CIH Rethinking Social Housing Project Update

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Melanie Rees, CIH

CIH’s Rethinking Social Housing project is now in full swing.

Formally launched in January, we wanted to get a national debate going about the role and purpose of social housing – and we’ve been blown away by the response we’ve had!  We developed a toolkit to help people to hold their own local workshops to discuss and reflect on what social housing is, its value and who it’s for. So far we’ve had results from 96 workshops (we’re very grateful to the Northern Housing Consortium for their support in delivering events in the North) and we expect to have even more by the deadline on 31 March. We’ve also had over 756 responses to our online survey. We’ll start the analysis in earnest at the start of April and will hopefully have something to share publicly by the end of April.

Alongside this, we are working with Ipsos MORI to carry out a public perception survey to help us to understand what the general public thinks and understands about social housing. This will happen during April and we expect to be able to report the results early in May. We are also working with CaCHE (the UK Collaborative Centre for Housing Evidence) to build up a picture of who is currently living in social housing.

We’ll be sharing results as they become available and will formally launch our findings, along with recommendations to government and the sector, at Housing 2018 in Manchester on 26, 27 and 28 June.

If you would like to know more, contact CIH head of policy Melanie Rees.

Is planned maintenance value for money?

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Now there’s a question to get the brain cells working. For many, to even question the assertion that planned maintenance delivers value for money is heresy. But is it?  Given that the vast majority of social housing has been modernised in the last 15 years and most have “reasonably modern” facilities, is continuing with component renewal through planned programmes the best way to target investment and deliver value for money (VFM)?

A small, but growing, number of housing organisations are questioning the VFM basis for planned programmes, when replacement en masse was needed due to major components all failing the decency threshold at the same time following years of underinvestment. However, that scenario has now changed and components are likely to fail at different times, not at one convenient point in time. This is because failure of main components such as kitchens, boilers and bathrooms, depends to a great extent on the level of fair wear and tear they receive from householders. This is increasingly being supported by stock condition surveys which are predicting different timescales for component failure, even if the components were fit at the same time.

Against this backdrop, demand-led component renewal is the most effective and efficient way of targeting capital resources. This system relies on operatives referring main components for replacement, but only when they cannot be repaired. The work is then carried out quickly by a flexible, multi-skilled team of operatives. It does not require technical surveys, or complex specifications to determine the scope of work. It does not require bureaucratic tendering and evaluation procedures. It does not need complicated project management systems or contractor monitoring arrangements. And it does not require detailed monthly invoicing or certification processes to pay contractors.

All-in-all, demand-led component replacement delivers targeted renewals, to where they are needed, in a timescale welcomed by tenants, whilst saving considerable sums in terms of back-office support costs. It also drives efficiency in the way components are replaced, maximising operative working time, thereby further reducing replacement costs.

If you are interested in exploring whether such an approach might save you money for other priorities such a fire safety improvements or new development, please contact the NHC which has a bank of experienced Associates who have delivered these systems with considerable success in other housing organisations.

This blog entry was written by Jeremy Lester, one of the NHC’s associates. For more on how the NHC can save you valuable time and money through our associates, please see the Business Improvement Services section of the NHC website.

Guestblog: Ward Hadaway – Housing Sector Forecast 2018

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Ward Hadaway logo

In its guest blogs, NHC Supporter Ward Hadaway offers the legal perspective and some guidance on some of the social housing sector’s most pressing issues. In this edition: a look at what’s in store for the housing sector in 2018.

On entering 2018, we reflect on the main outcomes of 2017 for the housing sector and discuss what we can expect in 2018.

Review of 2017

Looking back at 2017, a number of prominent events stood out for the housing sector:

  • The Housing White paper “Fixing our Broken Housing Market” outlined the Government’s plans to reform the housing market and boost the supply of new homes in England.
  • The General Election which gave the UK its sixth housing minister, Alok Sharma MP, since 2010 following Gavin Barwell losing his seat.
  • The supported housing U-turn in which the Government proposed a new ‘three-pronged’ funding model for sheltered, transitional and long-term supported housing from April 2020.
  • The catastrophic event of the Grenfell Tower fire drawing into focus product specification, health and safety and building regulation, management of social housing and the inadequacies of the local authorities in rehousing the victims of the fire.
  • The Autumn budget providing, amongst other things, an investment of £44bn into housebuilding over the next 5 years, a target of 300,000 new homes to be built a year until 2020 and a lift on borrowing caps for councils.
  • Government plans to abandon capping housing benefit for social housing tenants at the Local Housing Allowance (LHA).

What is the forecast for 2018?

The following key points are what we expect to look out for during 2018:

Government papers

The Government is continuing to work on a Social Housing Green Paper. The paper will focus on the safety and quality of social housing, the management of social homes, tenants’ rights and complaints handling procedures. In addition to this, the Green Paper is expected to consider how the sector can contribute to the Government’s economy boosting strategies.

The Government are conducting a nationwide ‘Social Tenant Engagement Questionnaire’ to obtain information on tenant’s views on social housing. The responses will feed into the policy paper and views can be submitted via the following link.

Homelessness

The Homelessness Reduction Act (HRA) is due to come into force in April of this year. The HRA will place duties on local authorities to try and help prevent homelessness by intervening at the earlier stages and some authorities will be under a duty to refer who may be homeless, or vulnerable to being homeless, to a housing authority. There is £72 million available to help authorities implement the HRA with a further £3 million being provided to bodies to update their data systems in order to monitor how the HRA is affecting homelessness in their district.

Changes to the GDPR

Changes to the General Data Protection Regulation (GDPR) come into force on 25th May 2018. The main changes regulate more stringently how organisations manage, store and handle ‘personal information’. Day-to-day work for social landlords and housing associations involves dealing with personal information. Organisations must move to compliance by 25th May 2018.

A snapshot of the property market

Over the past 12 months, house prices have risen 2.5%. Savills and Jones Lang LaSalle (JLL) predict a 1% rise in 2018 whereas Countrywide predict a 2% rise. A 3.1% increase is predicted next year by the Independent Office for Budget Responsibility based on first time buyers benefiting from the changes to SDLT whilst a 1.6% decrease has been forecast by Morgan Stanley. The supply of new build homes to rent has increased and as a result, JLL predict no more than 2% increase in rents for 2018.

With the uncertainty of Brexit negotiations and as always the possibility of unforeseen events (such as Grenfell) that tend to shape the landscape, it is always difficult to predict with any certainty what will happen this year. As ever, horizon scanning, preparation, and risk management will be crucial to deal with whatever 2018 presents.

If you have any questions on the above and how it will affect social housing providers, or any other questions as a social housing provider, please do not hesitate to contact me or a member of our expert Social Housing Team.

Joint seminar with the Northern Housing Consortium

We are hosting a seminar with the Northern Housing Consortium (NHC) covering Safeguarding in the Housing Sector on Wednesday, 28th March 2018 in Leeds. For further information and to book your place, please follow the link. Ward Hadaway frequently holds seminars with the NHC on a wide variety of issues concerning the housing sector. It is always worth keeping an eye on the NHC’s events listings or signing up to its weekly events update.


Our expertise

We work with Registered Providers across the country day-in, day-out so we know what kind of issues you face and the pressures under which you work. Our Social Housing Team brings together substantial experience and expertise to provide a full service tailored to meet your needs.

For further information, please contact Howard Walker, PR Manager at Ward Hadaway, on 0191 204 4446 or howard.walker@wardhadaway.com.

Guestblog: IamYiam – If your body is a temple, how can you worship it every day? 

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IamYiam

IamYiam is a health platform that creates personalised health and fitness activities and nutrition plans based on science, genetics and history. The company has written the following piece as an introduction to NHC members.

If your body is a temple, how can you worship it every day? 

It’s a good question, and one that probably enters our thoughts at various moments throughout our lives, especially at times when we are feeling run down or have an illness that interferes, or worse, inhibits our normal everyday lifestyle.

How we see our bodies is an interesting topic. Most of us desire to look good, some like to feel good too and others see our bodies as something to be respected; worshipped almost. Ultimately it is a matter of choice. Then there are those who see themselves from a different perspective. Those that seem to expect our bodies to be this robust, throw-anything-at-it machine, that will continue forever at peak performance, regardless of what nourishment we give it or what maintenance we provide. Our temples absorb this wear and tear and abuse, until they start to show signs of breakage. Only then we cry out for help.

This appreciation of our bodies, or more accurately general lack of appreciation, highlights a huge challenge in the way we think about our own health and the lifestyles we lead.

There is no doubt that currently we live in society that has a challenged curative healthcare system that costs us globally $8 trillion, with preventable diseases now making up for 75% ($6.1 trillion) of the global healthcare costs. This see’s the UK healthcare and wellbeing market with costs as high as £180bn with the UK’s NHS already overstretched.

One translation of these statistics could reflect that, as individuals, our approach to health seems to be that we choose to either hope for the best or ‘put it off till later’. We more or less act as if we are happy to treat our bodies to a life of disregard, and in turn ignore the inevitable health problems that will contribute to the trillions of pounds required to fix our bodies in the future.

Let’s imagine this challenge in another way. You are gearing up to set off on a lifelong voyage, similar to one’s lifelong health journey you might say.

First, you choose your destination, and then look to your mode of transport, your vehicle, your body in health terms. Interestingly, not all of us can have the body of a strong powerful 4×4, with some of us born to be more of a fast, streamlined sports car.

Next, as an intelligent individual that cares for our other passengers, likely you would prepare your chosen mode of transport for this adventure, safely checking it had enough fuel, understanding the correct tyre-pressure, glad you had recently undertaken the engine and brake service, all now maintained with refreshed engine oil, and maybe even a shiny body polish. Full of pride and confidence you press the start button, and purr into life.

Now imagine how enjoyable this journey would be as you smoothly travel to your destination, your body performing perfectly; capable of handling the twists and turns of the road ahead. And maybe one day becoming a timeless classic.

The alternative…jump into your car, your fingers crossed while you try to remember the last time you ever had your car serviced, wondering if the tyres have enough air or even tread for the road ahead. Your engine struggles into life, spluttering and coughing, as you limp off down the track, not looking forward to the journey and unsure as to whether you and you passengers will ever make it safely to your destination.

It seems therefore, that as we decide on our health journey we do have a choice, and that the challenge of caring for our bodies is not just a matter of simply sticking our heads in the sand. What else could be the cause for such alarming industry numbers?

The good news is that recent data shows us that personalised preventative health is the growth industry of the next decade, with consumers looking for factual guidance and better support in helping them to stay fit, healthy and happy in the long term. The choice of direction we take is changing from that of waiting to be fixed when things go wrong, to choosing a lifestyle that adds to the quality of one’s health and helps prevent the illness and poor performance of the past.

This choice however means consumers need trusted information on health and wellbeing and finding this information can be difficult, with the core questions of what will work for me and where do I start often forming the initial challenge.

It seems this new attitude to healthier bodies could help in the business world in other ways too.

In the UK, research shows that employees who suffer poor health, or have a lack of focus on wellbeing or display low social engagement have a direct impact on business, not just in lost productivity, but in generating a £29 billion annual bill for sickness absence. Yet despite the clear cost of getting it wrong, less than one in ten UK businesses adopt an approach to wellbeing that is linked to their business objectives. Most businesses know it pays to invest in the wellbeing of their people, but don’t know where to start.

This seems to reflect a more operational challenge, which is to provide employers immediate access to proven programs, providing meaningful performance focused results for their staff. Workplaces are ultimately where people, for better or worse, spend much of the working day, and combined with the need from business for better tracking and evaluation, the improvement in employees’ wellbeing to drive business performance is a clear route to growth.

Moving forward, we live in a world of information, connection and innovation, yet with too much choice and confusion. With so many heath conditions preventable and lifestyle-related, we anticipate consumers more engaged than ever in their healthcare, fitness and wellness future.

Whether it’s about helping employers in supporting employees manage their everyday health, through bespoke nutrition and fitness plans, or ensuring individuals are able to take control of their own health goals and receive clear advice. Or being able to track your progress through smart online assistants, whatever the solution, fortunately there are companies such as iamYiam that see this challenge and are there to help guide you on the path to wellness and improvement, with performance based results.

Deciding on your health journey, your destination and how you get there, is still a matter of choice, reflecting how you see yourself today and more importantly, tomorrow. Perhaps the real question should be “is your temple seen as a relic from the past, or to be enjoyed into the future as a timeless classic”?

The choice is yours.

www.iamyiam.com

For further information, please contact Alan Gordon, Chief Marketing Officer, iamYiam alan.gordon@iamyiam.com

7th Annual National Tenant Panels Conference round-up

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tenant advisor

 

 

 

 

In November 2017, the Northern Housing Consortium (NHC) welcomed more than 100 delegates to our 7th Annual National Tenant Panels Conference Focusing on the voice of our customers — Innovation, efficiency and effectiveness in partnership with Yvonne Davies at Tenant Advisor. The event was chaired by Tom Miskell, Chair of the NHC and Pendleton Together. Among lots of discussion and debate we heard speakers discussing a range of themes including:  scrutiny, health and safety, tenant voice, digital engagement, strategy and youth aspiration.

Delegates were involved in an interactive session focusing on Health and Safety matters asking the questions:

  1. How can you help your landlord to make tenants feel safe(r)?
  2. How can you support your landlord to communicate expectations of tenants on safety?
  3. What information do you need from your landlord about safety in your home/estate/neighbourhood?
  4. What are your top tips on sharing your concerns, ideas and solutions with your landlord?

Various themes emerged from this session. Delegates discussed taking more of a strategic approach to tenant engagement by having closer links with Fire and Safety Officers and being involved in risk assessments. There was a focus on observation, including knowing how to report hazards and providing training for resident representatives. Delegates suggested landlords provide communication in formats which are easier to digest, utilising digital channels and participating in more campaigns such as gas safety. Concerns were raised about hoarding and how to identify and help people involved. There was also a real focus on tailoring actions around where people live and the issues present in their community.

The event closed with a session titled Health and Safety Matters — Supporting Tenant Assurance where speakers from Liverpool Mutual Homes, Northwards and the Centre for Public Scrutiny shared their experiences and answered questions from the floor.

For further information on what was discussed in the interactive sessions you can see the notes on the Tenant Advisor website.

A Christmas message from the Chief Executive

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As 2017 draws to a close, I am sure we can all agree this has been a very turbulent year for the housing sector; a year with many positives including more recognition of the importance of housing, but with the awful tragedy of Grenfell never far from our thoughts.

We saw the Government focus on housing in last month’s Budget, including high profile measures designed to help fix the broken housing market and to stimulate the building of more homes across England.

The NHC shares the Government’s ambition to create a housing market that works for everyone. To help achieve this, during the year we have made progress on the recommendations made by last year’s Report of the Commission for Housing in the North. We want to make a real and lasting difference and our evidence underlines the importance of improving the quality of existing homes and places, alongside the need for new supply in place-based strategies.

The Commission report continues to guide our work and crucially, regeneration is back on the agenda. We will now be working on how we gain traction for regeneration within a framework that suits the needs and resources for the North in the current environment.

We want to raise the profile and importance of regeneration activity in a positive way – too often the term is used as a shorthand for unsuccessful market intervention. We have found this picture does not reflect the reality of what is happening on the ground in the North. We need to reclaim the term ‘regeneration’ to reflect the positive impact it can have on people and places across our regions. 

We know that when done well, in the right places and with the engagement of the local community, housing-led regeneration delivers substantial benefits. It increases the scope for new development on brownfield land and widens housing choices and economic opportunity. In the next year, we will be talking to politicians, decision makers at local and regional level and other key influencers to take forward this message. 

I am looking forward to building on this work in 2018 and working to ensure we can be in the best place to support you, our members, in achieving your aspirations. The Consortium exists solely for its members and, whatever the year ahead holds in store, we will be working hard to support you in every way.

In the coming year we hope to provide more opportunities to support you with innovative products and services, to remain a valuable asset to the housing sector and for a strong Northern voice to be heard by politicians and other key stakeholders.

On behalf of everyone at the NHC I wish you a very Happy Christmas and best wishes for 2018.

 

Jo Boaden
Chief Executive

 

Tackling and Preventing Homelessness: The Role of the Housing Sector

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We welcomed close to 70 delegates to Leeds for Tackling and Preventing Homelessness: The Role of the Housing Sector, delivered in partnership with Locata. With a mix of local authorities and housing providers in attendance and a great range of speakers, this event proved to be informative and insightful with lots of debate and discussion.

We opened with a welcome from Chair, Mike Wright, Strategic Lead for Homelessness at Greater Manchester Combined Authority (GMCA) who set the scene. He was followed by Anna Whalen from the DCLG on the Homelessness Reduction Act (HRACT). From her session it was clear that the HRACT (due to be implemented in April 2018) is a big game changer. Highlighting the importance of sharing innovation, she said the DCLG want an open dialogue with the sector. Key themes emerged including a greater emphasis on early intervention and prevention, partnership working, rapid intervention to ensure that a homelessness crisis is brief and doesn’t occur again and support for more people to get out of homelessness and into permanent accommodation.

 “We need to move from being investigators to facilitators” she said.

Homelessness DCLG

(The focus of Government on homelessness: £1 billion by 2020 to achieve these aims)

Next we heard from Chris Hancock, Head of Housing at Crisis who talked us through the history of crisis, the existing homelessness legislation and the steps taken to get to where we are now with the new HRACT. Speaking with passion he shared the opportunities and challenges for the sector. Taking us through the implications of the new ‘duty to refer’, he asked the questions:

“Where is your homelessness frontline?” “Where are your transition points?”

“Where does your local housing association sit with their allocations policies”

Chris also shared: Turned away – a report to examine the quality of help available to single homeless people. The report highlighted some alarming statistics and experiences from their ‘mystery shoppers’ on the homelessness frontline:

  • 50 out of 87 LA visits across England were given no support.
  • Gatekeeping at 29 visits prevented mystery shoppers from having an interview with a Housing Advisor.
  • Interviews with Housing Advisors for non-priority need mystery shoppers were often brief – and characterised by a lack of privacy and empathy.
  • The opportunity to make a homelessness application was mentioned in just eight visits, and in only three were people notified about the outcome of their application.

He touched on some outstanding problems around people with complex needs, issues within the code and training and support requirements for LA’s. The session also looked at how non-LA agencies will take forward their ‘duty to refer’. To finish Chris highlighted the learnings from the Liverpool City Region Housing First Feasibility study.

“We will not get it right first time.” Mike Wright

We were delighted to hear from our chair, Mike Wright, who talked about the impact the HRACT will have on the sector and in particular, the impact to the North. He also took us through the approach Manchester (GMCA) has taken and provided insight into how LA’s can start preparing.

“Is the Homelessness Reduction act a game changer? It is if you apply the act in the spirit and not the letter.”

Delegates were advised to look at their lettings and allocations policies separately. “The first year will be very much a learning curve” Mike suggested “we will not get it right first time.” He emphasised the need to start mapping and profiling demand and to start understanding housing markets. From a Northern perspective he suggested we need to be dealing with demand issues, asylum placements and more detailed interventions — an increased burden for some. Another key point was around the importance of the relationship between LAs and Registered Providers (RPs) suggesting we need to work with  RP’s for the Housing First approach and the ‘duty to refer’. He finished by emphasising the need to embed homelessness prevention across all teams and partners. This was a nice introduction into our professional practice sessions which followed the morning break.

Our Professional Practice Sessions are an opportunity for delegates to hear from other colleagues about best practice and challenges facing the sector. Delegates could choose between youth homelessness and the Accommodation Intensive Mentoring Support (AIMS) project, which shared the positive outcomes to date in tenancy sustainment and employment. We also heard from our supporter – Locata, jointly with Derbyshire Dales DC who shared their experience of implementing the new system and how this has worked for them and their residents. Finally, Threshold, part of New Charter Housing Group talked through their Housing First initiatives. The Housing First approach is based on the principles of housing as a right not a privilege, and to provide a stable, independent home and intensive personalised support to individuals.

The Professional Practice Sessions after lunch included Newcastle City Council’s approach to Housing First and the partnership approach between Thirteen Housing Group and Middlesbrough City Council in tackling and preventing homelessness. Gateshead Council also shared their approach to Health and Needs Assessment and the impact of homelessness.

“We need to address our culture of blame.” Fay Selvan

In a people focussed session, Fay Selvan, Chief Executive at the Big Life Group suggested “we’re having the same conversations over and over again, we know what the issues are but we’re not doing enough to address these”.

“What choices are we making around our homelessness population” she asked, “design your scheme at the coal face”. She went on to provide an insight into The Harvey Project, providing 24-hour harm reduction supported accommodation to drug and alcohol users based in North Liverpool.

From practical approaches to youth homelessness earlier in the day we went on to hear from DCLG’s Steve McKinlay from the Homelessness Advice and Support Team. Here he went through the Positive Pathway approach among other initiatives tackling youth homelessness including:

  • youth homelessness advisers – free resource to support and advise local authorities on developing local ‘pathways’ for young people.
  • Fair Chance Fund – Social Impact Bond pilot focussing on young people most at risk of long term poor life outcomes.
  • National Youth Reference Group – young people with lived experience of homelessness as the experts.

To close the day we heard from Ward Hadaway’s John Murray who provided a legal update summarising the changes with the new HRACT and emphasising the further duties to intervene at earlier stages to prevent homelessness. John also provided an overview of the latest homelessness decisions and Appeal Court reviews of allocation schemes.

Satty Rai, Member Engagement Manager at the NHC said:

“We could see that homelessness and preparation for the HRACT was important for our members coming out of our earlier engagement activity. We felt it was vital to bring together a mix of experts in homelessness policy alongside the practical experiences of LAs and RPs working together on a range of initiatives — one of which includes the Housing first approach. We were delighted with the level of discussion and contributions from the sector. This is clearly an area we want to continue engaging with our members and sharing good practice.”

Following the conference the NHC responded to the consultation on the Homelessness Code of Guidance. You can see our response here.

In terms of next steps the NHC are organising a member roundtable alongside Crisis – Improving Access to Social Housing for Single Homeless People, looking at single homeless people and the role of the sector in addressing a lack of access to social housing. We are also looking to run a homelessness working group which will bring members together to share learning, experiences and best practice and different approaches. Look out for another Homelessness conference next year too.

Protecting Consumers in the Letting and Managing Agent Market: Call for Evidence

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On 1st  October 2017, the Secretary of State for Communities and Local Government, announced proposals to address the imbalance of power in the private rented market by regulating letting and managing agents.

A call for evidence sought views on a new regulatory model and how best to protect and empower tenants and leaseholders.

The Northern Housing Consortium has responded to the Call for Evidence and you can read the response in full here.

The NHC has welcomed an approach to a more professional managing agent market and believe that, if framed correctly, there are benefits for property management agents as well as for tenants and leaseholders. We believe that regulation creates a level playing field, and will help responsible agents to not be undermined by a minority of agents with poor practice and will help improve the reputation of all.

The Government will bring forward detailed proposals early next year, following analysis of the evidence submitted.

Homelessness Code of Guidance – we want your views

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The Homelessness Reduction Act recently became law and is due to be enacted in April 2018.

The Draft Homelessness Code of Guidance provides direction on how local authorities should meet the requirements of homelessness legislation and has been updated to include information on the Homelessness Reduction Act.  The revised draft guidance is now open for consultation until 11 December 2017 and will be finalised for publication in spring 2018.

NHC will be submitting a response to the consultation. Given the knowledge of NHC Members in supporting people experiencing homelessness, we would welcome your views and expertise to inform our submission, particularly on the following questions:

The guidance outlines that advisory services must be designed to meet the needs of persons in the authority’s district. What information could be included in the guidance to ensure that the content of the information provided via these advisory services, and the way it is delivered, is appropriate for different groups of people who are at risk of homelessness? (Sections 3.4-3.5)

The duty to refer requires public bodies to identify people threatened with or experiencing homelessness and pass information on to the housing authority (with the individual’s consent). How this works in practice is to be determined at a local level, but what guidance could be included about how public bodies can identify people who are at risk of or experiencing homelessness, and how public bodies should work together to share information? (Chapter 4)

Housing authorities will be required to conduct assessments and develop personalised housing plans, developing a positive and collaborative approach towards applicants. Assessments will include assessment of an individual’s support needs. What guidance could be offered to housing authorities to ensure that an assessment of support needs is effective and that applicants are empowered to disclose information?  (Sections 11.2, 11.11)

People can be penalised if they ‘deliberately and unreasonably’ refuse to co-operate with the housing authority. Do you think it is clear from the guidance what it means to deliberately and unreasonably refuse to co-operate and how housing authorities will ensure particular groups who may find it difficult to co-operate are not penalised?  (Sections 14.41-14.51)

Applicants can review decisions made by the housing authority. What information could be included to ensure a review process is fair? (Chapter 19)

The guidance includes specific sections on providing homelessness services for people who have experienced domestic violence or abuse (Chapter 21), care leavers (Chapter 22), people in contact with the criminal justice system (Chapter 23) and guidance on modern slavery and trafficking in relation to applicants who are threatened with homelessness or homeless (Chapter 25). Do you think there is any specific information that should be removed or added to these sections?

Please contact Karen Brown by 4th December 2017 with any views you would like to share with us on these issues, to ensure the Code of Guidance supports local authorities effectively to discharge their duties.