We may ask customers who have been involved in the complaints process to participate in an optional customer feedback exercise upon closure of the complaint, so we can learn from our customers’ experiences of our complaints process and identify any improvements we can make.

7. INDEPENDENT HOUSING OMBUDSMAN

7.1 Customers have the right to refer their complaint to the Housing Ombudsman before, at any point during, and/or after taking it through this complaints policy. 
7.2 The Housing Ombudsman can provide advice and support to customers in relation to complaints. It can review complaints referred to it and launch its own investigations. 
7.3 Customers can reach the Housing Ombudsman in the following ways:
Via its website, 
By post: Housing Ombudsman Service PO Box 152, LIVERPOOL L33 7WQ
By telephone: 0300 111 3000 (lines are open Monday to Friday 9:15 to 17:15)

8. UNACCEPTABLE BEHAVIOUR

8.1 We understand that circumstances leading to a complaint can sometimes be stressful and upsetting. We do not view behaviour as unacceptable just because someone is assertive or determined, but in a minority of cases, people can pursue their complaints in a way that is unreasonable. This section explains how One Manchester will deal with the very few occasions where this issue arises.
8.2 We have grouped the behaviour we consider to be unacceptable into two broad headings:

• Aggressive or abusive behaviour which causes our colleagues to feel afraid, threatened or abused, for example threats, physical violence, personal abuse, derogatory or discriminatory remarks, rudeness and inflammatory statements and unsubstantiated allegations. Reports of this type of behaviour will be investigated and managed under our Unacceptable Actions and Behaviours Policy.
• Unreasonable demands that impact substantially on our work due to the amount of information that a customer seeks or provides, the nature and scale of the service they expect, or the regularity or amount of approaches or complaints they make. For example, asking for a response in an unreasonable timescale, insisting on communicating with a particular colleague, continual phone calls, emails or letters, repeatedly changing the substance of the complaint or raising unrelated concerns, refusing to co-operate with the investigation or review while still requesting their complaint to be resolved, persistent refusal to accept a decision, persistent refusal to accept explanations relating to what One Manchester can or cannot do, or continuing to pursue complaints on the same subject without presenting any new information. The way in which these customers approach us may be reasonable, but their persistent behaviours are not.

8.3    We do not want to exclude anyone from being able to access our complaints processes, but where a customer is behaving in an unreasonable way, we may need to take steps to manage how we engage with a customer regarding their complaint. 
8.4    How we manage unreasonable behaviour will depend on the nature and extent of it. Steps we may take, including separately or in combination, may include:

• Restricting or managing the method by which the customer contacts us, or we contact them, in relation to their complaint;
• Restricting or managing the frequency of contact we have with a customer regarding their complaint;
• Changing the person dealing with a complaint to another of our colleagues.

There may be other approaches that we need to take, depending on the circumstances.
8.5 Where we need to manage unreasonable behaviour in relation to a complaint and a customer, we will inform them of this in accordance with this policy. A customer who is dissatisfied with a decision by One Manchester under this section 9 can escalate this to a stage 2 complaint and/or seek advice from the Housing Ombudsman as explained in section 7.  

9. EQUALITY IMPACT ASSESSMENT 

9.1 An Equality Impact Assessment (EIA) has been completed and assessed.
9.2 The EIA found that One Manchester will ensure that this policy is applied fairly to all our customers. 
9.3 We will not directly or indirectly discriminate against any person or group of people because of their race, religion, gender, marital status, sexual orientation, disability or other grounds set out in our Equality, Diversity and Inclusion Policy. 
9.4 We offer opportunities for complaints to be made in different ways that are convenient or accessible to complainants and we offer help in accessing the process if it is needed. 
9.5 All decisions will be based on evidence and facts so they are free from bias and impartial. 
9.6 All decision letters will clearly set out the reasons for the decision and any further action to be taken.
9.7 Access to this policy is via One Manchester’s website. The website has Browse Aloud which reduces barriers between content and all our audiences. The support software adds speech, reading and translation facilitating access and participation for people with dyslexia, low literacy, English as a second language and those with mild visual impairments. Online content can be read aloud in multiple languages using the most natural and engaging voice to transform the user’s reading experience. This facility enables us to comply with the Equality Act 2010. 
9.8 This policy and its implementation should not have an adverse effect on any particular group however it is recognised that certain people could find it more difficult to make a complaint - people with a disability including mental health conditions and learning difficulties, those with dependents/caring responsibilities and those lacking confidence or unwilling to approach us themselves. If requested, we will help a customer to put their complaint in writing. 

10. MONITORING AND REVIEW OF THIS POLICY

10.1 Compliance with this policy shall be monitored by the Head of Customer Experience, who oversees the Customer Resolution Centre, Complaints, Customer Voice, and Customer Experience.
10.2 The Complaints team oversees the complaints process and checks complaint responses before they are sent to customers.
10.3 One Manchester will appoint a Member Responsible for Complaints from its governing board, and details of the Member Responsible for Complaints will be published on the website. 
10.4 An annual Complaints Performance and Service Improvement report will be shared with our Board and published on our website 
10.5 This policy shall be reviewed annually.
10.6 The Head of Customer Experience will be responsible for initiating a review of this policy and shall report to Place Committee with any recommendations for all improvements required.

11. CONTACT PERSON

11.1 The Head of Customer Experience is the contact person for this Policy. Managers and other colleagues involved in complaint resolution have responsibility for the effective de-livery of this policy.

12. ASSOCIATED POLICIES AND DOCUMENTS

12.1  Internal Documents:
12.1.1 Unacceptable Actions and Behaviour Policy
12.1.2 Compensation Policy
12.1.3 Anti-Social Behaviour and Hate Crime Policy
12.1.4 Equality, Diversity and Inclusion Policy
12.1.5 Whistleblowing Policy
12.2 External Documents:
12.2.1 Equality Act 2010
12.2.2 Landlord and Tenant Act 1985
12.2.3 General Data Protection Regulations 2016
12.2.4 RoSH Tenant Involvement and Empowerment Standard
12.2.5 The Housing Ombudsman’s Complaint Handling Code