Engagement Plan from 22 December 2022 to 30 March 2023

Landlord name

Hanover (Scotland) Housing Association Ltd

Publication date

22 December 2022

Regulatory status

Working towards compliance

The RSL does not meet regulatory requirements, including the Standards of Governance and Financial Management, and it is working to achieve compliance.

Why we are engaging with Hanover (Scotland) Housing Association Ltd (Hanover)

We are engaging with Hanover because it is a systemically important landlord and about its service performance.

We refer to a small number of RSLs as systemically important because of their stock size, turnover or level of debt or because of their significance within their area of operation. We need to maintain a comprehensive understanding of how their business models operate, and how they manage the risks they face and the impact these may have. So we seek some additional assurance each year through our engagement plans. Given Hanover’s turnover we consider it to be systemically important.

Hanover identified failures to comply with its tenant and resident safety duties including, fire risk assessments, electrical safety inspections, lift inspections, asbestos management and legionella. It is committed to addressing the non-compliance as quickly as possible. It has developed an action plan to address the areas of non compliance and is making good progress in carrying out its programme to restore effective management of its tenants and resident safety duties. We are engaging with Hanover to seek assurance about its progress.

We are also engaging with Hanover regarding its plans to dispose of 38 tenanted properties. Hanover proposes disposing of the properties because of the level of investment required to upgrade the properties and ensure they meet energy efficiency standards. We are engaging with Hanover to seek assurance about its plans to consult with tenants about the proposals and rehousing plans. We require assurance that tenants’ interests are fully protected.

What Hanover must do:

  • provide us with monthly updates on progress with its action plan to address the tenant and resident safety matters; and
  • provide us with updates about its proposals to dispose of tenanted homes and its work to rehouse and consult tenants.

Hanover must also continue to provide us with copies of its Board and audit committee minutes as they become available.

What we will do

We will:

  • review the information Hanover provides regarding its action plan and engage as necessary;
  • engage with Hanover as it progresses its strategy to dispose of tenanted homes and ensure tenant interests are protected;
  • review the minutes of the Board and audit committee meetings and liaise as necessary;
  • meet with Hanover’s senior staff to discuss progress with its business plan which it has previously submitted to us and any risks to the organisation; and
  • update our published engagement plan when we have completed our inquiries into the tenant safety matters.

Regulatory returns

Hanover must provide us with the following annual regulatory returns and alert us to notifiable events as appropriate:

  • Annual Assurance Statement;
  • audited financial statements and external auditor’s management letter;
  • loan portfolio return;
  • five year financial projections; and
  • Annual Return on the Charter.

It should also notify us of any material changes to its Annual Assurance Statement, and any tenant and resident safety matter which has been reported to or is being investigated by the Health and Safety Executive or reports from regulatory or statutory authorities or insurance providers, relating to safety concerns.

Our lead officer for Hanover (Scotland) Housing Association Ltd is:

Joyce Stewart

Regulation Manager