Anti-Social Behaviour Policy 2013

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1 Anti-Social Behaviour Policy 2013 Author(s)Name & Post Michelle Walters Anti-Social Behaviour Officer Version No: 1.2 Approval Date: 16 th July 2013 Review Date: August Document Control Sheet Title: ANTI-SOCIAL BEHAVIOUR POLICY Electronic File Name: Placement in Organisational Structure: Consultation with stakeholders/residents: Equality Impact Assessment: Approval Level: Dissemination Date: Method of Dissemination: Implementation Date:

2 2. Document Amendment History Version No. Date Brief Description

3 CONTENTS 1. Title 2. Policy Statement 3. Purpose 4. Scope 5. Objectives 6. Policy Details 7. Roles and Responsibilities 8. Monitoring, Evaluation and Review 9. Definitions and Abbreviations 10. Associated Documents 11. References 12. Appendices

4 1. ANTI-SOCIAL BEHAVIOUR POLICY 2. POLICY STATEMENT It is a requirement of section 218A of the Housing Act 1996 that we must prepare and publish a policy in relation to anti-social behaviour. It is also a requirement of our Regulators (Homes and Communities Agency (HCA)) to have an Anti-Social Behaviour (ASB) Policy that fulfils requirements in accordance to their Regulatory Framework for Social Housing April We, Friendship Care and Housing, have developed this Policy in accordance to these requirements: We are committed to providing safe and secure neighbourhoods. We believe that all residents should benefit from peaceful enjoyment of their home and environment. ASB seriously affects the lives of individuals and communities and its negative impact can lead to the decline in local areas and affect the well-being of individual members of the community. We will not tolerate any forms of anti-social behaviour. We will treat reports of anti-social behaviour seriously, and are committed to dealing quickly and effectively with these by working in partnership with other agencies, enforcing tenancy conditions, using preventative methods and when necessary and appropriate, the legal powers available to us. We will encourage and maximise levels of reporting of anti-social behaviour and ensure that our customers are able to report incidents easily and by using a variety of differing methods. 3. PURPOSE OF POLICY This policy sets out our approach and commitment to dealing with ASB effectively and efficiently in order to improve the quality of life for all our customers and the wider community. This policy will set out the remedies (legal and non-legal) available to us and who will be affected by this policy and its related procedures, including partnership working. It will set out the regulatory requirements and how we will work to ensure compliance, specifically the Regulatory Framework for Social Housing in England from April 2012, Neighbourhoods and Community Standard. It will set out our further commitment in tackling ASB in regard to the Respect ASB Charter for Housing SCOPE This policy applies to and affects our tenants and their families, other residents including shared owners, leaseholders, other landlords tenants and homeowners. It will also affect prospective tenants, our employees, Board members, prospective Board members, contractors, consultants, other stakeholders and external agencies.

5 5. POLICY OBJECTIVES To meet the requirements set out in the Regulatory Framework for Social Housing in England from April 2012, in particular the Neighbourhoods and Communities Standard. Please refer to appendix A. To honour our commitment to compliance with Respect ASB Charter for Housing. Please refer to appendix B. To work in partnership with the Police and local authorities as well as other partner agencies. To enforce tenancy and shared ownership conditions, using effective management interventions and a balance of prevention and support measures to include legal and non-legal measures. To provide a supportive and safe environment to customers to encourage reporting of ASB and make reporting accessible and easy. To have clear service standards that are published and available to customers in a variety of formats. To deal with ASB consistently and appropriately through prevention, diversion and non-legal measures which may include Mediation, Acceptable Behaviour Contracts, Good Neighbourhood Agreements, Parenting Contracts and youth diversionary activities. To make effective use of our Starter tenancy policies and procedures to deal with ASB caused by residents within the first 12 months of their tenancy. To use the full range of legal remedies available to us to tackle ASB. To pursue re-charges, compensation and criminal damage charges against perpetrators who wilfully damage our property. To publicise our successes locally, on our website and in resident publications to raise awareness of our work and to encourage further reporting of ASB. This will be authorised by a Senior Manager and on a case by case basis in accordance with appropriateness and suitability. To monitor our performance to assess the quality of our service, compliance with this policy and that our service standards are met. To actively seek feedback from our customers on their experience of our service, and take their views into account to improve the service and reflect a change in policy and procedure as appropriate. To share information with other agencies as appropriate with the customer s consent or in accordance with any formal information sharing protocols. To assess the vulnerability of all customers (complainant and alleged perpetrator) and offer assistance.

6 To provide support to victims of serious ASB, which may include target hardening measures such as removing or cutting back obscuring bushes or trees, fitting improved or additional locks to doors or windows, fitting security or fire-proof letter boxes, alarms, etc. We will also remove graffiti and make good damage which we are responsible for. An appropriate crime reference number must be supplied. To support victims in the event of serious ASB occurring that results in them wishing to move and we may, where appropriate, make temporary arrangements and/or seek to effect/facilitate a permanent move at the earliest opportunity. Whilst the interests of the victim are paramount, our emphasis is focused on the resolving the problem rather than moving the victim. To ensure robust evidence is available for court cases whilst having a victim centered approach giving full support to victims and witnesses. To ensure that we work in line with good practice and use relevant information from Housemark, Chartered Institute of Housing (CIH), Social Landlords Crime and Nuisance Group (SLCNG), Area Partnerships, training and workshops. 6. POLICY DETAIL We are committed in dealing with all reports of ASB effectively and efficiently in order to improve the quality of life for all our customers and the wider community. We have demonstrated our commitment in tackling ASB by signing up to the Respect ASB Charter for Housing on 28 th July The Charter has seven core commitments which are; Demonstrate Leadership and strategic commitment Provide an accessible and accountable service Taking swift action to protect communities Adopting a supportive approach to working with victims and witnesses Encouraging individual and community responsibility Having a clear focus on prevention and early intervention Ensuring a value for money approach is embedded in the service Our ASB procedures have been worked up in accordance with the associated Respect Toolkit. We will continue to work in partnership with other agencies (Police, ASB Units, Environmental Health, Safer Estates, Area Partnerships, etc) to prevent and tackle ASB in our neighbourhoods where we own homes. We are committed to developing new partnership opportunities as they arise and as appropriate. In accordance with regulation, we will ensure that

7 All tenants are made aware of their tenancy rights and responsibilities in relation to ASB, particularly new and prospective tenants at an early stage. We have a lead officer whose role is focussed in ASB showing strong leadership, commitment and accountability in preventing and tackling ASB. Our partnership working will reflect a shared understanding of responsibilities with partners and other local agencies. A strong focus exists on preventative measures tailored towards the needs of tenants and their families Prompt, appropriate and decisive action is taken to deal with ASB. ASB is dealt with fairly and in accordance with this policy and its related procedures. We will make full use of the range of legal and non-legal remedies available to us to ensure that ASB is dealt with swiftly and appropriately. These are set out in the related ASB procedures. The following Acts contain key legislation and powers to use either alone or in conjunction with the Housing Act 1996 in dealing with ASB. Housing Act 1988 (as amended) Environmental Protection Act 1990 Human Rights Act 1998 Statutory Nuisance Act 1993 Civil Evidence Act 1995 Housing Act 1996 (as amended) Protection from Harassment Act 1997 Data Protection Act 1998 Crime and Disorder Act 1998 Race Relations Act (as amended) 2000 Police Reform Act 2002 Anti-Social Behaviour Act 2003 Disability Discrimination Act 2005 Mental Capacity Act 2005 Housing and Regeneration Act 2008 The Government published a draft ASB bill in December 2012 that sets out new reforms in dealing with ASB. This policy will need to be reviewed when these new reforms come into force. The timescale indicated for this is September We are committed to welcoming and valuing diversity, promoting equality of opportunity and good community relations, and tackling discrimination in everything we do. We know that individuals can suffer ASB and discrimination on the basis of their gender, race nationality, ethnic or national origin, religious, cultural or political beliefs, disability (physical or learning, mental health, marital or civil partnership status, social background, family circumstances, sexual orientation, gender reassignments, spent criminal convictions, age or for any other reason. We will be fair and accountable, ensuring that there is no preferential treatment and that no one is disadvantaged.

8 We recognise that some individuals acting anti-socially may themselves be vulnerable. In these cases we will endeavour to work with appropriate agencies to offer help to the individual to enable him / her to modify their behaviour. We will use the influence we have to challenge and seek to eliminate inequality and disadvantage, and to create communities where people live well together because diversity is valued and respected. We will, when requested, make arrangements for this policy to be available in large print or on tape, will make arrangements for translation to assist an individual whose first language is not English or to talk through the policy will anyone who asks for help. In delivering this policy will we ensure compliance with our Equal Opportunities and Diversity policy and strategy. We will seek to ensure that a diverse range of tenants and residents are involved in shaping the service and that the needs of particular groups are considered. Confidentiality and Information Sharing Any information provided to us in respect of ASB will be treated in the strictest confidence in accordance with our Data Protection Policy and Procedure. Section 115 of the Crime and Disorder Act 1998 enables us to share information and discuss cases with our partner agency providing it is for the purpose of the reduction of crime and disorder. We will ensure that a separate ASB case file is opened upon receipt of a complaint of ASB. This will be kept separate from the house file if a Friendship / Beechdale tenant. This reflects good practice within the sector in relation to data protection and third party information. In accordance and to comply with the Data Protection Act 1998 and particularly the fifth principle, personal information is not to be kept for longer than is necessary for the purpose for which it is processed we will ensure that Records relating to offenders, ex-offenders and persons subject to cautions will only be held whilst the tenancy continues or be held on a need to know basis. Police sourced records may be confidential and must be dealt with as required by the Police. ASB case files and associated documents will be held for as long as necessary.

9 7. ROLES AND RESPONSIBILITIES The Board has ultimate responsibility for this policy and its related strategy, ensuring that statutory and regulatory obligations are met. The Executive Management Team is responsible for developing the organisational culture in which this policy can operate effectively and ensuring that it is implemented. The Anti-social Behaviour Officer, Managers and Team Leaders will have responsibility to ensure the principles of his policy are understood and implemented. All employees are responsible for ensuring the policy is incorporated into their working practices. Appropriate training will be given to staff to raise their awareness and to equip them to implement this policy and its related procedures effectively. Staff will take part in local networks and partnerships to enable them to make best use of resources available and to keep abreast of good practice, key developments in policy and legislation and local initiatives which are of benefit to our business and our customers. 8. MONITORING, EVALUATION AND REVIEW All reports of ASB will be reported on Contact Manager. All appropriate staff will be fully trained, using this policy and its related procedures. We will monitor and report our performance and have targets for ASB that will be set and reviewed annually. Staff will also report on their own individual target performance in accordance with procedures. Performance will be reported regularly to appropriate Boards, Committees and customers. Customers have been consulted fully in relation to this policy in particular our Reviewers Forum and BEES (Beechdale Estate Environmental Society). This policy will be reviewed in accordance with the Government reforms as mentioned above. Thereafter, every three years or sooner due to changes in legislation or good practice, particularly the Government ASB Reform indicated for DEFINITIONS AND ABBREVIATIONS Legal Definitions of ASB: ASB is defined in the following legislation as: Conduct causing or likely to cause a nuisance or annoyance to a person residing, visiting or otherwise engaging in a lawful activity in residential premises. Using or threatening to use residential premises for immoral or illegal purposes. (Housing Act 1996) Acting in a manner that causes or is likely to cause harassment, alarm or distress to one or more persons not of the same household as the perpetrator. (Crime and Disorder Act 1998)

10 Conduct capable of causing nuisance or annoyance to any person and which directly or indirectly relates to or affects the housing management functions of a relevant landlord. (Anti-Social Behaviour Act 2003) Abbreviations used in this policy: ASB Anti-social Behaviour 10. ASSOCIATED DOCUMENTS This policy is associated to the following: Anti-Social Behaviour Procedure Tenancy Agreement / Lease Domestic Abuse policy and procedures Racial / Harassment / Hate Crime policies and procedures Data Protection policy Starter Tenancy policy and procedure Safeguarding Adults policy Safeguarding Children policy Lone Working policy and procedures Equality and Diversity policy Re-Charge Policy Exceptional Social Needs Move policy & procedures 11. REFERENCES The Regulatory Framework for Social Housing in England from April Anti-Social Behaviour Hate Crime and Incident Policy, Gloucester City Homes, Anti-Social Behaviour Policy, Beechdale Community Housing, Respect ASB Charter for housing, June Social Landlords Crime and Nuisance Group (SLCNG) Bulletin No 507 (2013) Document Retention for Housing Associations. Summary Statement of Policy on Anti-Social Behaviour ASB, Derby Homes. Tackling anti-social behaviour: Tools and powers toolkit for social landlords, Department for communities & local government, 2010.

11 12. APPENDICES Appendix A. The Regulatory Framework for Social Housing in England from April 2012, Neighbourhood and Community Standard. Required Outcomes 1.Neighbourhood management Registered providers shall keep the neighbourhood and communal areas associated with the homes that they own clean and safe. They shall work in partnership with their tenants and other providers and public bodies where it is effective to do so. 2.Local area co-operation Registered providers shall co-operate with relevant partners to help promote social, environmental and economic wellbeing in the areas where they own properties. 3.Anti-social behaviour Registered providers shall work in partnership with other agencies to prevent and tackle anti-social behaviour in the neighbourhoods where they own homes. Specific expectations 1. Neighbourhood management 1.1 Registered providers shall consult with tenants in developing a published policy for maintaining and improving the neighbourhoods associated with their homes. This applies where the registered provider has a responsibility (either exclusively or in part for the condition of that neighbourhood. The policy shall include any communal areas associated with the registered provider s homes.2.local area co-operation 2.1Registered providers, having taken account of their presence and impact within the areas where they own properties, shall: Identify and publish the roles they are able to play within the areas where they have properties. Co-operate with local partnership arrangements and strategic housing functions of local authorities where they are able to assist them in achieving their objectives. 3.Anti-social behaviour 3.1Registered providers shall publish a policy on how they work with relevant partners to prevent and tackle anti-social behaviour (ASB) in areas where they own properties. 3.2.In their work to prevent and address ASB, registered providers shall demonstrate: That tenants are made aware of their responsibilities and rights in relation to ASB. Strong leadership, commitment and accountability on preventing and tackling ASB that reflects a shared understanding of responsibilities with other local agencies. A strong focus on preventative measures tailored towards the needs to tenants and their families.

12 Prompt, appropriate and decisive action is taken to deal with ASB before it escalates, which focuses on resolving the problem having regard to the full range of tools and legal powers available. All tenants and residents can easily report ASB, are kept informed about the status of their case where responsibility rests with the organisation and are appropriately signposted where it does not. Provision of support to victims and witnesses.

13 Appendix B. Respect ASB charter for housing June 2011

14 Introduction CIH, SLCNG and HouseMark are pleased to introduce Respect ASB Charter for Housing, the sector-owned replacement for the Respect Standard for Housing Management. Introduced by the government in 2006, the original Standard played an important role in driving up performance in both preventing and effectively tackling anti-social behaviour (ASB). Over 500 signatories are a clear testimony to its success over the last five years. ASB continues to be a key issue for landlords, tenants and communities, and when the housing minister announced in January 2011 that the Standard would be passed from government to sector ownership, CIH, SLCNG and HouseMark were delighted to be asked to take up the baton. The resulting Charter has been developed through wide consultation, and is essentially an updating of the Standard. Indeed, following the consultation process it was decided to retain the Respect name, it being well-recognised and understood within the sector. The Charter continues to be voluntary, and is a key part of the new, co-regulatory approach within housing. It should be noted that the Charter is not intended to be a wider community safety charter it is about landlords ASB services. However, the importance of partnership working in improving outcomes for service users is acknowledged throughout the Charter. Scope of the Charter The Charter aims to be outcome-focused and not prescriptive or process-driven. Its purpose is to improve ASB services, and consists of seven core commitments: 1. Demonstrating leadership and strategic commitment 2. Providing an accessible and accountable service 3. Taking swift action to protect communities 4. Adopting a supportive approach to working with victims and witnesses 5. Encouraging individual and community responsibility 6. Having a clear focus on prevention and early intervention 7. Ensuring a value for money approach is embedded in the service These commitments are supported by a series of building blocks based on sector good practice. By signing up to the Charter, landlords are making public their commitment to provide a high quality ASB service, and their accountability to tenants for its delivery. Smaller landlords with fewer resources may need to take a proportionate view of the commitments and building blocks within the Charter, whilst maintaining their key focus on outcomes for tenants. The Charter will continue to be based on a self-assessment approach and can be used as a framework for improvement, tailored to local needs and priorities. This Charter is intended for landlords, but it will be important for them to then consult with their tenants about what this means, locally, for them and for the services they expect from their landlord. It was very important that tenants were involved in the development of the Charter. Representatives from both TPAS and TAROE were on the steering group. The remainder of this document sets out the Charter itself. Information on how to sign up to the Charter and a list of current signatories can be found at

15 A note on language Several key words recur throughout the Charter and should be interpreted in their widest possible sense as indicated below: Tenant includes all types of potential tenants, existing tenants, residents, leaseholders, etc. Landlord refers to housing associations, stock retaining local authorities and (where appropriate) their ALMOs. Complainant is the person reporting the ASB to the landlord. Victim includes any person affected by the ASB. Witness refers to any person who has seen or heard the ASB complained of; it includes but is not restricted to individuals providing evidence in support of formal enforcement action(s). Perpetrator refers to individuals found to be responsible for committing anti-social acts or for permitting or encouraging such acts.

16 ASB Commitments 1. We demonstrate leadership and strategic commitment (There is strong leadership, corporate commitment and accountability about preventing and tackling ASB. This is embedded throughout our business and across key partners) Building Blocks 1.1 Our values, aims and objectives are reinforced by our approach to ASB and this approach is subject to ongoing ratification, assessment and review by both us and our tenants. 1.2 Tackling ASB is a core strategic and operational business activity and we will ensure that we commit sufficient capacity and resources to tackle ASB effectively. 1.3 We provide relevant training, capacity-building and support across all levels of the organisation (including staff, tenants, the governing body and relevant partners) that supports the delivery of a targeted action/service improvement plan for ASB. 1.4 We clearly communicate to all tenants that ASB will not be tolerated. Our staff and contractors are supported to identify and report incidents where they have been subject to or have observed ASB. 1.5 We proactively engage with relevant partners to support a joined-up approach to tackling the root causes of ASB and promoting positive behaviours. 1.6 We have performance management frameworks in place to report, monitor and review ASB performance. These include challenging performance targets and are also reflected in service plans at a team and individual level. Our ASB targets are subject to regular review and demonstrate year-onyear improvement. 1.7 Information on our performance against ASB targets is readily available and shared across the organisation to drive continuous improvement. It is regularly reported to our senior management, our governing body, partner agencies and our tenants. 2. We provide an accessible and accountable service (All our tenants can easily report ASB and access the service. Tenants are provided with useful and timely information and are actively encouraged to influence how we deliver the service) 2.1 All of our tenants can easily access our ASB services. 2.2 We collect information which helps us to understand local demographics and the overall profile of our tenants. We use this information to tailor how the service is delivered to individuals and to demonstrate equality in service provision. 2.3 We provide clear information which sets out what the service is, how it is delivered and how it can be tailored to meet local needs. All information about our services can be made available in a variety of formats, and translated into relevant community languages on request. 2.4 There is a range of ways for our tenants, including marginalised groups, to be involved in shaping the service. We do this routinely and systematically to support continued service improvements. 2.5 We publicise what we and our partners have done to tackle ASB in our communities - both our enforcement activity and the activities we do to prevent ASB occurring. Our approach balances the need to protect communities and build confidence that ASB will not be tolerated.

17 ASB Commitments Building Blocks 2.6 We take seriously all complaints about the services we provide. This is demonstrated in our overall approach to handling complaints which are regularly monitored against targets and contribute to the process of continual learning. 2.7 We regularly assess satisfaction with the ASB services and gather feedback on what we could do to improve them. We publicise survey results and customer feedback to our tenants. 2.8 We have mechanisms in place to allow our tenants to assess how we are performing. We provide our tenants with regular, robust and appropriate information in a format which has been agreed with them. Tenants are encouraged and empowered to hold us to account about the delivery and performance of our ASB services. 3. We take swift action to protect communities (We take prompt, appropriate and decisive action to deal with ASB before it escalates. In doing so, we adopt a problemsolving approach and have regard to the full range of tools and legal powers available) 3.1 Our staff are fully aware of the range of tools and powers available to them and our partner organisations, and know how to use them appropriately in accordance with our published policies and procedures. 3.2 We apply consistent and robust processes for managing ASB cases. 3.3 The actions that we take to tackle ASB are carefully considered and are proportionate to the effects of the behaviour on individuals, communities and the environment. 3.4 We have a proactive approach to gathering evidence and utilise a variety of available sources (i.e. multi-agency, non-housing management staff and contractors) to support action to tackle ASB. 3.5 We have strong working relationships locally and strategic links with partners (including local authority, police, and court services); we use these to investigate and tackle ASB. 3.6 We act swiftly when a perpetrator fails to engage with support provision and their behaviour does not improve. 3.7 We close cases appropriately, in a timely manner and, where possible, in consultation with the complainant. 4. We adopt a supportive approach to working with victims and witnesses (Our approach to case working demonstrates a strong focus on identifying and minimising risk) 4.1 Our management of ASB cases demonstrates a clear focus on protecting people from harm and on supporting victims and witnesses. 4.2 We have appropriate measures in place to identify and respond to both the risk to and vulnerability of victims and witnesses, including repeat victimisation. 4.3 Our staff are aware of and know how to access the support that is available to assess the needs of victims and witnesses on a case-by-case basis, particularly where victims and witnesses are vulnerable. 4.4 We agree action plans with complainants, update them regularly on the progress of their case and inform them directly of all key developments.

18 ASB Commitments Building Blocks 4.5 We ensure that individuals attending court are supported and we liaise with the courts where necessary to minimise any distress and any associated risks. 5. We encourage individual and community responsibility (We work with community groups and partners to promote tolerance and responsibility amongst our tenants and the wider community) 5.1 We can provide evidence of our work with tenants, tenant groups and leaders, and partner organisations to promote tolerance, balancing individuals liberties with their impact on others and the community (e.g. good neighbourhood agreements, tenants engaging in mediation, and restorative justice schemes). 5.2 We encourage and facilitate community involvement among tenants, including how individuals can support other members of their community to help us and our partners tackle ASB issues. 5.3 We take steps to find out about and effectively meet our tenants expectations of our ASB service. 5.4 Where appropriate and safe, we encourage self-help options to resolve more minor nuisance issues (e.g. encouraging complainants to talk to perpetrators, seeking to resolve the issue amicably and without recourse to the landlord). 6. We have a clear focus on prevention and early intervention (The preventative measures we use are tailored towards the needs of our tenants and their families. We also provide, whether directly or via our partners, effective support to enable perpetrators to change their behaviour) 6.1 Our policies for allocations and lettings contribute to preventing ASB and nuisance, and promoting neighbourhood sustainability. 6.2 Our tenancy agreements set out clearly what we mean by ASB, the standards of behaviour we expect of all tenants and the sanctions that we may apply to those who behave in an anti-social manner. We reinforce these key messages at tenancy sign-up and set them out in publicity that is available to our tenants. 6.3 We proactively engage with partners to address the causes of ASB and to reduce the opportunities for it (e.g. through the appropriate provision of services such as warden patrols, CCTV and/or other measures). 6.4 We work with our tenants and with partner agencies to identify ASB hotspots and use the information to target resources. 6.5 We use a range of early intervention techniques to prevent ASB from escalating. 6.6 We proactively engage with our tenants and with partner agencies to provide diversionary activities (e.g. facilities for young people) and to evaluate their impact. 6.7 Our staff are able to access services to provide support to vulnerable individuals.

19 ASB Commitments 7. We ensure that a value for money approach is embedded in our service (We can demonstrate a strong focus in securing efficiency and effectiveness by balancing cost and quality) Building Blocks 7.1 Value for money is understood and embedded in our work; it is part of our performance management framework, determines resource allocation and is widely communicated to staff who are encouraged to identify value for money opportunities. Resources are used effectively and efficiently. 7.2 We understand the cost of the ASB service, including elements such as staffing costs, responding to ASB incidents (e.g. criminal damage, graffiti, fly-tipping) and of making use of various ASB tools. 7.3 We know how we are performing in delivering our ASB service, and how satisfied service users are. Costs, performance and satisfaction are benchmarked against comparative providers and demonstrate value for money. 7.4 There is an evidence-based approach to budget-setting and this is linked to the annual service improvement plan. 7.5 We know whether we are getting value for money for procured services (e.g. mediation, support services, professional witness services) and we have, where appropriate, undertaken joint procurement and considered shared services. 7.6 Through tenant scrutiny arrangements, tenants are provided with appropriate information on comparative service costs, performance and satisfaction, enabling evidence-based value for money judgements to be made. Consultation on changes to the service includes a cost-benefit analysis, so tenants can make informed value for money choices.

20 Information on how to sign up to the Charter and a list of current signatories can be found at 20

21 21

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