Version 2.0 Last reviewed: January 2026
7. Sustainability and Environmental Management
8. Responsibilities, Accountabilities and Governance Structure
9. Employee consultation, and equality, diversity and inclusion
11. Legislation and regulation
Appendices (Available internally only)
1. Scope
1.1 Sovereign Network Group (SNG) recognises and accepts its duty of care under the Health and Safety at Work Act 1974 (HASAWA). SNG is committed to ensuring, as far as reasonably practicable, the health, safety, and wellbeing of all colleagues, as well as the safety of customers, contractors, visitors, members of the public, and other stakeholders affected by its activities.
1.2 This policy applies to all SNG workplaces, including the following:
- SNG-owned and leased properties (offices, residential buildings and operational facilities).
- Any locations where SNG employees, contractors, customers or members of the public may be affected by SNG activities or operations.
1.3 The arrangements set out our goal of keeping everyone safe and well (ES&W). These arrangements are defined in our Safety Management System (SMS) (Appendix 1), following the principles of the Plan, Do, Check, Act (PDCA) model.
2. Purpose and objectives
2.1. The policy defines requirements to comply with legal responsibilities as an employer under the Health and Safety at Work etc. Act 1974, and the Management of Health and Safety at Work Regulations 1999.
2.2 The objectives of the policy are to:
- Prevent, minimise and reduce environmental impacts.
- Set out how SNG delivers appropriate measures to manage the organisation's environmental impacts and conserve resources.
- Define the organisational arrangements for the effective planning, organisation, control, monitoring, and review of preventative and protective measures.
- Outline SNG’s commitments to managing the health, safety and welfare (physical and mental wellbeing) of colleagues, contractors and others who may be affected by SNG’s activities. The commitments are set out in section 5.
- Establish clear lines of responsibilities and accountabilities (section 8) at all levels of the organisation for all aspects of health and safety. This is supported by associated specific Policies, Procedures and Guidance documents referenced in section 11.
3. Policy statement
Sovereign Network Group (SNG) places its legal, moral, and financial responsibilities towards health, safety, and the environment (HSE) at the very centre of its business objectives and is committed to continual improvement.
SNG aims to lead by example, exceeding sector benchmarks and sharing good practice to encourage higher health, safety, and environmental standards across social housing. Our goal is to establish a positive safety culture and minimise the impact of the company’s operations on the environment, whilst ensuring everyone is safe and well.
We are committed to protecting the environment by reducing negative impacts and enhancing positive contributions through all our activities and services. SNG identifies key stakeholders, legal obligations, and significant environmental aspects to ensure a holistic, cradle-to-grave approach to compliance, supported by our comprehensive environmental legal register.
Health, safety, and environmental (HSE) impacts are managed within our Safety Management System (SMS) by applying the Plan, Do, Check, Act (PDCA) principles. This strategic assurance framework enables us to proactively address risks at first, second- and third-line defence, ensure legal compliance, and minimise the potential for enforcement actions and reputational damage across all areas of HSE.
Alongside this policy, SNG has a statement of intent outlining our commitment to Building Safety and Compliance.
The Chief Executive Officer (CEO) has direct accountability for HSE performance and will work with, and delegate to, colleagues and other stakeholders to ensure this policy is delivered.
4. Definitions
PDCA - Plan, Do, Check, Act: A continual improvement cycle aims to achieve a better balance between the behavioural and systems aspects of health, safety and environmental risks management.
CEO - Chief Executive Officer
CPTO - Chief People & Transformation Officer
CCO - Chief Customer Officer
CIDO - Chief Investment and Development Officer
EB - Executive Board
Employee representation - Employee Engagement Forum (EEF), Trade Consultative & Engagement Forum (TCEF)
HSE&AWD - HSE, Assurance and Workplace Director
HASAWA - Health and Safety at Work etc. Act 1974
HSLG - Health and Safety Leadership Group. A cross-functional committee of Senior Leadership Group (SLG) Directors from across SNG.
HSE - Health Safety and Environment
ISO 45001 - An international standard for occupational health and safety management.
PDCA - Plan, Do, Check, Act: A continual improvement cycle aims to achieve a better balance between the behavioural and systems aspects of health, safety and environmental risks management.
SMS - Safety Management System. A systematic framework which helps us to identify, assess, and manage our health, safety and environmental risks.
5. Policy
5.1 The policy defines how SNG will remove, reduce and minimise the risks from work related activities and how it supports SNG’s commitment to the safety of all colleagues, contractors, customers, and anyone affected by SNG’s operations.
5.2 We will lead by sharing our Health and Safety good practices with peers across the housing sector and through collaboration, striving to raise Health and Safety standards throughout the sector.
5.3 Occupational health and safety is a principal risk for SNG. Sub-principal risks and associated control effectiveness are measured and monitored within the Occupational health and safety Risk Control Matrix (RCM). In line with SNG’s risk aversion for health and safety, we regard compliance with the Health and Safety at Work etc. Act 1974, and associated regulations, as the minimum acceptable standard for all activities affecting the health and safety of colleagues, customers, contractors, and others who may be affected.
5.4 We aim to develop and implement our health, safety and environmental management system in accordance with ISO 45001 Occupational health and safety management systems standards.
5.5 We are committed to maintaining the highest standards of health, safety and psychological safety through a culture of fairness and transparency, ensuring accountability and clear lines of responsibility.
5.6 We are committed to provide safe and healthy working conditions for the prevention of work-related injury and ill health for all areas within SNG activities to reduce risk of harm to its colleagues, contractors and others.
5.7 We are committed to ensuring there is equality, diversity and inclusion and to apply this policy consistently, fairly and not discriminate against anyone based on their protected characteristics, as set out in the Equality Act 2010. This includes PPE selection which must consider individual needs related to gender, religion, disability, or other protected characteristics. Therefore, ensuring PPE and equipment is suitable, does not discriminate, and maintains the required level of protection reflected in risk assessments as required.
5.8 We are committed to supporting colleagues with diverse needs by making reasonable adjustments to ensure equitable access to learning opportunities. We will use inclusive training materials by having accessible formats, flexible delivery methods, and culturally sensitive content. Additionally use video recording software and closed captions as a feature when sharing HSE videos. HSE document templates have accessible formatting and an ‘Accessibility checker’ and can summarise with Copilot function.
5.9 We aim to reduce our carbon footprint and protect the environment, including the prevention of pollution and the efficient use of organisational resources, through the Environmental, Social and Governance (ESG) strategy.
6. Compliance
Compliance with this policy will be monitored as follows:
6.1 Targets and key performance indicators (KPIs) will be set by the HSE&AWD and agreed by the Health and Safety Leadership Group, for key HSE objectives.
6.2 The HSE team report performance against a range of leading and lagging KPIs and provide performance reports for the Board, Executive Board, and HSLG. These summarise the organisation’s performance against agreed KPIs, strategic HSE objectives, and additional information as required, to show continual improvements.
6.3 The Board, Executive Board (EB) and HSLG receive and review HSE performance reports quarterly, monthly, and quarterly, respectively.
6.4 Findings and recommendations from Assurance Reviews.
6.5 Review of accidents, incidents, significant near miss and unsafe condition report data.
7. Sustainability and Environmental Management
7.1 At SNG, we recognise the critical importance of sustainability in our operations and services. We are committed to embracing sustainable practices that contribute to environmental protection, social equity, and economic viability.
8. Responsibilities, Accountabilities and Governance Structure
8.1 The SNG Board, Chief Executive Officer (CEO), EB and HSLG are accountable for ensuring HSE arrangements are in place and operating effectively. The HSLG is a Group established by the EB.
8.2 The HSLG forms part of SNG’s formal governance structure; ultimately reporting to the SNG Board.
8.3 The implementation of this policy is the collective responsibility of all SNG colleagues, achieved through associated procedures and Safety Management System.
8.4 The policy will be communicated to all colleagues through a wide variety of communication channels.
8.5 We are committed to continuously enhancing our HSE standards through benchmarking our performance against leading organisations in the social housing sector. Regular comparisons help us adopt best practices; ensure we meet industry standards and foster a culture of continual improvement.
8.6 To achieve our vision of ‘Everyone Safe and Well,’ fostering a strong safety culture is critical for successful HSE management. This requires commitment, proactive actions, and a positive attitude from every level of the organisation. Detailed responsibilities and accountabilities for individuals, roles and groups are outlined in the sections below.
Responsibilities and accountabilities
Board
Responsibilities
- Delegate overall HSE responsibility to the CEO.
- Review and assure HSE performance quarterly by assessing reports and KPIs as provided by relevant stakeholders across the organisation.
Accountabilities
- Monitor delegated responsibilities through appropriate committees.
- Review delegated responsibilities at regular intervals for performance, compliance and improvements.
Chief Executive Officer
Responsibilities
- Lead by personal example to establish a pro-active safety culture and promote the ES&W vision throughout the organisation.
- Review HSE performance and progress against strategic objectives and inform the Board of any major HSE incidents or potential regulatory notices.
- Ensure that HSE implications are considered and addressed in decisions made by the Executive Board.
Accountabilities
- Ensure the organisation's HSE Policy aligns with corporate objectives and has been communicated throughout the organisation.
- Ensure that colleagues have sufficient time and resources available to implement the HSE Policy and SMS.
- Ensure that HSE risks are identified, and controls implemented to manage the risk within the organisation’s health & safety risk appetite.
Executive Board Members
Responsibilities
- Discharge HSE functions delegated by the CEO and provide Direction as required.
- Allocate sufficient resources for HSE responsibilities within their directorate by setting appropriate budgets and staffing levels.
- Lead by personal example to establish a pro-active safety culture and promote the ES&W vision throughout their directorate.
- Review HSE performance monthly against set KPI's and progress to HSE strategy.
Accountabilities
- Monitor HSE performance within their Directorate.
- Ensure their Directorate is properly resourced for HSE management.
- Demonstrate visible leadership in HSE management and strategic decisions.
- Monitor HSE performance, aligned to the corporate vision.
Health and Safety Leadership Group
Responsibilities
- Review and discuss HSE performance reports quarterly by holding review meetings.
- Make strategic decisions and interventions on HSE risk management.
- Complete other duties outlined in the HSLG Terms of Reference, as necessary.
Accountabilities
- Provide clear direction and decision making as required to HSE performance and monitoring.
- Ensure risk management interventions are effective and appropriately delivered.
- Complete tasks set out in the HSLG Terms of Reference.
Chief People & Transformation Officer (CPTO)
Responsibilities
- Review operational H&S principal risk and strategy by assessing the organisational risk profile and making recommendations for improvements.
- Ensure resource allocation for HSE strategy implementation by coordinating with relevant teams to allocate staff and budgets.
- Chair HSLG meetings and escalate relevant matters to the Executive Board by ensuring key HSE issues are raised and addressed at EB and board level.
- Provide assurance to the Board on HSE performance by delegating responsibility of preparing and presenting HSE performance reports.
Accountabilities
- Oversee the implementation of the HSE strategy and ensure HSE risks are effectively managed.
- Provide the necessary resources to implement the HSE strategy.
- Lead effective HSLG meetings and ensure all HSE critical issues are brought to the Executive Board’s attention.
- Provide clear and accurate assurance on the organisation’s HSE standing to the Board.
Chief Customer Officer (CCO)
Responsibilities
- Own the Building Safety and Compliance principal risk, ensuring adequate management of building safety across SNG and making recommendations for improvements.
- Ensure delivery of the Building Safety Strategy and related policies is sufficiently resourced to meet the building safety and compliance requirements of the organisation.
- Provide assurance to the SNG Board that the business is effectively managing its Building Safety and Compliance principal risk by delivering data led regular reporting on the safety remediation programme and building safety compliance position.
Accountabilities
- Ensure building safety risks are managed and risk controls executed effectively within the organisation.
- Ensure the necessary resources are in place to execute the organisation’s Building Safety strategy and associated policies.
- Provide data led accurate reports on the organisation’s building safety and compliance position to the SNG Board.
Chief Investment & Development Officer (CIDO)
Responsibilities
- Ensure resource allocation is adequate to support Homes and Place Standard commitment.
Accountabilities
- Allocate the necessary resources to meet new development safety requirements.
HSE, Assurance & Workplace Director
Responsibilities
- Deliver detailed analysis and reports on HSE performance to the CPTO, EB, and the Board.
- Develop and maintain the HSE management system by ensuring systems are up-to-date and reflect current regulations.
- Provide accurate detailed summaries of serious incidents which are cause for concern and escalate as necessary to the CPTO.
- Meet with operational leadership to review HSE strategy and performance.
- Develop HSE plans and KPI’s by coordinating with key stakeholders to establish measurable safety targets.
Accountabilities
- Provide accurate and up-to-date information on HSE performance KPI's and Strategy.
- Ensure effective operation of the HSE management system across the business.
- Ensure detailed analysis on occupational health incidents with appropriate actions to support improvements.
- Accountable for ensuring that the HSE strategy is regularly reviewed and updated in line with operational risk profile.
- Create clear, measurable HSE objectives for the organisation.
Managing Director Property Services/Property Services Director
Responsibilities
- Actively promote the ES&W vision and principles across property services, to create a positive safety culture where health, safety and wellbeing are integral values for all colleagues.
- Review HSE performance measures demonstrating compliance with safety standards across the Property Services.
- Report periodically HSE performance to the CCO regarding improvement programmes and initiatives, supporting or with the HSE team.
Accountabilities
- Maintaining open communication between the HSE and their teams.
- Ensure ongoing monitoring of the HSE performance of the Property Services team.
- Provide periodic updates on HSE performance to the CCO with the HSE team.
Head of HSE
Responsibilities
- Review HSE policy annually by evaluating its relevance against current legislation and safety management system.
- Monitor the SMS by regularly reviewing safety performance data and address areas needing improvement.
- Engage directorate stakeholders to embed a positive safety culture, overseeing HSE compliance and continual improvement.
- Review and monitor HSE plan, training matrix, and competency framework by ensuring staff training is current and effective.
Accountabilities
- Ensure any material changes are incorporated as required into the HSE policy.
- Monitor HSE performance and regularly review against the Safety Management system.
- When required, manage reviews and audits to continuously embed a strong safety culture.
- Regularly analyse and review HSE training performance and effectiveness across the organisation.
Asset Safety and Compliance Director
Responsibilities
- Report Building Safety (BS) Compliance and BS Remediation performance to the CCO by preparing performance reports and action plans.Review building safety compliance risks and controls by conducting regular review of performance data.
- Review building safety compliance and BS risks and controls by conducting regular review of performance data.
- Monitor compliance reporting alongside BS Compliance and BS principal risks and escalate notification of critical incidents to the HSE, A&WD as required.
- Engage with directorate stakeholders ensuring compliance with statutory obligations by organising regular compliance reviews.
Accountabilities
- Ensure accurate and timely reporting on building safety and compliance.
- Manage building safety and BS safety compliance risks and implement controls.
- Escalate critical HSE incidents to the CCO and HSE, A&WD.
- Maintain adherence to building compliance in line with the SMS.
SLG Directors
Responsibilities
- Ensure HSE performance is an integral management function in their business areas by reviewing and implementing improvements.
- Direct the implementation and monitoring of HSE risk management controls by ensuring regular checks and HSE performance reviews are conducted.
- Implement relevant processes supporting the SNG Safety Management System, embedding good practice with guidance and advice from HSE.
Accountabilities
- Regularly review HSE performance within their business areas.
- Ensure HSE risks are reviewed and monitored.
- Ensure the Safety Management system elements where relevant are implemented
Heads of Service
Responsibilities
- Embed HSE risk management: Include HSE in operational planning with appropriate controls and measures to manage.
- Ensure HSE training is completed. Schedule and monitor training completion as per requirements against the HSE training matrix.
- Consult with colleagues on safety issues. Organise regular meetings to discuss and address HSE concerns.
- Monitor contractor and third parties HSE performance within their areas by conducting regular reviews.
Accountabilities
- Ensure risks are managed and reviewed for controls as appropriate to business area.
- Review HSE training completion following requirements of job roles and responsibilities.
- Consult colleagues regularly on HSE issues.
- Ensure HSE standards are communicated, maintained monitored and reviewed in their business area.
Line Managers
Responsibilities
- Understand HSE requirements of their teams, regularly monitor compliance and ensure all incidents are reported promptly in E-Safe with the appropriate review and action as required.
- Promote a positive HSE culture by regularly engaging with colleagues on safety initiatives.
- Ensure all team members attend required HSE onboarding and training.
- Ensure HSE risks identified for roles are clearly understood and incorporated into risk assessments.
- Monitor operational HSE requirements by regular monitoring. Ensure any safety concerns are addressed.
Accountabilities
- Maintain a clear understating of the HSE requirements within their teams and regularly monitor compliance.
- Foster a culture of HSE awareness within their teams.
- Identify and regularly review the HSE training matrix is appropriate for team members.
- Ensure role and task risk assessments are completed and reviewed as required.
- Review teams’ performance to HSE requirements and escalate any concerns as required to the HSE team for continuous improvement.
Employees (Colleagues)
Responsibilities
- Take reasonable care for health and safety of self and others by understanding and following relevant risks controls within job role.
- Report all accidents, incidents, and near misses promptly through incident reporting tool, E-Safe.
- Understand and apply the controls identified in risk assessments and always apply safe working practices.
- Apply the Stop works procedure as appropriate and if required escalate to line manager for resolution.
- Use tools and equipment as recommended by manufacturer’s guidance. Apply controls to mitigate any potential risks to safety and health.
Accountabilities
- Ensure adherence to relevant company HSE procedures, safe working practices and use appropriate personal protective equipment (PPE).
- Ensure understanding of E-Safe reporting tool to promptly report incidents and near misses for further line manager’s review and escalation as required.
- Complete all relevant risk assessments applicable to their role. Attend relevant HSE training as identified for role.
- Take appropriate action to prevent incidents by always working safely.
- Use tools and equipment safely and correctly. Have a clear understanding of controls as stated in risk assessments for use.
Employee Representation (EEF, TCEF, ICC)
Responsibilities
- Discuss all HSE concerns raised by colleagues and escalate as appropriate for feedback and resolution.
Accountabilities
- Ensure all HSE queries raised are resolved and communicated as required.
Contractors (via Contract Managers)
Responsibilities
- Meet Construction Design and Management (CDM) Regulations where required and liaise appropriately with SNG managers to ensure all Construction Phase Plans (CPP) are reviewed before work commences.
- Provide SNG with all required HSE documentation, including incident data, training records, licenses, risk assessments and method statements and report any HSE incidents promptly.
- Provide all contractor and sub-contractor employees with HSE inductions.
Accountabilities
- Ensure CDM regulations are followed as appropriate to ensure works are conducted safely.
- Ensure all documentation is accurate and reflects risks appropriately; incidents reports are made available for further review by the contract manager and HSE team.
- Ensure all contractor and sub-contractor employees understand their risks and SNG’s expectations to safe working practices.
9. Employee consultation, and equality, diversity and inclusion
9.1 At SNG we consult with our colleagues for participation and review of HSE activities and performance evaluation at all levels, for ongoing improvements to the HSE Safety Management System (SMS).
9.2 Achieved by:
- Consulting with the EEF group for HSE policy updates
- Creating steering groups and workshops for participation and input into review and design of programs.
- Consulting with TCEF for performance and HSE team plan and programs activity discussing and consulting with TCEF
- HSE performance and analysis to Board, EB and by Directorate.
- Key HSE decisions are taken to the HSLG Health and safety leadership group for discussion and approval. Equality and diversity
- We will apply this policy consistently and fairly and will not discriminate against anyone based on any relevant characteristics, including those set out in the Equality Act 2010. For example, reasonable adjustments will be considered for colleagues with a disability with regards to their working environment.
10. Related documents
10.1 The HSE policy, standards and procedures (Appendix 4) and Safety Management System (Appendix 1) to supplement this policy, are located on our intranet in an A-Z. They set out safe working practices, incorporating relevant regulations and best practice. Describing in detail what will be done in practice to achieve the aims set out in the CEO’s Statement of Intent. The procedures are developed, published, reviewed and maintained by the HSE team.
10.2 Building Safety and Compliance Policy (Appendix 5).
10.3 Fire & Building Safety Policy (Appendix 6).
11. Legislation and regulation
11.1 The legislation listed in this policy is not intended to cover all legislation applicable to this policy. To comply with clause 1.1 of the Regulator of Social Housing’s Governance and Financial Viability Standard, which requires adherence to all relevant law. SNG will take reasonable measures to ensure compliance with all applicable legislation by reviewing policies and procedures and amending them as appropriate. Any queries relating to the applicable legislation should be directed to the policy owner.
- Health & Safety at Work etc Act 1974
- Management of Health & Safety Regulations 1999
- Regulatory Reform (Fire Safety) Order 2005.
- The Construction (Design and Management) Regulations 2015
- Fire Safety Act 2021
- Building Safety Act 2022
12. Review
12.1 This policy will be reviewed annually, or sooner if significant changes occur in the relevant legal or operational landscape. The review will made available for consultation with Board, EB, HSLG and EF.
12.2 Input to review will include changes in applicable regulations, outcome of HSE performance, annual HSE plan, sector best practice guidance, audit results, consultation outcome and performance data.
Appendices
- Appendix 1: Safety Management System (Available internally only)
- Appendix 2: Health and Safety Leadership Group Terms of Reference (Available internally only)
- Appendix 3: Contractor Management Standard (Available internally only)
- Appendix 4: HSE Pages (Available internally only)
- Appendix 5: Building Safety and Compliance Policy (Available internally only)
- Appendix 6: Fire Safety Strategy (Available internally only)