North Tyneside Council (202430789)

REPORT

COMPLAINT 202430789

North Tyneside Council

21 May 2025

Our approach

The Housing Ombudsman’s approach to investigating and determining complaints is to decide what is fair in all the circumstances of the case. This is set out in the Housing Act 1996 and the Housing Ombudsman Scheme (the Scheme). The Ombudsman considers the evidence and looks to see if there has been any ‘maladministration’, for example whether the landlord has failed to keep to the law, followed proper procedure, followed good practice or behaved in a reasonable and competent manner.

Both the resident and the landlord have submitted information to the Ombudsman and this has been carefully considered. Their accounts of what has happened are summarised below. This report is not an exhaustive description of all the events that have occurred in relation to this case, but an outline of the key issues as a background to the investigation’s findings.

The complaint

The complaint is about the landlord’s response to the resident’s reports of damp and mould.
The Ombudsman has also considered the landlord’s handling of the associated complaint.

Background

The resident holds a secure tenancy with the landlord which started in 2023. The property is a 2-bedroom house. The resident has complex post-traumatic stress disorder (PTSD), long COVID, and asthma. The landlord has a record of these vulnerabilities.
In February 2024, the resident had a replacement kitchen and bathroom fitted by the landlord. Within 2-3 weeks of completion, in March 2024, he contacted the landlord to report his kitchen floor tiles were lifting and requested for it to attend to investigate this further.
The landlord arranged for its contractor to carry out a survey which was completed in April 2024. The contractor’s report confirmed the presence of damp and mould in the property. It noted there were several signs of a severe damp issue which would require extensive work in both the kitchen and bathroom to rectify.
The resident made a complaint to the landlord on 1 May 2024. He said:
1. There were previous signs of damp in the property, which he believed the landlord had concealed and not inspected properly before he moved in.
2. Within 3 weeks of the kitchen and bathroom installation, the floor tiles were bubbling and lifting. Damp had also started to appear through the new plasterwork and there were tide marks on the walls.
3. The landlord had attended to strip the floor tiles and screed, leaving the kitchen and bathroom floors in a poor condition. This made it difficult for him and his family to use these areas safely.
4. He had been told further work to the kitchen and bathroom floors would be required. He had concerns and questions about what the actual issue was, how long the work would take, and what the outcome would be.
5. He was concerned he would be left with no access to cooking, washing or toilet facilities.
6. The ongoing issues were impacting his and his young children’s quality of life and exacerbating his health conditions.
7. He did not feel he should be paying rent for a property that was not fit for purpose.
8. He requested to be rehoused, and for the landlord to give him Band 1 priority so that he could look for a habitable home for him and his children.
On 17 May 2024, the landlord provided its stage 1 response. It advised its records which dated back 7 years showed no previous reports of damp at the property. The landlord said it was not upholding the resident’s complaint as it had “acted immediately instructing a survey and recommended remedial works required”. It confirmed damp and mould had been found in some areas of the property by the contractor and cited this as being “common” when there was condensation present. It said the resident would need to be decanted into temporary accommodation so that remedial works could be completed. The landlord made a recommendation to the resident to make a housing application but said the information he had provided “would not warrant a Band 1 priority”.
The resident escalated his complaint on 18 May 2024. He said:
1. He was told in the landlord’s stage 1 response that the cause of the damp issues in the property was condensation. He said this contradicted what he was told by its contractor, who said the property had rising damp.
2. He questioned why a decant was required if the issues in his property were caused by condensation.
3. He felt prior inspections for damp had not been carried out adequately.
4. He had requested a copy of the damp survey report twice but had not received this.
5. He requested a schedule of remedial works required at the property.
6. He wanted a permanent move to a different property to reduce the disruption for him and his family. He asked for the landlord to put him back on the bidding site in an elevated banding.
7. He asked the landlord to consider a rent reduction as he had been living in substandard conditions since his floor was ripped up.
On 11 June 2024, the landlord provided its stage 2 response. It partially upheld the complaint on the basis that the damp survey report had not been provided to the resident. It did not uphold the other elements of the complaint. It apologised for not sending the survey report when requested and enclosed a copy with its response. It said a rent reduction would not be applied but stated an amount had recently been written off the resident’s rent account. It did not provide a schedule of remedial works, but it did say that he needed to be decanted. It stated work had been provisionally scheduled for late August 2024, as this was the contractor’s earliest availability, and was expected to take 3 weeks. The landlord advised it would be in contact with the resident to confirm the exact date and discuss further.

Events since the end of the landlord’s complaints process

The landlord responded to an email from the resident on 17 June 2024 and agreed to his request to escalate his complaint to stage 3. It advised it would share his request with the complaints manager and get back in contact with him. On 8 November 2024, the landlord responded to a further email from the resident. It apologised for misleading him and stated it should have checked when his complaint was registered before confirming it would progress to stage 3. The landlord stated it was keen to progress the repairs and offered for a senior officer to make further contact with him.
The resident escalated his complaint to the Ombudsman on 12 November 2024. He said:
1. The situation remained unchanged, and he and his family were still living in the property with rising damp.
2. This was continuing to exacerbate his physical and mental health conditions.
3. After the initial damp survey, nothing had been done by the landlord, and it had not followed through with the actions set out in its stage 2 response.
4. The landlord had agreed to progress his complaint to stage 3 but upon making further contact, it confirmed it had closed his complaint, which he had not been aware of.
As an outcome, the resident told us he would like the landlord to apologise. He also requested for it to give him priority banding so that he could move to a different property. In addition, he asked the Ombudsman to consider awarding compensation for the landlord’s handling of his damp and mould reports.
The landlord has provided evidence of further correspondence with the resident since the end of the complaints process. In January 2025, the resident was given the option of a temporary decant, direct let to another suitable property, or to be assessed and accepted onto the housing register enabling him to bid on properties. The resident chose the latter option. The landlord has stated that the resident has had an active housing application since this time but has made no bids on any alternative properties.

Assessment and findings

Scope of the investigation

The resident said that the landlord’s handling of the damp and mould impacted his health. We are not medical specialists, so we cannot assess whether something caused an impact to health or not. The resident may choose to seek independent advice regarding this aspect or consider a claim through the landlord’s liability insurance or the courts. While we cannot determine impact on health, we have considered the impact of any failings by the landlord. This includes any distress and inconvenience caused to the resident.
In his complaint to the landlord, the resident asked to be moved permanently and to be given additional priority due to the extensive remedial works required to his property. The allocation of local authority housing stock in England is governed by Part 6 of the Housing Act, which sets out the circumstances in which reasonable preference must be given to certain applicants. The Local Government and Social Care Ombudsman (LGSCO) can review complaints regarding applications for rehousing that fall under Part 6. This includes complaints regarding the applicant’s banding, or priority. Any concerns the resident has specifically about his rehousing request are better suited to the LGSCO. Therefore, this part of the resident’s complaint will not be included within the scope of our investigation.

Reports of damp and mould

The tenancy agreement confirms the landlord’s statutory repair responsibilities under Section 11 of the Landlord and Tenant Act 1985. It states that the landlord is responsible for keeping in repair the structure of the property.
The landlord’s condensation, mould and damp (CMD) policy was published in November 2024. This was after the landlord had issued its final response to the resident. However, in its response to our information request, the landlord has advised that the content and details of its CMD policy would have been applicable at the time of the resident’s complaint.
Its CMD policy states it will “support and work with our tenants to ensure that their homes remain safe, healthy, and affordable to live in”. The landlord states it will respond to moisture related issues in a “timely manner”. It says it will record all moisture related repairs and attempts to contact tenants. Where remedial works are required, it says it will provide temporary accommodation or consider rehousing the household on a permanent basis. Permanent rehousing will be considered by the landlord in conjunction with supporting and relevant medical information.
The landlord’s website says it offers three repair priorities (emergency, urgent and routine). It says it aims to complete all appointed repairs within 30 working days.
Landlords are required to keep a property secure and safe using a risk assessment approach called the Housing Health and Safety Rating System (HHSRS). Both damp and mould and falling on level surfaces are hazards that fall within the scope of HHSRS. HHSRS does not set out any minimum standards, but it is concerned with avoiding or minimising potential hazards.
The Homes (Fitness for Human Habitation) Act 2018 says that rented properties must be “fit for human habitation” on the day of letting and throughout the tenancy. This means they must be safe, healthy and free from defects that could cause harm. This includes ensuring that the property is in a good state of repair, has no signs of damp or mould growth, and is structurally sound.
The resident has highlighted concerns that the landlord was aware that there were damp issues in the property prior to him moving in in June 2023. The Ombudsman does not dispute the resident’s claims. However, our findings must be based on documentary evidence. The landlord’s repair records dating back to 2022 do not indicate any previous reports or knowledge of damp issues at the property. Our investigation will therefore focus on the events following the resident’s first report of a potential problem on 18 March 2024.
The landlord has provided evidence which shows it first responded to the resident’s reports of damp and mould affecting his property on 23 April 2024, when its contractor attended to complete a damp survey. This was 23 working days after the resident had initially reported his concerns regarding the tiles lifting in the kitchen. This would be considered a “timely” response in line with its CMD policy and published repair information. It was reasonable and appropriate of the landlord to arrange for its contractor to complete a specialist damp survey. This showed that it was taking the resident’s concerns seriously and it was committed to identifying the cause of the damp.
The contractor’s report states at the time of its visit, the landlord was in the process of removing self-levelling screed from the kitchen floor. This suggests the landlord had taken steps prior to 23 April 2024 to mitigate the risks from the lifting tiles, which was reasonable in the circumstances. However, it is not clear from its records what work had been carried out and when. This points to a record keeping issue.
The contractor’s survey report identified the following:
1. There was moisture staining to the kitchen/living room partition wall. Bridging was identified by the surveyor as the main form of dampness.
2. There were salt deposits in the concrete sub-base of the kitchen floor, likely due to the absence of a damp-proof membrane beneath the concrete floor. An escape of water was also identified from the stopcock located beneath the kitchen sink unit.
3. There was salt affected wall plaster on the kitchen/rear entrance partition wall. Bridging was identified by the surveyor as the main form of dampness.
4. There was condensation in the front entrance caused by moisture in the air. Black spot mould growth was also identified, which could be associated with condensation or rainwater ingress.
5. There were salt deposits at a low level in the front entrance, which confirmed the passage of water through the building fabric.
The contractor included a scope of works and a quote within its report, outlining what was required to remedy the issues identified. This included excavating and renewing the concrete flooring in the kitchen and bathroom, installing a damp proof course, hacking off existing plaster, and replastering. Several recommendations were also identified within the contractor’s report, as follows:
1. It noted a damp proof course had been installed in the property previously. It recommended for the landlord to contact the original installers to enquire regarding the extent of the work and any guarantees that may have been issued.
2. It noted an isolated area of dampness at low-mid level to the right-side external elevation with a high damp reading. It recommended for the landlord to open the cavity for further inspection.
3. It noted mould growth on the tongue and groove flooring in the front entrance with a high moisture meter reading. It recommended for the landlord to arrange a further inspection of the suspended timber floor.
There was no contact from the landlord to the resident between the completion of the survey on 23 April 2024 and its stage 1 response on 17 May 2024 to advise what the outcome of the survey was and the plan of action for remedying the issues. The resident had said in his complaint on 1 May 2024 that he had concerns and questions following the damp survey and was concerned he would be left without basic facilities. It appears the resident was not aware he would need to be temporarily decanted until the landlord advised him of this in its stage 1 response. This was unreasonable of the landlord, as it should have updated the resident at the earliest opportunity rather than waiting to formally respond to his complaint. This delay added to his uncertainty and distress.
In its stage 1 response letter, the landlord said, “damp was found in some areas, along with black spot mould, which is common with condensation in a property”. It also enclosed a condensation leaflet with its response and said a temporary decant had been agreed. This demonstrates that it failed to assess the actual findings of the survey report, which pointed to a severe damp issue in the property rather than an issue arising from condensation alone. This was unsatisfactory and undermined the resident’s concerns.
The Ombudsman’s spotlight report on damp and mould (published in October 2021) states that landlords should “share the outcomes of all surveys and inspections with residents to help them understand the findings and be clear on next steps”. Despite the survey report being available at the time, the landlord did not provide the resident with a copy or include details of the report’s findings within its stage 1 response. This resulted in a lack of clarity for the resident on what the actual issue was, and the work required to put it right. In turn, this led to a repeat request in his complaint escalation for a schedule of remedial works and copy of the damp survey report.
The landlord did send the resident a copy of the survey report with its stage 2 response. This was 7 weeks after completion of the survey and there was no explanation for this delay, which was unsatisfactory. The delay added to the resident’s uncertainty, as well as causing him avoidable inconvenience, time and effort to try to get the issues resolved. The landlord should have provided the resident with a clear outline of the issues identified and a plan of action for repair at an earlier stage. If it had done so, it may have alleviated some of his concerns, which may have enabled it to resolve the complaint earlier in the process. Proactively sharing the report would also have demonstrated an open and transparent approach.
On 20 May 2024, 18 working days after the damp survey, the landlord instructed its contractor to carry out the remedial works to the property. It requested a start date and confirmation of the duration of works. The Ombudsman notes that the delay in raising works was not excessive. However, it is unclear why the works were not raised immediately given the seriousness of the findings within the survey and the complaint raised by the resident on 1 May 2024.
In emails exchanged between the landlord and the contractor, the contractor confirmed the scope of works required and gave a provisional start date of 27 August 2024. It advised work was expected to take until 17 September 2024. The landlord did request if the contractor could bring this forward due to the complaint and stated the decant facility was not available in August, but the contractor said this was their earliest available date. The Ombudsman recognises that the landlord did what it reasonably could to bring the remedial works forward, but as it required a specialist contractor, the delay was unavoidable.
The landlord’s records show it did not respond appropriately to potential hazards caused by the damp issues. Under HHSRS, the landlord is required to consider whether any damp and mould in its properties amount to a hazard and require remedying. While it did instruct the remedial works, which was a positive step, there is no evidence in the landlord’s records to suggest that it acted upon the further recommendations from the contractor outlined in paragraph 26. This is concerning given the potential hazards identified. Black spot mould was also found in certain areas of the property at the time of the damp survey. However, there is no evidence that the landlord tried to mitigate the potential risks from this while it was waiting for the remedial works to commence. It could have considered completing a mould wash, for example, particularly given the resident’s health conditions, of which it was aware.
A further hazard the landlord is required to assess under HHSRS is falling on level surfaces. The resident was clear in his complaint to the landlord on 1 May 2024 that he was concerned about the condition of the kitchen and bathroom floors after operatives had attended to strip the floor tiles and screed in these areas. He said he had been left with a “dusty, damp, uneven and jagged edged floor”. He told the landlord that this was making it difficult for him and his family to use these areas safely. The resident reiterated his concern in his complaint escalation on 18 May 2024, stating he had been living in “substandard living conditions” since his floor had been ripped up. The landlord did not specifically address these concerns in either of its complaint responses, which was a failing. While waiting for the remedial works to commence, it also did not take steps to mitigate the effects of the poor condition of the floor, which was a potential hazard.
Given the extent of the remedial works required at the property, it was appropriate for the landlord to offer a temporary decant to the resident. However, given the circumstances, this should have been offered sooner rather than on commencement of the remedial works. The landlord was aware on completion of the damp survey on 23 April 2024 that there was a severe damp issue in the property, and it was also aware of the resident’s health conditions. By not offering an immediate decant, the landlord failed to adequately assess the resident’s circumstances, vulnerabilities and the impact of the situation on his household.
The Ombudsman’s spotlight report on damp and mould states, “Where extensive works may be required, landlords should consider the individual circumstances of the household, including any vulnerabilities, and whether or not it is appropriate to move resident(s) out of their home at an early stage.” The landlord did not do this, which was unsatisfactory.
The resident told the landlord in his complaint on 1 May 2024 that he wished to be rehoused due to the damp issues in the property and the impact this was having on him and his family. He requested for it to give him Band 1 priority. The landlord was dismissive of the issue, stating that the resident should exhaust his options with the repairs team before seeking rehousing. It also stated that the information he had provided “would not warrant a band 1 priority”. It did advise the resident to make a housing application but did not offer to support him to do this. This was unreasonable in the circumstances.
In his complaint escalation, the resident said he was willing to move but would rather do so permanently to minimise the disruption caused to him and his family. He asked the landlord to put him back on the bidding site in an elevated banding. The landlord’s stage 2 response did not acknowledge this. On his repeat request, the landlord should have recognised he may have needed support or assistance to complete a housing application, and this should have been offered as part of its response to help to put things right for him. Its omission indicates that it did not sufficiently consider the resident’s individual circumstances and needs.
Given the circumstances of the case, while the landlord was not obligated to permanently move the resident, it should have considered this during the complaints process. Its CMD policy states permanent rehousing is an option where remedial works are required. The landlord should have supported the resident in providing the necessary supporting and relevant medical information so that his request for a permanent move could be assessed in line with the requirements of its policy. By not doing so, this caused him further distress and inconvenience.
A further email was sent from the landlord to the contractor on 20 August 2024 requesting remedial works to be put on hold. It said the resident was not engaging in terms of him being decanted for the duration of the works. The landlord stated in an email to us on 28 March 2025 that an “impasse” was reached as the resident did not want to proceed with the temporary decant and remedial works in August 2024. It said the resident had not indicated differently since this date, and therefore it had not made any further attempts to reschedule the works required. In his communication with this Service in November 2024, the resident said the landlord had not contacted him to discuss a temporary move or the remedial works since it provided its stage 2 response on 11 June 2024.
The Ombudsman has been provided with limited records of communication between the resident and the landlord. When we asked for evidence of correspondence or communication between the parties, the landlord responded on several items that no records were held as many of the conversations had been held verbally or in person. It should have systems in place to maintain accurate records of all forms of communication with its residents (for example, by keeping contemporaneous records of telephone discussions and/or by following up any verbal agreements in writing). The landlord did not keep these records despite its CMD policy stating that it will record all moisture related repairs and attempts to contact residents. This demonstrates that its record keeping was inappropriate.
The landlord’s poor record keeping has hindered our investigation. We were unable to evidence communication between the resident and the landlord regarding the decant and remedial works. There is an apparent discrepancy between the parties’ understanding of the situation, which is concerning, and the remedial works required to the resident’s property remain outstanding. The Ombudsman does not dispute the claims made by either party. However, in the absence of records of communication, a finding has been made based on the documentary evidence provided.
Overall, there were failings by the landlord which have had a significant impact on the resident. At the time of our investigation, he continued to live with a severe damp issue which had been ongoing for 14 months. The loss of full use of his kitchen and bathroom had resulted in a reduction in amenity and enjoyment of his home. In its response to the resident’s reports, the landlord failed to meet its obligations under the Homes (Fitness for Human Habitation) Act 2018 and to mitigate the risks from potential hazards under HHSRS. It failed to communicate clearly with the resident regarding the actual cause of the issue and a plan of action for putting it right. It held information regarding the resident’s vulnerabilities but failed to use it, leading to avoidable distress and inconvenience. Poor record keeping also contributed to the landlord being unable to resolve his complaint through to completion. Considering the above, it is the Ombudsman’s decision that there was maladministration in the landlord’s response to damp and mould.
It is noted that since the end of the landlord’s complaints process, it offered some options to the resident including a further offer of a temporary decant, a direct let to another property, or acceptance on to its housing register to enable him to seek permanent rehousing. This shows an attempt by the landlord to address the detriment to the resident and to put things right, which was reasonable. However, this alone is not considered proportionate to redress the failings identified in this investigation. The landlord does not have a compensation policy, and its complaints policy does not provide any details of the awards it will make in the event of service failure. In the absence of this information, this Service considers a payment of £600 to be appropriate compensation for the failures identified. This is in accordance with our remedies guidance for circumstances where there has been a failure by the landlord in the service it provided which had a significant impact on the resident.
The Ombudsman has recently determined a case for the landlord (case reference 202300165) where record keeping issues were identified. A number of orders were made for this case including the need for the landlord to identify improvements it could make to its processes and practices to ensure accurate record keeping. Therefore, we have not made a further order for record keeping as this has been addressed in a previous determination.

Complaint handling

The landlord published its most recent complaints policy in April 2024, which outlines its 2-stage complaints process. It says it will respond to stage 1 complaints within 10 working days and stage 2 complaints within 20 working days. It states that if something has gone wrong, it will consider a range of remedies which will reflect the impact on the customer. These include an apology, a financial remedy, acknowledging where things have gone wrong, and acting upon any delays.
The Ombudsman’s Complaint Handling Code (‘the Code’) sets out the following:
1. Under section 6, landlords are required to address all points raised in the complaint definition and provide clear reasons for any decisions. They must also ensure any actions outstanding following the stage 2 response are tracked and actioned promptly with appropriate updates provided to the resident.
2. Under section 7, landlords are required to acknowledge where things have gone wrong and set out the actions they have already taken or intend to take to put things right for the resident. They must ensure any remedy offered reflects the impact on the resident, using the Ombudsman’s remedies guidance to support their decision making.
The landlord adhered to the timescales within its policy during the complaints process. However, there were other failures. The landlord’s final response failed to fully address all the points raised in the resident’s complaint escalation and did not go into enough detail regarding the substantive issue of the damp and mould. It did not adequately review the stage 1 response and assess where things had gone wrong at this stage. In doing so, it failed to uphold other elements of the resident’s complaint, which was inconsistent with the evidence. As a result, it did not use its complaints process as an effective tool to put things right.
As a result of not acknowledging the full extent of its failings, the landlord also did not offer adequate redress in its final response. Its complaints policy does state it will consider a range of remedies where something has gone wrong. It attempted to put things right by sending the resident a copy of the survey report he had previously requested and offering an apology. While these were positive steps, we consider it did not go far enough when reviewing the complaint in its entirety. It made no offer of compensation at stage 2, which was insufficient. The landlord should have considered awarding compensation to the resident for the distress, inconvenience, time and trouble it had caused.
In its stage 2 letter, the landlord confirmed this was its final response and advised the resident of the details for the Ombudsman if he remained dissatisfied. However, 6 days later, it responded to an email from the resident and agreed to escalate his complaint to stage 3. This was misleading for the resident, as he was left thinking that his complaint was going to be investigated further. It was not until he chased the landlord, 5 months later, that he realised his complaint had been closed following the completion of stage 2. The landlord should have tracked the outstanding actions following its stage 2 response and provided the resident with updates. It did not do this, and therefore it went unnoticed that the resident had been misinformed.
The Ombudsman notes that the landlord did make some attempt to try to put things right for the resident upon acknowledging its error, by offering for one of its senior officers to contact him to progress the repairs. This was reasonable in the circumstances. However, it must be recognised that the confusion caused a delay in the resident bringing his complaint to the Ombudsman and added to his time, trouble and distress. While it is acknowledged that the landlord had only introduced its 2-stage complaint process in April 2024, this showed a lack of awareness of its new policy, which is unsatisfactory.
Considering the circumstances of the case, it is the Ombudsman’s decision that there was maladministration in the landlord’s complaint handling. The landlord’s complaints policy does not provide any details of the awards it will make in the event of service failure in complaint handling. This Service considers a payment of £150 to be appropriate compensation for the complaint handling failures. This is in accordance with our remedies guidance for circumstances where there has been a failure by the landlord in the service it provided which adversely affected the resident.

Determination

In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration by the landlord in its response to the resident’s reports of damp and mould.
In accordance with paragraph 52 of the Housing Ombudsman Scheme, there was maladministration by the landlord in its handling of the associated complaint.

Orders and recommendations

Orders

The Ombudsman orders the landlord to apologise to the resident for the failings identified in this report. This should be written by a senior member of staff. Evidence of its apology should be provided to the Ombudsman within 4 weeks.
The Ombudsman orders the landlord to pay the resident a total of £750 in compensation within 4 weeks. Compensation should be paid directly to the resident. The compensation is made up of:
1. £600 in recognition of the distress and inconvenience caused by the errors in its handling of the damp and mould.
2. £150 for the complaint handling failures identified.
The Ombudsman orders the landlord to contact the resident to determine whether he wishes to proceed with the remedial works and temporary decant while awaiting his permanent move. Within 4 weeks, it should provide us with evidence of its correspondence with him.
If the resident wishes to proceed, within 4 weeks, the landlord should provide the resident and the Ombudsman with an action plan for completion of the remedial works and timescales for this. This plan should include the scope of works, planned start date, duration of works and temporary decant options.
The Ombudsman orders the landlord to confirm whether it has completed the further recommendations identified in the damp survey, as outlined in paragraph 26. Within 4 weeks, it should provide the resident and the Ombudsman with an update detailing what action it has taken or will take in relation to these recommendations.

Recommendations

It is recommended that the landlord contacts the resident to see if he requires any support or assistance with bidding on alternative properties.
It is recommended that the landlord conducts complaint handling refresher training with its staff, if it has not done so recently. This should focus on its complaints policy introduced in April 2024, its 2-stage procedure, and compliance with the Ombudsman’s Complaint Handling Code.