Openness and transparency
We are committed to being open and transparent; this is why we openly publish our documents so that you can see the way we operate. Being open and transparent is a key principle of good governance.
Lincolnshire Housing Partnership (LHP) is a charitable Community Benefit society registered under the Co-operative and Community Benefit Societies Act 2014. As a registered provider of social housing we are regulated by the Regulator for Social Housing and Homes England. We must comply with the Standards that together form the Regulatory Framework. We are also regulated by the FCA as a Community Benefit Society. HM Revenue and Customs make sure we comply with general charity law requirements.
All these regulators have various statutory requirements which we must comply with. They have rights of inspection and intervention in our dealings if we get things seriously wrong and we are obligated to supply prescribed information to them. You can read our last judgement or find out more information here.
Value for money
Value for Money (VFM) is intrinsic to the delivery of our strategic priorities and this document sets out our approach to ensuring we make the best possible use of our resources in order to maximise the available investment to support each of our priorities and that each pound spent delivers the best outcomes for our tenants in delivery of our corporate plan.
The Rules of LHP are the basis of its Constitution and follow the model National Housing Federation Model Rules 2015. Effectively the Rules are very similar to the Articles of a Company. They set out LHP’s charitable objects which are primarily founded on providing affordable homes for those in need for the benefit of the community. The Rules set out LHP’s powers for shareholders and the Board. There are detailed provisions dealing with the shareholders and holding general meetings. Each shareholder has a share worth £1 which does not attract interest or dividend. The Rules specify who is unable to be a shareholder and how shareholding ends. Rules relating to the Board sets out its composition, quorum, terms of office, meetings and declarations of interest amongst other matters.
There are also other provisions dealing with key roles such as the Chair and Chief Executive, financial control and audit, and statutory and miscellaneous matters.
The Constitution sets out how LHP is governed and, in addition to the Rules, includes Standing Orders, Terms of Reference, Scheme of Delegation and Financial Regulations. These set out the strategic and operational management and decision-making processes for the Board, its Committees and its employees. They are the main governance documents which support the Rules. They set out the terms of reference of the Board and its committees and how meetings are conducted. They also provide the scheme of delegation of decision making to the Executive to deliver services in line with Board’s set priorities. The Financial Regulations set out LHP’s financial management controls including accountancy, audit standards and procedures. The Regulations also govern how contracts procured and managed in conjunction with Procurement Rules. The Procurement Rules ensure that we secure VFM through appropriate levels of competition for goods and services we need to deliver our services. Without such robust documents we would be unlikely to meeting the regulators standards of governance or comply with legislation.
As a new entity formed from the merger of Shoreline Housing Partnership and Boston Mayflower, we have now developed a new corporate plan together with our vision and values as an organisation.
The LHP Group
LHP is the parent company of several wholly owned subsidiary companies. These subsidiaries are: Shoreline Property Services, Humber Homes, Speedwell Homes and Boston Mayflower Finance Plc.
Shoreline Property Services Limited (“SPS”) has been dormant since 2009. It was originally established to hold LHP’s direct labour organisation and was a trading partner until 2009 when a repairs and maintenance contract was entered into with an external provider and all activities within SPS ceased. The Board has resolved to wind the company up as being superfluous to future needs and this is in progress.
Humber Homes Limited has been mainly dormant since 2015. It was originally set up as part of the mechanisms for the redevelopment of the former Yarborough Estate now known as Freshney Green and was a party to the original Development Agreement. Boston Mayflower Finance PLC is a special purpose vehicle incorporated for the purposes of raising finance and is without any assets of its own. As a PLC the Company has some different statutory requirements to comply with.
Speedwell Homes Ltd’s purpose is to manage a small number of properties on behalf of private owners. The properties are leased and suitable tenants placed on 5 year fixed tenancies at market rent.
Relationships and controls between LHP and the Group are governed by agreements which includes intercompany services and charges.
LHP is committed to achieving the highest standards of probity and good governance in all its activities. LHP has adopted a probity policy which regulates payments and benefits, gifts and hospitality and deals with conflicts of interest situations for both Board members and employees. This policy:
Board member remuneration and expenses policy
This policy sets out the parameters which allow board members to claim expenses. These are to meet all reasonable expenditure for travel, accommodation and other expenses incurred by board members in connection with attendance at meetings with the board or committees of the board or general meetings or otherwise in connection with the discharge of their duties. The policy also sets out remuneration levels for Board members for carrying out their duties based on advice from an independent adviser and equivalent sector payment levels.
Recruitment and selection
We have a shareholders policy which sets out the way in which we appoint shareholders. Our Rules state that only a shareholder can be a Board member. We also have a Succession Policy which sets out how we recruit to our Board and plan for the future when vacancies arise. We recruit to the Board based on an annually reviewed skills matrix to make sure our Board always has a balance of skills and knowledge to meet out changing needs.
Board member code of conduct
We have adopted the National Housing Federation Code of Conduct. The conduct of board members impacts directly on our public reputation. Proper conduct by the board can dictate how effectively our money and assets are managed. The board members code of conducts sets out board members’ responsibilities in respect of acceptable behaviour and accountability and therefore is important in setting the culture for LHP and the leadership role of the Board.
Access to information, confidentiality, Data Protection and GDPR
We have provisions dealing with access to information, confidentiality and GDPR/data protection which ensures that our board members and employees understand the need to manage and use the information we hold properly and lawfully. We uphold the basic rights of customers to access the information held about them and ensure that we meet our obligations under the GDPR/Data Protection Act and associated legislation and guidance to ensure confidentiality is maintain properly, particularly where we hold personal information about our customers.
Anti-Fraud and Corruption Policy
This Policy sets out and explains the various forms of and offences which relate to fraud and corruption. It gives examples of such and explains the obligations which fall to Board and employees. The policy sets out how LHP will mitigate against the risk of fraud with various measures. An example of a key preventative measure is proper assurance in selection of the right staff with high levels of integrity and honesty. The Policy explains how concerns can be identified and dealt with. The Policy has a Fraud Investigation Plan which gives detailed guidance on the processes and procedures to be followed and responsibilities for investigating and acting on LHP’s response to acts of fraud and corruption.
Bribery Act Policy
The bribery act policy explains our actions to deal with the Bribery Act 2010 and sets out what measures we have taken to avoid instances of bribery and corruption within our business activities and when contractors are acting on our behalf. There is a corporate risk if adequate measures are not in place to prevent and minimise acts which fall within the definition of bribery.
Anti Money Laundering
This policy explains the various forms money laundering can take and the relevance of money laundering in respect of LHP activities. It sets out a summary of the relevant legislation and the responsibilities of employees to not ignore signs which indicate suspicions of an offence. Examples of transactions and behaviours of customers are given to assist employees. The need to obtain appropriate proof of identification in dealings which are higher risk is emphasised. Designated Roles required under the Act are explained. Appendices set out processes and procedures in dealing with cases and reporting on to enforcement agencies.
LHP has created this new policy to reflect changes in reporting mechanisms and included the ability for staff to externally report and investigate disclosures. LHP is committed to conducting business at the highest standards of equality, probity, integrity and propriety. We believe that effective communication among people at all levels promotes better business practice. As part of this commitment, LHP will not tolerate wrongdoing by employees at any level. To support this, we look to have an open and supportive culture and encourage both Board and Committee members and all employees to report any serious concern as soon as possible relating to one of the areas listed in this policy, in the way set out in this procedure, without fear of reprisals.
Modern Slavery Statement
Organisations with an annual turnover of at least £36m are required by the Modern Slavery Act 2015 to publish a Statement setting out what they are doing to stop modern slavery and forced labour practice occurring in their business and supply chains. The Statement sets out at a high level LHP’s Statement as to how it intends to comply with the Act with particular emphasis on procurement rules, processes and procedures and supply chains, and raising awareness.
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As part of our commitment to openness and transparency, we publish:
Lincolnshire Housing Partnership Limited registered as a charitable Community Benefit Society under the Co-operative and Community Benefit Societies Act 2014 with registered number: 7748. Data Protection registration number: ZA345449 Registered Office: Westgate Park, Charlton Street, Grimsby, North East Lincolnshire, DN31 1SQ