Contents
- Scope
- Part One: Conduct and Behaviour Standards
- Part Two: Competence Standards
- Contact
- Appendix A – Housing Management Services
- Version control
Scope
This policy only applies to “Relevant Individuals” as defined below. It is not contractual, and we may amend it any time.
Definitions and abbreviations
“CCS” - Competence and Conduct Standard set by the Regulator of Social Housing, and associated regulations, Government Policy Statement, and Directions.
Service Providers - External organisations and self-employed individuals engaged by us to deliver housing management services on our behalf, such as contractors, consultants, agencies, whose services fall within scope of the CCS.
Relevant Individuals (“You”, “Colleagues”) - Employees (includes apprentices and fixed-term employees) of Sovereign Network Group (‘SNG’, ‘us’) and Service Providers, who meet the criteria defined in the CCS. They are defined as:
- Referred to in the CCS as Senior Housing Managers and includes different job titles at SNG, such as Locality Managers: Individuals who are expected to spend the majority (usually more than 50%) of their working time managing delivery of housing management services to the registered provider’s social housing tenants, or that managing delivery of housing management services is an important and substantial aspect of their role.
- Known as Senior Housing Executives in the CCS, but job titles differ at SNG, e.g., Directors and Heads of Service. Individuals who have sole or joint responsibility for the day-to-day management of the provision of services in scope of the CCS. Play a significant role in making decisions about the management of at least 50% of such services. Provide strategic direction and have accountability for housing management services.
- Service Providers who are Relevant Managers (for workers and self-employed individuals), or Relevant Managers within Service Providers (for organisations). Relevant Managers are individuals who fall into the above descriptions of Senior Housing Managers and Senior Housing Executives.
Relevant Individuals do not include:
- Unpaid volunteers
- Individuals within their probation period
- Trades roles
- Back-office management roles such as finance, procurement, human resources (HR), information technology (IT), governance, legal.
- Service Providers who are delivering only one housing management function, e.g., asset management only.
Identifying roles in scope
Examples of functions performed by Relevant Individuals are in Appendix A.
SNG Employees
We will determine which roles at SNG are Relevant Individuals by conducting a qualifications audit, repeated annually to maintain ongoing assurance that all identified roles meet the requirements of the CCS.
We will announce and publish internally the internal roles we identify as Relevant Individuals.
Service Providers
Service Providers are expected to determine themselves if they are in scope of the CCS and which roles working for us fall within this policy. They must provide us with written confirmation this has been done.
Introduction
The purpose of this policy is to outline the steps we will take to ensure that you have the qualifications, skills, knowledge, experience and behaviours required to deliver safe, high‑quality, ethical, and respectful services to customers. It covers the following:
- Expected behaviour and conduct
- How we manage and develop skills, knowledge, experience and behaviours tailored to your role.
- How we maintain learning and development so you can demonstrate appropriate and up to date qualifications, skills, knowledge, experience and behaviours for your role.
- How we review and appraise your performance and manage poor performance.
Part One: Conduct and Behaviour Standards
This section explains the standards of conduct and behaviour we expect from you.
You must always follow all our company policies, code of conduct, procedures, and standards including, but not limited to, the following key areas:
- Customer, safeguarding, and housing management
- Human resources (HR/People) including equality, diversity and inclusion
- Health, safety, and environment (HSE)
- Information technology (IT) and communications
- Finance and procurement
- Data protection
- Governance and risk management.
We expect you to always behave ethically and responsibly, according to our values, policies, and the law. This applies across all locations, all work activities, and all work‑related interactions.
A summary of your key responsibilities is below:
Our values, purpose and vision
Always follow our values, purpose and vision, which are written below. More detail is found on our website and intranet.
Values:
Play your part
Lead by example
Always take action
Committed to customer
Everyone matters
Purpose
Providing good, affordable homes: The foundation for a better life.
Vision
Thriving communities, over generations.
Code of Conduct: Key points applicable to this policy
You must always follow our Code of Conduct; below we summarise key points that are specifically applicable to this policy.
Inclusive, safe, sustainable workplace
- Treat everyone with respect and work collaboratively.
- Use evidence and professional judgement to act promptly, prioritising safety and quality of service.
- Declare, manage and where possible avoid conflicts of interest.
- Maintain professional boundaries at work in all interactions with others.
- Try to resolve minor issues informally where appropriate. Engage constructively with formal processes such as for serious or repeated issues.
- Raise concerns about safeguarding or inappropriate behaviour towards you or others promptly. Use whistleblowing or safeguarding procedures when necessary.
- Challenge or report bullying, harassment, discrimination, victimisation, and inappropriate conduct or behaviour.
Training and continuous improvement
- Complete mandatory training and maintain competence for your role, including membership of professional bodies where applicable.
- Keep your e-learning, skills, and qualifications up to date and act in line with the expectations of your role.
- Aim to continuously improve our processes and seek better ways of working.
- Share relevant information with others, including during appraisals and development conversations, provided that the information is not confidential and can be properly disclosed.
- Give and receive constructive feedback; learn from mistakes and feedback.
Consequences of unacceptable conduct
We comply with legal requirements for your protection and that of others. If you work in a way that’s inconsistent with any of our policies, we’ll investigate and may need to take appropriate action under our Disciplinary Policy (including dismissal in appropriate cases).
Some of the most serious potential consequences for you, particularly if you work in a high-risk job, could be as follows:
Failure to follow Code of Conduct. Warnings, training. Fines, job or income loss. Criminal record, prison. Injuries or even death.
Our customers’ expectations
We gather customer feedback in a variety of ways including customer surveys and customer influence panels. We use this to shape our Code of Conduct, customer strategy, and the service we deliver. Below are examples of the behaviours and actions our customers expect:
Working environment
- Always work safely for everyone
- Treat homes with care and be tidy
Unacceptable behaviour
- Maintain boundaries and behaviour in line with our Code of Conduct
Culture
- Work together with everyone involved to achieve efficient positive solutions
- Have a can-do attitude
Training and resources
- Keep knowledge and skills up to date
- Ask for support or training if needed
Fair treatment
- Be polite, friendly, and approachable
- Listen carefully and with patience
- Be respectful to customers and their homes
- Make decisions and prioritise work fairly
- Understand the emotional impact of issues, e.g. repairs, delays
- Communicate clearly and sensitively
- Be open and honest, e.g., about delays, issues, timescales
- Give accurate information and consistent messages
- Give prompt replies
- Give regular proactive updates with reasons
Resolve problems
- Aim to solve problems
- Resolve issues fully and see it through to the end
- Take responsibility for tasks and own any issues when they arise
- Avoid delays
Continuous improvement
- Seek and listen to customer feedback
- Act to achieve customer satisfaction
Our reputation
- Do what we say we will
- Finish work to a high standard and completely, first time
- Meet timescales or appointment times.
Part Two: Competence Standards
Qualification requirements
You must have, or obtain, the relevant qualifications defined in the CCS.
Prior learning, including apprenticeships, accredited modules and relevant qualifications, will be recognised where they meet the conditions.
If your existing qualification is at the right level but does not fully meet the essential content criteria, you must complete top‑up modules or supplementary training to cover any missing areas. This ensures you achieve required standards.
Top‑ups may be required where qualifications lack components such as:
- Professional practice and ethical decision‑making
- Customer service in housing and tenant engagement
- Equality, diversity and inclusion
- Housing law, regulation and national policy context.
For those identified as Executive Housing Managers, these components include those above and the following:
- Leadership and management in the context of housing management
- Stakeholder engagement and managing relationships in housing management.
We will take reasonable steps to assure ourselves that Relevant Individuals who are, or who work for Service Providers meet the CCS qualification requirements. This may be done through contract management arrangements, progress monitoring visits and requests for appropriate evidence to demonstrate competence and compliance.
Recruitment and onboarding
When recruiting for roles carried out by Relevant Individuals, job descriptions must clearly state the essential qualification, or acceptable equivalents.
In some cases, it may be acceptable to be working towards the qualification, or demonstrate ability and commitment to achieve it by enrolling in the course and making progress to complete it.
Learning and development
Individual learning and development (“L&D”) needs must be tailored to the role and CCS requirements. L&D should be documented, including any qualifications, professional body membership, and Continuing Professional Development (CPD) activities.
SNG Employees
L&D needs will be identified through performance discussions and regular feedback and review sessions (121s), which may include review of service outcomes and key performance indicators (KPIs).
Written development plans will be created to address identified gaps in skills, knowledge, experience, or qualifications.
You will have access to learning opportunities that enable you to achieve the required standards of performance and conduct. Internal training includes technical competencies required for the role and behaviours aligned with our values. We will also provide access to and funding for relevant external training and study courses leading to essential qualifications required for your role.
Service Providers
Relevant Individuals who are, or who work for, Service Providers, must comply with the learning and development requirements of the CCS and provide us with written assurance of how they do this.
Performance
SNG Employees
Performance is monitored at formal bi-annual and annual meetings with your manager, as part of your “My Performance” process. Performance may from time to time be reviewed between these formal meetings, through informal one-to-one conversations with your manager.
The My Performance process includes:
- Setting objectives specific to your role
- Assessing your progress towards objectives
- Creating and maintaining a written personal development plan (PDP)
- Completing and maintaining up to date training
- Giving evidence of essential qualifications, and the demonstration of competence, skills, knowledge and behaviours in line with our values and role requirements.
- Identifying any areas for improvement and taking action to address them if applicable
- Documenting performance and development in the HR system.
Service Providers
Your performance, conduct and behaviour must be regularly reviewed, and you are required to:
- Provide written evidence of essential qualifications
- Keep records of your demonstration of competence, skills, knowledge and behaviours in line with our values and role requirements.
- Complete and maintain up to date training and qualifications and keep records to evidence this.
- Identify any areas for improvement and take action to address them if applicable.
- Provide examples and evidence of compliance on request. We will carry out regular performance reviews relating to Relevant Individuals who are, or who work for, Service Providers, including assessing customer satisfaction, feedback, and complaints information.
Managing poor performance
SNG Employees
Performance concerns will be addressed through a structured performance improvement approach following our Performance and Capability Policy.
Depending on the situation, poor performance management may include:
- Informal conversations
- Action plans with detailed concerns, steps, timescales
- Implementing support
- Training
- Formal meetings.
For possible outcomes, see the non-compliance section of this policy.
Service Providers
If we have performance concerns about Relevant Individuals who are, or who work for, Service Providers, these will be addressed through the relevant contract management and performance review arrangements.
We will normally seek to understand and resolve concerns at the earliest opportunity, working with the Service Provider to support improvement where appropriate.
However, where concerns are serious, repeated, or required standards are not met, we may investigate further and take proportionate action in line with the non-compliance section of this policy and any applicable contractual arrangements.
Monitoring and compliance
This policy will be available on our intranet for colleagues, and on our website for customers and third parties, including Service Providers.
It may be reviewed and updated from time to time, for example if there are relevant legal, regulatory, or organisational changes. As part of the review process, stakeholders will be consulted, including customers and colleagues.
Customers are given the opportunity to scrutinise and influence this policy through consultation during policy development and review, or they may give feedback and insight to inform improvements at any time, either directly, or through customer panels or forums.
Compliance with this policy will be monitored using:
- Training and qualification records
- Internal audits
- Contractor performance reviews
- Customer feedback and satisfaction measures, such as engagement surveys and Customer Influence Panel (CIP).
The SNG Annual Assurance Review for our executive and non-executive boards will cover our compliance with the CCS.
Action for non-compliance
SNG Employees
If we consider an employee is unable to meet the relevant standards, we will follow our Performance and Capability Policy for issues relating to skill, aptitude, health or other physical or mental quality. Where an employee is not meeting the relevant standards because of their conduct (action or inaction), they will be investigated for misconduct under our Disciplinary Policy.
You will normally be informed of possible outcomes before any formal meetings and a fair process will be followed in line with our policy. Depending on the circumstances, possible outcomes could include a warning, redeployment to an alternative suitable role, or termination of employment.
Service Providers
If a Relevant Individual who is, or who works for, a Service Provider, fails to meet the requirements under this policy, we will take action. The situation will be investigated, and possible outcomes could include escalation, additional monitoring, a warning, notice of remedial action, improvement plan, report to authorities, suspension or termination of contract. We will decide appropriate action on a case-by-case basis, depending on the circumstances.
Responsibilities
Policy Owner - Oversees the policy, ensures alignment with strategy and law, reviews major changes
Policy Author - Updates policy in line with legislation and regulations
Line Manager - Identifies training needs for individuals in their team; implements and supports colleague development plans, reinforces learning on the job
Learning and Development Manager - Provides access to required training, maintains, develops and continuously improves training provided
Reasonable adjustments
Reasonable adjustments to this policy and the process will be made as necessary, such as for disabled colleagues or those who are absent from work long-term, e.g., family leave. This could be, for example, a temporary pause for an agreed period on the requirement to be actively progressing a qualification.
Support arrangements will be considered on a case‑by‑case basis to ensure that your needs are fully understood and appropriately addressed.
Where required, a tailored plan will be implemented to ensure you can access and meet the mandatory qualification requirements applicable to your role.
Support
Tell your manager or the HR team if you need reasonable adjustments to support you at work; there’s guidance on the intranet to help you.
Visit the online wellbeing hub for information about the Employee Assistance Programme (EAP) and mental health first aiders (MHFA). The EAP is a free, independent and confidential advice service, available 24 hours a day, 7 days a week. MHFAs will listen without judgement and can assist you to find and contact specialist support services if needed.
Contact
If you need assistance accessing this policy, advice on how to follow it, or have a suggestion, contact the Learning and Development team by creating a case in Workday (only available to employees).
Appendix A – Housing Management Services
“Housing Management Services” are listed in Annex A to the government's Competence and Conduct Policy Statement. Examples of functions performed by Relevant Individuals include, but are not limited to, the following:
Manager functions
- Operational management of services provided in connection with social housing management, such as: Tenancy management, repairs and maintenance (including out of hours), estate management, customer services, customer involvement and empowerment activities, allocations and lettings management, income management, asset management (including building/fire safety), anti-social behaviour management, and capital/major works in occupied buildings, aftercare services to customers, e.g., managing defects on new builds.
- Making decisions about the operational management and oversight of the service or managing the quality and / or safety of housing management services or deciding changes to policy or to service delivery
- May or may not have line management responsibilities.
- Services do not include managing delivery of personal care to customers, construction of new buildings, or management of unoccupied buildings.
Executive functions
- Overall strategic direction and service quality accountability, developing and embedding organisational culture, implementing performance management strategies, ensuring accessible, customer-focused policies and procedures are in place.
Version control
Effective Date - 28/09/26
Change - New policy aligned to new regulations.
Version - 1.0