The Guinness Partnership Limited (202309736)

REPORT

COMPLAINT 202309736

The Guinness Partnership Limited

29 November 2024

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

1. The complaint is about the landlord’s:
   1. Handling of leaks, repairs, and damage to the resident’s property and possessions.
   2. Handling of alleged unauthorised alterations and installations to the plumbing and electrics to the property.
   3. Complaint handling.

Background

2. The resident is an assured tenant in a 2-bedroom mid-terrace house and her tenancy started in March 2021. She lives in the property with her adult relative who has autism.
3. The resident raised her stage 1 complaint on 17 March 2023. She told the landlord that she had been dealing with ongoing water leaks at her home for over 2 months. Although planned, repairs had not been completed and after repeat discussions with her family doctor, she had compiled a letter to stress the urgency of moving her case along. She told it that her relative was autistic and their wellbeing had been severely affected since the issue occurred in her home. She said this was further contributed to due to a lack of end date for the issues to be resolved.
4. The resident wrote to the landlord again on 15 April 2023 and said there had been multiple “devastating” water incidents that occurred at her property between 16 December 2022 and 11 March 2023. “The failures” left her property in a dangerous condition with water destroying her flooring, damaging her walls and floorboards, missing ceilings, and almost causing fires twice in the property as water had got into the electrics. She was only warned about the fire due to a fire alarm system that alerted her to the problem and their ownership of fire extinguishers to extinguish the smoking in the plugs. She provided a summary of events between December 2022 and April 2023.
5. The landlord provided its stage 1 response on 15 June 2023. It explained her complaint, and the reported damage to her property. It said:
   1. When she reported the leak in December 2022 and the damaged ceiling, it attended as an emergency to rectify the fault. It returned on 11 January 2023 to reinstate her ceiling.
   2. On 19 January 2023, she reported that the loft had started to leak again. When its contractor visited to assess the problem on 30 January 2023, they found that alterations had been made to the electrics which had not been completed by either it or its contractor. It isolated multiple circuits and disconnected some from the fuse board to ensure her safety.
   3. On 4 March 2023, she reported another leak from an unknown source. It attended to complete an emergency repair within 24 hours. It then returned on 8 March 2023 and 21 March 2023 to fully rectify the fault and install a new socket for her washing machine. It also replaced the dryline box for the fan isolator in the kitchen.
   4. On 5 April 2023, it returned to redecorate the hallway and bedroom ceilings. She reported another leak on 3 May 2023, this was fixed on the same day. During its recent visits it completed investigative work to try to identify the cause of the repeated leaks.
   5. Its engineers found changes to the electrics and plumbing that had not been completed by it or its contractors. Therefore, it was difficult to establish what was causing the issue within her home and where the liability lay. It had replumbed her entire home including her heating system, both systems were pressure tested and its subcontractor recommissioned the boiler.
   6. It thanked her for providing her break down of costs and explaining her personal distress since the time she reported the leak.
   7. Where a water leak caused loss or damage to personal possessions, it would be responsible for paying compensation only if it was at fault. As alterations had been made to the plumbing and electrics without prior consent from it, it had not been able to confirm the cause of the leak and had not identified evidence to confirm that the leak was caused by its actions or inactions.
   8. It understood that she was currently working with it to have further repairs completed to her home. Those works included reinstatement works following the replumbing of her home, various electrical works, and an agreed list of items she had presented to it.
   9. To complete the works, it understood that she was required to move out of the property for 2 weeks. It was working through options suitable for her and it acknowledged that she recently reported a fire at the property. The fire brigade had attended, and it was thankful no one was injured. It understood how distressing this was for her.
   10. It was investigating the cause of the fire but so far it was inconclusive. It reiterated that during recent visits it had found electrical changes to the property and no evidence of compliance with electrical regulation had been provided. It explained the importance of all electrical works being completed by qualified persons and signed off accordingly. It told her that any property alterations were also required to receive permission from it before taking place.
   11. It would not uphold her complaint as it had attempted to repair the leak, but as it had found alterations that it did not carry out, it was difficult to resolve. Whilst her complaint was not upheld it wanted to apologise for the delay in responding.
   12. It failed to acknowledge or respond to her complaint within its timescales and there were further delays to complete its investigation whilst she waited for the outcome of the repair inspection. It apologised for any increased frustration and offered her compensation of £100.
6. The resident asked for her complaint to be escalated on 17 June 2023. She said:
   1. Its contractors did attend to rectify the original loft fault but failed to truly identify the root cause. She would not know until the winter if the action taken after 3 month of the leak from the loft actually resolved the issue.
   2. The water pipes that continuously burst between March 2023 and May 2023 were situated between the floorboards and lower ceilings which were completely sealed at the time. As such it was not logically possible for her or her relative to have interfered with them as it suggested.
   3. It was established on 7 March 2023 by a plumber, that the inserts in the connections to some of the pipes were missing from the original construction of the house. They said this should be further checked due to the high likelihood of others being missing. This was not acted upon, and the result was that when one area was repaired, it put pressure on the next area resulting in many burst pipes (the resident said she reported at least 7 episodes of this, 2 of which flooded her home. Only 1 of these had occurred when she initially complained to the landlord).
   4. Two months later after the near destruction of the house from the burst pipes, endless call outs and the distress it caused, the plumber was approved to replace the entire plumbing. This solved the water issue but only after causing considerable damage and distress. Being told she caused this was “beyond despicable” given what she had gone through.
   5. Other serious issues were occurring due to the previous ingress of water and the humidity caused by a heatwave at the time. The property had continued to decay and remained ignored by the landlord.
   6. It said a ceiling had been reinstated on 11 January 2023 but failed to acknowledge the previous “reinstated ceiling” fell onto her disabled relative on Christmas day in 2022 whilst they were sleeping (the same way the first collapse occurred on 16 December 2022). Her relative was physically hurt and terrified. This was after 2 weeks of staring into the open hole caused by the initial collapse, and she stated the stress was “unbelievable”.
   7. The concerns with the electrics were caused by water damage. There were promises of a full electric check following one of its contractors blowing the main fuse box and a new one being installed at the end of January 2023. The check was not completed despite one of its surveyor’s also requesting it in March 2023 and her repeated requests. This was although it was aware of the continuous water ingress into the electrics and the high volume of damage/frayed cables from original installation by the builder causing problems.
   8. These were only a few inaccuracies and there were comprehensive records of all the events. She also provided another document with a summary of other issues.
   9. It had contacted her over 2 weeks prior, but no suitable accommodation had been found for the decant. She was still living in the property which was very unsafe, and no repairs of any kind had occurred since 15 May 2023 despite having an electrical fire on 19 May 2023.
7. The resident then brought her complaint to the Ombudsman on 18 June 2023. She explained the situation with the leaks in the property, fires, and the landlord’s actions. She also provided the Ombudsman with contemporaneous records.
8. The landlord provided its stage 2 response on 7 July 2023. It said:
   1. It had found no failure in how it responded to her repair requests, and the delay with the repairs was due to the volume of work required to resolve the problems caused by the unauthorised alterations.
   2. It found alterations continued to be made within her home after it began carrying out repairs. This hindered its efforts and caused further delays.
   3. In addition, the alterations it found did not meet regulations and had been a danger to her and her home. It needed to move her and her relative into temporary accommodation so it could return the property to the condition it was in prior to the issues occurring.
   4. It was responsible for a delay with 1 repair where she advised that the loft insulation was not removed for several weeks. Its records indicated that the loft insulation was replaced within four weeks, but the felt roof vents were yet to be installed. It would address this when it began repairs on 17 July 2023 and apologised for the delay.
   5. Having completed its review it found that her complaint was partially upheld for the delay with the installation of felt roof vents.
   6. It apologised for her overall experience and the distress caused to her. It offered her £250 as an apology for the delay with the installation for the felt roof vents.
   7. It had discussed the complaint internally and feedback would be provided to the relevant team, and they would work to improve the level of service provided.
   8. It confirmed repairs were scheduled to begin on 17 July 2023. She would be kept updated on the timeline for the completion of the repairs.
9. The resident disputes the events in paragraph 8(b) and 8(c). Namely, that of alterations being made.

Assessment and findings

Scope of investigation.

10. The resident has raised concerns about the impact of the situation on her health, and physical injuries caused to her relative. The Ombudsman is unable to draw conclusions on the causation of, or liability for, any impact on health. Personal injury claims, must, be decided by the court as they can consider medical evidence and make legally binding findings. However, the Ombudsman will consider the general distress and inconvenience the situation may have caused the resident as well as the landlord’s response to any reported impact on her health.
11. The resident has raised concerns with another fire following the completion of works on her property in September 2023. The landlord has responded to this as part of a stage 1 response on 27 September 2023 in a separate complaint. The Ombudsman has also not been provided with any evidence that this has exhausted the landlord’s complaints process. As such the Ombudsman will only consider the resident’s complaint between March 2022 and July 2023.

Handling of leaks, repairs, and damage to the resident’s property and possessions.

12. The tenancy agreement places responsibility for maintenance of the roof, drains, gutters and external pipes on the landlord. It states it must keep in repair and proper working order any installation it provides for heating, water, heating, sanitation, supply of water and electricity in the home. This includes smoke alarms, and wastepipes. The resident made numerous reports of leaks and issues with the electrics in the property, between December 2022 and May 2023. This included issues with the smoke alarms. The landlord took prompt action to try to make safe and resolve the issues with the property in line with its obligations under the tenancy agreement. It raised emergency appointments and attended to most of the repairs within the timescales in its policy and this was appropriate. It also raised works for an electrician to complete a full test of the electrics following the reports of water entering them in January 2023. Where it failed to meet its repair obligations, it acknowledged this within its complaint response, which was also appropriate.
13. The landlord also took temporary action such as the provision of dehumidifiers to aid with drying out the property. It offered to temporarily decant the resident from the property on at least 2 occasions whilst it completed necessary works. For example, after her reports of a leak in January 2023 which caused the electrics to be waterlogged. Its operatives were unable to resolve the issue and it had caused a lack of heating and hot water. It decanted the resident between 15 July 2023 to 29 July 2023, while it completed works to the property. It took appropriate action and considered the vulnerabilities of the household when reflecting on the actions it needed to take to allow it to complete the necessary repairs and making the required safeguarding referrals.
14. It is unclear when the landlord provided the resident with the dehumidifier. She identified that she had to replace the dehumidifier as it stopped working in March 2023. However, it is unclear whether she approached the landlord to explain the situation prior to purchasing a new one. She also said that she had incurred additional electrical and heating costs due to having to run a dehumidifier 24 hours a day as well as heating her relatives room due to the missing ceiling. The landlord’s stage 1 response states that it had been difficult to establish were liability lay for the damage to the property. It should have demonstrated that it considered that it may also have been responsible for some of the damage through the reported defect. As such, it should have considered the potential additional costs to the resident and whether it was responsible for providing her with any redress. It has not demonstrated that it has, and this was unreasonable.
15. There were issues with the landlord’s communication. This can be seen around its actions on 16 December 2022 where the resident reported the ceiling collapse. The landlord’s notes say that it was a job to make safe and the resident stated that it attended on the same day took photographs, commented on the damage, and left. Its records also do not reflect that it completed any works on that day. The landlord has not demonstrated that it explained to her why it did not take any action, or that the ceiling remained safe despite it not completing any work. Its communication around this was unreasonable and caused the resident frustration and distress. Its records however then show that it raised works to the ceiling on 17 December 2022 and attended to complete the job on 19 December 2022. It did not provide dates of completion for several of the emergency repairs raised within its repair records. For example, a ceiling assessment on 19 December 2022. If the works could not be completed for any reason, an explanation should have been provided. It also failed to clearly explain why it had not met the 24 hour timeframe in its policy and this was unreasonable.

16. It is unclear if/why the landlord waited 3 days to make safe the electrics as the job description of 16 December 2022 included this as part of the required works. It has provided no explanation to suggest that it believed the electrics were in a safe state to mean no immediate action was required, or that it made them safe on 16 December 2022. It also has not demonstrated that it explained to the resident why no works were completed/ there was a delay in it acting around this and this was unreasonable. This inevitably contributed to the resident’s frustration with the situation. Although there is evidence to suggest that the landlord did complete the repairs, it must ensure that it provides appropriate clear dates to show that it met its obligations within a reasonable timeframe, and in line with its policy. Its failure to ensure it kept appropriate records of the repairs may have affected its service provision to the resident, due to the delays evidenced in it taking the necessary action and communicating with her. This would inevitably have contributed to the distress faced by her.
17. The landlord’s records show that the resident reported a lack of heating or hot water due to a total loss of power on 20 January 2023. The landlord attended on 20 January 2023, to repair the electrics but was unable to carry out the repair. its records confirmed that on 21 January 2023 and 22 January 2023 works were raised. An electrician was required to attend a water leak to a socket to the electric boiler. This was completed on 23 January 2023. Additional work orders were also raised on 28 January 2023 and 29 January 2023 for water getting into the electrics and tripping them. It said these works were completed on 30 January 2023. These were further appropriate actions taken by the landlord and in line with its policy around emergency repairs.
18. Due to the repeated nature of the issues, and the safety concerns, it would have been good practice for the landlord to have demonstrated that it completed risk assessments around the issues. For example, following the resident’s reports of the second leak on 20 January 2023 and continuous power trips until 27 January 2023. Although it took appropriate action, a risk assessment would have allowed it to tailor its approach more to the overall situation. It would also have allowed it to reassure both itself and the resident that the property remained safe for habitation.
19. The resident advised that she tried to contact a member of the landlord’s staff in January 2023 but did not receive a response until March 2023. She also explained she tried to contact them several times and received no further response. The landlord has not demonstrated that it kept the resident updated on what was occurring around the issues. This raises concerns with the landlord’s communication with the resident. The landlord should have agreed an action plan with the resident on how/ when it would complete the repairs. This could have informed its approach on any other temporary considerations it could take around the leaks and electrics. This would also have allowed it to agree a communication frequency with her and would have been an effective tool in managing her expectations. Having clear communication and actions would have allowed the resident to have confidence in the landlord and its approach. It is acknowledged that an action plan was put in place. However, this was in relation to managing her relative’s behaviour to stop the unauthorised alterations whenever it completed the repairs. The risk assessment and action plans could have been revisited when the resident raised new concerns with the leaks. They may have contributed to a prompter investigation into the root cause of the issues and allowed for timeframes around communication to be explained.
20. The landlord first began to suspect that unauthorised alterations had been made at the property in December 2022. It identified in March 2023 that there was a defect in the installation of the plumbing when the property was initially constructed, and this may have contributed to the repeated leaks. It completed an emergency attendance in relation to the leaks on 3 May 2023 and another on 5 May 2023. The landlord advised it believed there were related to the resident’s relative’s alterations of the pipework within the property. It then decided to replace the plumbing in May 2023, after its emergency attendance. It confirmed that it had begun works to resolve the leaks on 17 July 2023, and the full replumbing was not completed until 5 September 2023, 4 months after it initially decided to do so.
21. It is acknowledged that the landlord was entitled to try to effect other solutions it believed may have rectified the situation before deciding to replace the plumbing. However, the situation had been ongoing for a prolonged period of 5 months, and its attempts at fixing the issue did not work as it kept reoccurring. It has not demonstrated that it considered other options such as replumbing the property sooner and this was unreasonable. Although a surveyor had attended in March 2023, there is no evidence this informed its approach around the plumbing works. The failure to take prompt action to finding a permanent solution to this concern caused the resident frustration, and inconvenience as she had to keep reporting leaks. The landlord provided no information on how it categorised the works, (e.g. responsive repairs, or planned works). This would have allowed it to manage her expectations on the length of time it would take for the works to be completed. It also has not shown that it provided the resident with any explanation of this, or why it continued to repair the pipework rather than replace it.
22. The tenancy agreement states that the landlord would insure the home and any fixtures and fittings that belonged to it. It also says that residents are responsible for insuring the contents of their home and their belongings. The evidence suggests that the resident first reported that damage had been caused to her belongings on 15 April 2023. As some of the damage may have been caused by the potential defect during the construction of the property (missing inserts with the plumbing), the landlord should have advised the resident about any potential insurance claims she could make. This would have been to both its insurer and her own contents insurance, and its failure to do so was unreasonable. This would have allowed an independent party to identify if there was any liability on the landlord’s part.
23. Following the landlord’s visit to the resident’s property, an email was sent internally on 15 May 2023 with findings around alterations being made to the plumbing works. A comment was made about the potential for another leak due to these which was inappropriate and raises further concerns with the landlord’s communications. The Ombudsman noted that the tone of one of the email about the alterations and leaks was unprofessional. Whilst not aimed at the resident or her family, its email could be seen as it failing to take the matter seriously, and it may want to be mindful in future of its comments. When communicating to or about resident’s a landlord has a duty to remain professional and courteous. The failure to do so in this instance was unreasonable.
24. The resident had reported concerns about an electrical fire at her property on 19 May 2023. She advised in an email on 21 May 2023 that there had been other similar issues and her concerns about the tripping electrics. The landlord discussed internally on 23 May 2023 that it was unable to complete any further repairs at the property until an action plan was in place with the resident. This was due to the continued unauthorised alterations after it completed any works. The Ombudsman acknowledges that the landlord was considering more permanent action it could take around the situation. It, however, has not demonstrated that it informed the resident why it was not acting. It also could have shown that it took consideration about how to temporarily resolve the situation to ensure the residents’ safety and this was unreasonable. This raises further concerns with the landlord’s communication and would have caused the resident frustration due to a perceived lack of action.
25. The tenancy agreement states that residents must not tamper with or damage electricity supplies, or any other equipment provided by the landlord. It states that all electrical work must be done by a registered professional and inspected by it. Due to the repeated electrical issues in the property, the resident requested a full rewire. The landlord had identified that there had been several unauthorised, and potentially dangerous alterations and installations added to the electrics. It had also identified alterations to the plumbing. It believed that these may have contributed to the issues with the electrics, leaks, and fire in the property. The landlord advised internally on 23 May 2023 that it may require a partial rewire of the property. It then confirmed in separate correspondence to the resident on 27 September 2023 that it had appropriately completed a total rewire of the property. It advised the Ombudsman on 18 July 2024 that this was completed on 4 September 2023 and 5 September 2023. This was a reasonable and responsible approach for the landlord to take to bring the property back to a safe electrical standard.
26. The resident raised concerns with the length of time taken by the landlord to decant her from the property. The Ombudsman appreciates that the landlord may have had limited appropriate stock available meeting the resident’s requirements. This was also dependent on factors outside of its control such as availability of suitable accommodation from other sources. The landlord has however, not demonstrated that it kept the resident informed around progress or that it explained the reason why it needed 3 weeks to decant her, and this was unreasonable.
27. From the resident’s initial reports on 16 December 2022, the landlord’s records demonstrate that it finished all the required works on 5 September 2023. This represents a timeframe of over 7 months. However, the issues with the leaks in this case were complex to identify, and the landlord demonstrated that it was proactive in its attempts to get the issues rectified. Whenever it attended to complete works, new issues would then occur which were often outside of its control and affected progress of the repairs.
28. In summary, whilst the landlord acted appropriately in some of its actions, there were still some issues with its handling of the matter. There were issues with its communication with the resident and record keeping of the repairs. It did not demonstrate that it had considered the additional costs incurred to the resident around heating and electricity. It also failed to explain to the resident why it had not acted following the fire in her property in May 2023. It also did not explain about any potential insurance claims either to its buildings insurance or her own contents insurance. Based on this the Ombudsman finds that there was maladministration. The landlord apologised for the resident’s overall experience and the distress caused to her. It offered the resident compensation of £250 for the delays installing the roof vents. Whilst this goes a way in addressing its failings, this was only in relation to 1 aspect of its handling of the situation. An order has been made for additional compensation of £200 to be paid to the resident for the frustration, distress, and inconvenience caused to her around its handling of the issue.

Handling of alleged unauthorised alterations and installations to the plumbing and electrics to the property.

29. The landlord’s alterations policy states that where it identifies unauthorised alterations to a property it will investigate. Unauthorised alterations can be discovered because of a repair visit, and where it does discover such concerns, it will determine if the works pose a health and safety issue. Where it could satisfy that the works had been completed in line with building regulation conditions and/or any planning conditions, it would grant permission. It would also grant permission where it was satisfied that the standard of work was acceptable. A letter would then be sent to the resident identifying whether permission was granted or if the property needed to be returned to its original condition.
30. After discovering the alterations during its repair visits, the landlord appropriately communicated with the resident. It told her that she needed to remove any unapproved alterations from the property, and explained where it believed she should complete a retrospective permission request to request permission for some of the items. It also asked her to provide electrical safety certification and details of service schedules. It explained where no permission had been granted for alterations and said where there were concerns of safety. It identified that the works had been completed by an unqualified person, and this informed its decision on why it would not be granting permission. It acted appropriately, in line with its policy around the discovery of the alterations, the actions it took and its consideration around where permission should be granted.
31. The tenancy agreement states that if residents want to make alterations to their home, they must first obtain permission in writing, and this included adding to fixtures and fittings or anything it had installed. It states that residents are responsible for improvements, alterations or additions made by them or those acting on their behalf. The landlord’s operatives attended in May 2023, observed, and found alterations had been made to the electrics and plumbing in the property. They also found that electrical installations had been fitted such as a commercial fire detection system, emergency lighting, a “sprinkler system”, and security alarm, amongst other alterations. The resident applied for retrospective permission after the landlord requested that she either did this or remove the items.
32. The operatives that attended and made the assessment that there had been alterations to the electrical and plumbing system were skilled professionals and suitably qualified in their trade. The landlord was entitled to rely on the professional opinion and observations of its operatives in reaching its decision that unauthorised and potentially unsafe alterations had been made.
33. The Ombudsman acknowledges that the resident stated in her correspondence to the landlord that the items were installed due to a fear for her health and safety. However, it remained reasonable for the landlord to require an application for the works, and to consider if permission could be granted as required by the tenancy agreement.
34. Once the landlord identified that there were unauthorised alterations, it then explained they had to be removed or retrospective permission was required. It then provided the resident with the opportunity to request retrospective permission which was appropriate.

Complaint handling.

35. The landlord’s complaints policy states that it will acknowledge a complaint within 2 working days and provide its stage 1 response within 10 working days of it being logged. If an extension was required, this would not exceed a further 10 working days unless agreed by the parties. It would explain the reason for the delay to the resident. The resident raised her complaint on 17 March 2023 and a response was due on 31 March 2023. The landlord did not respond until 15 June 2023. This represents a delay of 52 working days. It has not demonstrated that it requested an extension or kept the resident updated about the delays and this was unreasonable. This would have added to the resident’s frustrations with the landlord.
36. The landlord apologised for the delay in its complaint handling and offered the resident £100 for the delay. The Ombudsman considers this to be reasonable redress for the delay and frustration faced by the resident around the landlord’s complaint handling.

Determination (decision)

37. In accordance with paragraph 52 of the Housing Ombudsman’s Scheme there was:
    1. Maladministration with the landlord’s handling of leaks, repairs, and damage to the property.
    2. No maladministration with the landlord’s handling of reported unauthorised alterations and installations to the plumbing and electrics to the property.
    3. Reasonable redress with the landlord’s complaint handling.

Orders

38. Within 4 weeks of this report the landlord must:
    1. Provide the resident with an apology for the failings identified within this report.
    2. Pay the resident compensation of £450 broken down as:
       1. £250 previously offered within its stage 2 response for the installation of the roof vents. If this has not been paid already, this is to be paid directly to the resident.
       2. £200 for its handling of the leaks, repairs, and damage to the property. This is to be paid directly to the resident.
    3. Review its repairs log and identify if any of the repairs relating to the complaint remain outstanding. The landlord must meet with the resident to ensure that it logs align with her understanding of any outstanding repairs. If any repairs do remain outstanding, provide the resident with a schedule of works and timescales for the completion of the works.
    4. Speak with the resident, identify what her additional electrical and heating costs were for the periods when the ceiling was missing, and the length of time she ran the dehumidifier. It must then refund any reasonable costs identified. This is not to include the additional costs of purchasing a dehumidifier.
    5. Support and provide the resident with the necessary information on making an insurance claim around any losses faced to her possessions as a result of any damage caused by the leaks.
    6. Provide proof of compliance with these orders.

Recommendation

39. If not already paid, pay the resident the £100 offered in its stage 1 response for its complaint handling failing. This must be paid directly to the resident.