Reasonable Adjustments Policy

1. At One Manchester, our vision is to create inclusive, connected, and sustainable places where people can thrive and live well.  We aim to deliver this through our Inclusive Access Strategy. Our purpose is anchored in providing good quality homes, great services, and real opportunities for our customers and communities.
2. This commitment extends to ensuring that our customers, especially those facing vulnerabilities, are supported to live well and thrive within our neighbourhoods and are treated with fairness and respect.
3. This Policy is our guiding approach to nurturing a community where inclusivity and tenancy sustainability are not just ideals but lived realities to ensure that customers that need additional support feel comfortable explaining this to us, and that we can provide equal services.

1. This Policy supports our vision and purpose that all customers have equal access to our services, and no-one is put at a disadvantage for any reason.  This policy does not seek to explain how we will approach every situation, it is intended as a general statement of our policy and:
   1. Confirms our commitment to improving inclusive access to all our customers.
   2. Sets out some of the basic principles of our commitment to provide reasonable adjustments for customers that require additional support to access our services.
   3. Sets out the factors that we will take into account in dealing with requests for reasonable adjustments.
2. We recognise the importance of promptly identifying those who require additional services, ensuring they have the access and assistance needed to maintain their tenancy. This proactive approach is crucial in fostering a supportive and inclusive environment for all members of our community.
3. This Policy is intended to help all colleagues to understand and put into practice the duty placed on One Manchester to make reasonable adjustments to remove or reduce those barriers, including attitudinal and communication barriers, which can place vulnerable customers at a disadvantage when accessing our services.
4. It defines what a ‘reasonable adjustment’ is, in what type of circumstances we’ll make them, and how customers can request them.  It should be read with our Inclusive Access Strategy, which sets out how we’ll support our customers with vulnerable needs and explains how we define, assess, and record vulnerability to meet customers’ needs, when necessary.
5. This Policy is in accordance with:
   1. The Housing Ombudsman Service’s Complaints Handling Code
   2. Our duty under the Equality Act 2010
   3. Our duty under the Equality Act 2010

1. The scope of this Policy extends to all services provided by One Manchester to its customers whether directly or where we have contracted out our landlord services to a third party. Additionally, it applies to members of a customer’s household where a vulnerable household member impacts on their ability to sustain their tenancy. 
2. The Policy is relevant to a diverse range of housing types owned and/or managed by One Manchester. 
3. Our Aids and Adaptations Policy sets out how we will provide adaptations to help customers continue to live independently in their home. An adaptation is an alteration or addition to a property, the installation of equipment or specialist equipment, to support someone’s ability to live independently. Adaptations are beyond the scope of this Reasonable Adjustments Policy although some “aids” may be captured as a reasonable adjustment as defined here. Colleagues must refer to both policies when requests for “aids” are made by or on behalf of customers.

1. The Equality Act 2010 (the Act) protects the rights of individuals and to advance equality of opportunity for all.  Under the Act the legal duty to make reasonable adjustments arises in three circumstances:
   1. Where there is a provision, criterion or practice which puts a person at a substantial disadvantage
   2. Where a physical feature puts a person at a substantial disadvantage
   3. Where a disabled person would, but for the provision of an auxiliary aid, be put at a substantial disadvantage
2. In addition, One Manchester acknowledges and understands that not all our customers with vulnerable needs have a disability and so we have extended the duty to provide reasonable adjustments to those customers who consider themselves as being vulnerable.
3. Customers will be asked to disclose whether they, or any household members, have any additional needs at the start of their tenancy. Customers are encouraged to state their needs whenever possible, and to assist with this, One Manchester will ensure any data on our customers is kept securely and that a judgement-free culture is fostered throughout the organisation.
4. In pursuit of our vision and purpose, One Manchester’s offering aligns with the latest Consumer Standards and Expectations and any related Code of Practice issued by the Regulator of Social Housing. We ensure that our services, communications, strategies, policies, procedures, and functions effectively acknowledge, understand, account for and react to the diverse needs of our customers, especially those who are vulnerable.  
5. The Equality and Human Rights Commission advises on the following when deciding whether an adjustment is ‘reasonable’ or not: 
   1. Effectiveness - The adjustment should be designed to fully address the disadvantage it is meant to overcome. For example providing an audio version of documents may not properly overcome the barriers faced by the customer if there are other requirements that need to be overcome, for example the customer also has a hearing impairment.
   2. Practicality - For example it may not be possible for One Manchester to provide additional time to customers if there are legislative deadlines to meet. 
   3. Resources - Resources - For an adjustment to be reasonable, it should be effective. However, it is important to remember that is an adjustment which is deemed effective, may not be considered reasonable. For example resourcing is not just about the cost, but it may involve other factors, for example recruiting additional staff with specific skills. If an adjustment costs a significant amount, it is more likely to be reasonable to make the adjustment, if the organisation has substantial financial resources 
   4. Potential Disruption to One Manchester’s service - For example, it would not usually be reasonable for a Neighbourhood Officer to cease work on all other cases and devote all of their time to one customer, as others will inevitably suffer. The amount of extra time provided must therefore be ‘reasonable’ in all the circumstances.

1. One Manchester recognises that vulnerability is a dynamic and multifaceted, influenced by a variety of factors and life events. Our approach to defining vulnerability encompasses individual customers or households experiencing difficulties in daily living and those who may require additional support for various reasons to sustain their occupancy. To aid in accurately identifying and understanding these vulnerabilities, we have developed an Appendix : Factors in Identifying Vulnerability. This Appendix is specifically provides a set of indicators ranging from personal characteristics to life experiences. Its inclusion is integral to our commitment to recognising the diverse and sometimes subtle manifestations of vulnerability. By doing so, we aim to ensure that our services are responsive and effectively tailored to the diverse needs of our customers.
2. Vulnerability can arise from a multitude of factors, including but not limited to age, disability, mental health issues, bereavement, financial instability, or a lack of social support. It may also be related to life events such as hospital discharge, homelessness, or experiences of sustained illness. We will never assume that whole groups are inherently vulnerable and work with our customers on a case-by-case basis.
3. We assess vulnerability on an individual basis or sometimes situational basis, recognising that it can be temporary, permanent or fluctuating. Support provided by One Manchester, or through referrals to external agencies, is tailored to the level of vulnerability and the specific circumstances of each customer or household.
4. Our definition and approach to vulnerability is guided by our overarching commitment to inclusivity and empowerment. We ensure that our policies and services not only recognise vulnerability but also foster independence and resilience among our customers.  Further guidance can be found within the Appendix to this Policy.
5. At One Manchester, we recognise that vulnerability often presents in varied and subtle ways, and identifying it is crucial to providing effective support. We expect our colleagues to be vigilant of signs of potential vulnerability through their interactions with our customers, whether in person, over the phone, or via digital communications. This includes noticing changes in behaviour patterns like irregular rent payments, lack of engagement, or signs of distress during home visits. We also rely on insights from our contractors and collaborations with external agencies, who often provide critical information about customers’ circumstances. By maintaining a vigilant and empathetic approach across all levels of interaction, we aim to identify and address the needs of our vulnerable customers promptly and compassionately, ensuring no one is overlooked.

1. One Manchester will let customers know that we can provide reasonable adjustments 
   
   for example in the following ways:
   1. Through our Tenancy Experience Visits.
   2. By including a paragraph in written communications (e.g. acknowledgement letters)
   3. By asking whether a reasonable adjustment might be required over the telephone
   4. By including a note on our published documents indicating that we can provide the document in an alternative format on request 
   5. By publishing this policy on our website
   6. By working with key representatives groups and others to raise awareness of this policy
2. A reasonable adjustment can be requested from One Manchester in the following ways:
   1. By the customer themselves, either by speaking to their Neighbourhood Officer, the Customer resolutions Centre or using our online services.
   2. By referral from a local authority or other relevant agency
   3. By a family member when we’ve been given permission for them to do so and/or
   4. A colleague may suggest for one to be made, when they’re aware it will support the customer’s needs.
3. In some cases, we may seek advice from expert organisations that can assist with signposting and other forms of support.

1. The responsibility for the effective delivery of this Policy lies with the Neighbourhood, Customer Experience and CRC Teams. They play a pivotal role in ensuring that the Policy's provisions are translated into practical and impactful actions on the ground. 
2. Every colleague at One Manchester is obligated to adhere to this Policy in their daily operations. This includes understanding the Policy's principles, applying them in their interactions with customers, and contributing to an environment that supports and respects the needs of vulnerable customers. 
3. We commit to providing training to all colleagues , equipping them with the knowledge and skills required to support all customers effectively. This training will cover areas such as understanding vulnerability, making reasonable adjustments, and applying empathy in service delivery. 
4. A key aspect of implementation involves enhancing our systems to capture and manage data on customer vulnerability accurately. This includes ensuring that colleagues who need access to this data are equipped to use it responsibly and effectively.

1. An Equality Impact Assessment (EIA) has been completed and assessed.
2. The EIA found that One Manchester will ensure that this Policy is applied fairly to all our customers that fall within it. We will not directly or indirectly discriminate against any person or group of people because of their race, religion, gender, marital status, pregnancy or maternity, sexual orientation, disability or other grounds set out in our Equality, Diversity and Inclusion Policy.
3. Access to this Policy is via One Manchester’s website. The website has Recite Me 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. 

1. The Leadership Team holds the responsibility for monitoring the performance, effectiveness, and outcomes of this Policy. This oversight ensures that the Policy's objectives are being met and that it continues to effectively address the needs of vulnerable customers. 
2. The Policy will undergo an annual review to ensure its adequacy in meeting its stated aims and relevance in the current context. This review process is crucial for maintaining alignment with any changes in legislation, regulation, or shifts in the social housing landscape that could impact our duties and obligations towards vulnerable customers.
3. Every three years, or sooner if required by business needs or changes in legislation or regulation, a fundamental review of the Policy will be conducted. This comprehensive review will assess the Policy's structure, content, and implementation to ensure it remains robust and fit for purpose.
4. The effectiveness of the Policy will be evaluated using specific metrics, including: 
   1. Reduction in the number of tenancy issues and evictions involving vulnerable customers. 
   2. Feedback from vulnerable customers on their experience and satisfaction with housing services. 
   3. Analysis of case studies and incidents to identify trends, areas of success, and improvement opportunities.
5. Feedback from customers, employees, and external partners will be actively sought and incorporated into the review process. This ensures a holistic understanding of the Policy's impact and areas for enhancement.

• Inclusive Access Strategy
• Anti-Social Behaviour and Hate Crime Policy
• Adaptations Policy
• Adult Safeguarding
• Child Safeguarding
• Allocations Policy
• Compensation Policy
• Complaints Policy
• Condensation, Damp and Mould Policy
• Equality, Diversity and Inclusion Policy
• Reasonable Adjustments Procedure
• Repairs Policy
• Starter Tenancy Policy
• Tenancy Management Policy
• Income Management Policy
• Gas Safety Policy
• Fire Safety Policy
• Electrical Safety Policy

1. Our Policy aligns with relevant legislation and regulatory standards set by the Regulator of Social Housing, ensuring our practices are compliant and effectively cater to the needs of vulnerable customers.
   1. Humans Rights Act 1998
   2. Equality Act 2010
   3. Regulator of Social Housing Consumer Standards
   4. Consumer standards Code of Practice
   5. The Housing Ombudsman’s Complaint Handling Code 2024

This Appendix provides a framework for identifying potentially vulnerable customers. It is important to note that the presence of these factors does not automatically imply vulnerability, but they serve as indicators to be considered in understanding each resident's unique situation.

• Age-related Factors: Including older people (especially those over 75 years), andyoung adults (16-21 years).
• Physical and Mental Health: Including residents with disabilities, chronic health conditions, or mental health challenges.
• Social and Economic Factors: Including refugees, asylum seekers, care leavers, lone parents under 21, and ex-service personnel.
• Family Dynamics: Families with disabled children, carers, or those experiencing terminal illness.

• Cognitive and Developmental Conditions: Including learning disabilities, Autism Spectrum Disorder, or age-related cognitive impairments.
• Mobility and Frailty: Customers themselves or household members with impaired mobility or frailness due to age or health conditions.
• Communication Barriers: Customers with limited literacy, English language skills, or communication challenges.

• Housing Instability: Including a history of homelessness, transitioning from supported accommodation, or living in temporary housing.
• Traumatic Experiences: Including bereavement, experiences of abuse or harassment, domestic violence, or recent discharge from institutional care. 
• Health and Well-being Challenges: Including recent hospitalisation, sustained physical or mental illness, addiction, or substance abuse.
• Socioeconomic Challenges: Facing multiple debts, fuel or food poverty, or significant changes in family circumstances such as pregnancy or bereavement.

• Transitional Phases: Including recent immigrants, ex-prisoners, or ex-service personnel returning from conflict zones.
• Educational and Social Challenges: Families with children facing educational challenges or social exclusion.

This Appendix aims to provide a comprehensive and flexible framework to assist One Manchester in identifying and responding to the vulnerabilities of our customers, ensuring that our approach is inclusive, empathetic, and responsive to the diverse needs of our customers.