Code of Governance

Completed: This piece of work was led by the Chief Transformation Officer and signed off by the Board during the year. It was launched internally at the Leaders and Managers Conference at the start of 2026

Completed: The information was uploaded to the Great Places website on the handover date of 11th September 2025. All relevant changes were made on companies house and with the FCA, and a range of internal communications was also undertaken to introduce colleagues to the new Board and Committees.

Completed: The new Growth Committee was established with key changes being made to the Code of Governance including the new terms of reference and role profiles for the committee. Cube has been subsumed into the coterminous arrangements for the Board, and all entities have had an update to their governing documents. Early feedback from the Board appraisal process has demonstrated strong satisfaction and confidence with the new Committee arrangements.

Completed: Altair were commissioned to carry out the biennial review of NED remuneration, as well as independent committee remuneration as per the policy. Following recommendation from the Remuneration and Appraisal Committee, the Board agreed the proposed changes to ensure remuneration remains in line with market benchmarks.

Completed: A briefing for all NEDs was produced outlining potential conflicts of interest whilst on the coterminous Board, as well as a standard operating procedure for the Governance team to ensure that papers, agendas and minutes clearly distinguish entity-level decisions as appropriate.

Completed: All induction and onboarding activities were carried out as planned, with the feedback from the new Board and Committees being overwhelmingly positive regarding the process.

After a successful first year of delivery, 2025-2026 saw us work through our second year of the 3-year Corporate Plan “Here for our Customers” which affirms that we want to be:

• Great for our customers
• Great for our homes and communities
• Great for our business

In 25-26, there has been excellent progress in delivering the complaints and repairs reviews, with early signs of improvement as a result. The multichannel communications platform has been rolled out and has now been closed as a priority.

The management accounts review has been extended to a wider finance programme and will continue into year three.

The plan focused on 5 key priorities in the areas of property, data, compliance, management accounts and a multi-channel communications platform. Strong performance has been achieved in all of these areas, despite this being a hugely ambitious programme. Going into year three there are two new priorities: Customer Services and Building Professional Excellence, with these being a focus into 26-27.

Our vision, values and operating principles remain strong and relevant.

Our Vision

• Great Homes: Maximising our investment in safe, sustainable homes
• Great communities: Building successful, vibrant communities
• Great people: Providing outstanding customer service and support

Our Values

• We are fair (fair, open and accountable)
• We care (know, respect and care about our customers)
• We appreciate (appreciate the effort of everyone who works here)
• We partner (promote partnerships, efficiency and value for money)
• We innovate (passionately embrace creativity, change and innovation)

Operating Principles

We also have a set of clear operating principles. These are the building blocks that we recognise, from a customer, regulatory and financial perspective, we need to do well to achieve the overarching aims of the business.

• We protect our financial strength
• We exercise good governance
• We respect equality, diversity and inclusion

Great Places has always placed customers at the heart of decision making and has sought to include the customer voice where possible when making all major decisions. Our Board maintain a focus on customers by receiving regular updates on customer complaints, compliments and focused reports from our customer scrutiny group on specific areas of the business where there is an impact on customers.

2025-2026 saw a strong second year for the committee with them carrying out scrutiny of key parts of the corporate plan including the complaints and repairs review, as well as signing off the Housing Ombudsman Service self-assessment, reviewing the work of the Social Value and Independence and Wellbeing teams and inputting to the new Customers and Communities Strategy.

The members of the committee have also added value by supporting recruitment and attending conferences on behalf of the organisation, representing Great Places at a national level.

The below information shows how we involve residents and customers and get information from them, how the Board gets this information and uses it and finally how we close that feedback loop by sharing the information. The Board actively direct activities within the business based on the feedback it receives.

How we capture insight from customers

• Customer Committee – feedback and input
• Customer complaints – feedback and compliments
• Customer Scrutiny Group (Insight)
• Customer Satisfaction Surveys
• Community Investment Activity
• Meeting customers on stock tours
• Customer engagement activity – surveys, face to face consultations and digital forums
• Informal channels – Hub, Neighbourhoods (patch-based models), I&W and Plumlife
• Our Voice – customer engagement portal

What the board does with the insight from customers

• Review the Customer Experience Dashboard
• Respond to Ombudsman’s annual report and self-assessment
• Approve Customer Experience and Customers and Communities Strategy
• Review the Great Communities Report
• Consider ‘Customer Stories’ and service-specific reports incorporating customer voice
• Hear from the Customer Scrutiny Group (Insight) and agree actions as a result of those reviews. Progress is then monitored by the new customer committee

How we share feedback with customers & colleagues

• Website
• Plumlife and PFI Newsletters
• Corporate Reports including Annual Complaints Report, ESG and Quarterly Performance Updates
• My Great Place magazine
• Monthly e-news bulletins
• Email and Social Media Campaigns
• Internally via HOME and podcasts
• Publication of our TSM results
• Leaders and Managers Conferences
• Colleague conferences

Great Places has always had a strong focus on Equality, Diversity and Inclusion (EDI) for both our customers colleagues and Board. Key to this is having strong data as a baseline, using different ways to capture insight on EDI and going above and beyond the minimum requirements to ensure we are doing everything possible to use this information to improve where we can. Our Inclusive Services team have done a fantastic job improving the data we hold significantly, helping us understand the detailed demographics and needs of our customers enabling us to tailor our services. They will continue to work on this data aspect as we look to mainstream this activity to make it ‘business as usual’.

The below demonstrates our approach to insight around EDI:

What the Board does with the insight on EDI

• Approves Diversity, Equity and Belonging statement
• Approves the Customer Experience Strategy which includes our approach to EDI
• Discuss EDI specific matters at Board away days and Topic sessions
• Reviews EIA Summaries on policies and service changes
• Approves the Gender, Disability and Ethnicity Pay Gap Reports
• Reviews the Great People and Safeguarding Reports which consider EDI matters
• Reviews customer stories and gets feedback from customer-facing colleagues
• Considers equality of service based on information from TSMs
• Approves and receives updates on programmes and innovations aimed at improving EDI representation

How we capture insight on EDI

• Customer/community profile and demographics (supported by the Inclusive Services Team)
• Colleague forms and Cascade Intelligence
• Customer and colleague input to the EDI strategy
• Partnership work including benchmarking key metrics
• Colleague and customer feedback and insight
• Co-Production (e.g. Housing First)
• Accreditation feedback
• Information and analytics from the tenant satisfaction measures

How we share feedback with customers & colleagues

• ESG Report has a section on EDI
• Statutory publications
• Customer and Colleague communications and campaign work
• DICE Reports (GMHP) and the NHF EDI Data tool
• Customer Communications on EDI
• Information through HOME and podcasts

The Board operates openly and transparently with all colleagues at Great Places, with the full Code of Governance available on our intranet pages. Each year our statutory financial statements and accounts are published as well as our Customer Annual Report which outlines the work that has been undertaken in the previous year.

The Board also welcomes scrutiny on key areas of the business from our Customer Insight Group, who report to the Board directly three times a year. As outlined above, this has been enhanced through the Customer Committee, whose chair sits as a member of the Board and provides a direct link between the committee and the Board.

Information about our Board, who they are and their declarations of interest are all available on the Great Places website.

• Great Places Board

Great Places has a 3-year corporate plan in place called “Here for our Customers” as well as annually approving the Business Plan which reflects the continuously changing operating environment. The Board also reviewed our 10-year ambitions in 2025/26 taking a long-term view of where we want to be in 2035/36.

The Code of Governance contains many provisions relating to the Chief Executive who has the delegated authority to oversee and manage the operational delivery of the organisations strategies and plans. These clauses include ensuring that there is a rigorous contract of employment in place, that they are remunerated accordingly, that their role and delegated authority is documented and that they are subject to annual appraisal which is overseen by the Board. Locally we also have a nominated deputy policy in place to ensure the effective running of the organisation in the event of the CEO’s absence. We have reviewed all these provisions and can confirm that we are fully compliant with them all.

Great Places operates with a coterminous Board which represents Great Places Housing Group, Great Places Housing Association, Plumlife Homes, Terra Nova Developments – and as of 2025, Cube Homes Limited. From 2025 a new Growth Committee was established to ensure stronger oversight of development activity, composed of a mixture of Non-Executive Directors and Independent Members with expertise in land, development and property.

Reviews of our diverse activities and structures are carried out annually and the current structure of Great Places, including reference to our joint ventures (predominately Hive Homes and Forge New Homes), is shown as follows. Following a recommendation from our Triennial Governance Review, we have agreed to enhance this oversight with more regular reporting going forward.

2025-2026 saw a new Chief Customer Officer come into post following the retirement of their predecessor. Anew Chief Transformation Officer was also appointed to lead the strategic and cultural transformation of Great Places, enhancing service delivery and operational efficiency.

Great Places colleagues continue to give positive feedback in our all-colleague surveys. And then continue as normal. The comparable questions that feature in all surveys have the highest positive response with ‘I know and understand what Great Places vision and values are’ scoring 95% and ‘I’m motivated to achieve Great Places purpose, vision and values’ now 91%. This takes our overall engagement score to 90%, a 3% increase on previous scores and exceeding the 85% stretch target.

The benchmark question ‘How satisfied or dissatisfied are you with the organisation as an employer?’ had an 84% positive response, putting Great Places comfortably above the median of 80.15%.

The main points of feedback from the workforce continues to be pay and reward. Therefore this year a new Pay Policy was developed and approved which reinstated pay progression for colleagues enabling them to progress within the organisation. This had been a priority for the Remuneration and Appraisal Committee and was launched in March 2026.

The organisation has a large number of performance indicators across the themes of Great Homes, Great People, Great Communities as well as some cross-cutting measures.

12 of these are highlighted as ‘Signals for Success’ which are high-priority measures, and these are reviewed and targets set annually by the Board. Examples of the measures include Development starts on site, interest cover EBITDA-MRI, leavers within the first 12 months and sickness absence days lost. The Board received regular report at each meeting which look at these as well as ‘homes of concern’ measures and a balanced scorecard outlining performance in key areas.

Throughout the year, the Board also receives reports from all areas of the business. These are a mixture of Executive reports, strategies, policies, performance updates, topic sessions, risk reports, approvals and information items for consideration. These enable the Board to have both the breadth and depth of information required to manage performance.

A task and finish group of the Board have reviewed these Signals for Success for 2026-2027 and have agreed to include new measures focusing on a range of customer satisfaction measures, colleagues satisfaction and development completions along with revised targets for the year.

Our company rules, Memorandum and Articles of Association and enhanced Code of Governance clearly outline the roles, responsibilities and functions of the Board and its three Committees. These were all updated in September 2025 along with our intra-group agreement to reflect the structural changes at group level including the new committee and the addition of Cube Homes to the Coterminous Board.

Each role including those of Chair, Cube Chair, Committee Chair, Co-optee and Non-Executive Director has its own role profile which confirms their responsibilities and restrictions on their role.

There are also detailed Schedules of Reserved Matters and Schemes of Delegations which clearly articulate those matters which are solely reserved to the Board (and Shareholders at AGMs). It also identifies those which are delegated to Committees of the Board, the Chief Executive and those which can then be delegated further as part of the operational running of the business. A Scheme of Financial Delegations, Asset Management Delegations and Delegations to support The Homes England Strategic Partnership (2) are also in place to support this.

There are four standing Committees of the Board: Audit and Assurance, Remuneration and Appraisal, Customer Committee and the Growth Committee which provide more in-depth scrutiny to specific areas of the business and report these to the Board. These Committees have a Chair who is also a Non-Executive Director of the Board and all four have a terms of reference document which clearly states their responsibilities and reporting lines. The Customer and Growth Committees include Independent Members who sit by virtue of their expertise in that area. Task and Finish Groups are also convened from time-to-time to focus on specific tasks (e.g. Signals for Success and target setting, Board Recruitment, Executive Recruitment etc.)

The Board can have up to 12 Members including Executive Members at any time. Board succession is considered regularly by the Remuneration and Appraisal Committee and an annual exercise is undertaken by the Board to identify skills, knowledge and experience which exists on the Board and where there may be gaps to be filled in the future. This continues to be an effective means of identifying skills gaps on the Board and has been used as part of the recruitment of the new Chair and Non-Executive Directors.

Recruitment processes are open, fair and both value and merit-based; and are tailored to ensure that we are recruiting to meet any gaps identified as part of the appraisal process. This could include a particular area of expertise, or to ensure that we recruit those with specific lived experience or where their unique perspective is reflective of our customer base.

The Board of Great Places are remunerated at a fair market rate which is biennially reviewed and benchmarked by external consultants to keep pace with the market. Emoluments are always disclosed as part of the financial reporting each year and are reported to the Remuneration and Appraisal Committee.

The Great Places website has a dedicated page which profiles our Board, their skills, attributes, experience as well as their published declarations of interest for transparency purposes. Oversight with more regular reporting going forward.

Great Places conducts all Board and Committee meetings effectively, as endorsed by our maintained G1 rating at our most recent Regulatory Inspection in 2024. An annual process for reviewing the effectiveness of not just individuals, but also Board and Committees more generally is conducted; and actions for improvement are acted upon. The annual governance calendar is agreed up to 6 months before year end and an urgency process can be used if decisions are required between meetings. Meeting papers are published in advance giving the Board sufficient time to read them and make comments and observations using the online system. Each meeting also has a standing item allowing the Board to comment on the effectiveness of the meeting, changes to the risk profile resulting from decisions made in the meeting and add suggestions for improvement.

The Board undertakes a formal, annual review of its performance and effectiveness; and this is supported by a Triennial Review of our Governance arrangements by an external organisation. All Board Members receive an induction to the business, along with ongoing opportunities for learning including topic sessions, away days, access to conferences and events as well as internal opportunities for improving profile and getting to know the business. A comprehensive appraisal process is carried out with peer-review every two years, with a scaled-back version on an annual basis. The results of these are reported back to the Board and an action-plan developed.

Our annual financial statements and accounts, as well as Internal Controls Assurance Statements, are the means by which we confirm that we are compliant with the NHF Code of Governance. Our internal process for demonstrating compliance is a rigorous self-assessment against each element of the Code and the collation of an evidence chest which supports our stated compliance and areas where we are required to explain.

Positively, we are compliant with all provisions in the Code of Governance. However we continue to strive for excellence and are always looking at ways we can continue to meet and exceed the requirements of the Code.

Great Places has a standing Audit and Assurance Committee which meets 5 times a year and has oversight of both internal and external audit, as well as the Great Places internal process for control assurance. The Committee reports regularly to the Board and also holds in-camera meetings with the external auditors at least annually (without any Executive Directors present), but also at each meeting if required (as a standing item).

The Committee has responsibility for reviewing all internal audits throughout the year, as well as considering the effectiveness of internal audit arrangements and the re-procurement of internal audit. The Committee provides robust challenge to the auditors, as well as to the Executive Team and colleagues where there are concerns or adverse findings and have routinely asked for follow-up reports to be provided between scheduled meetings.

The Committee is strongly involved in the annual statutory reporting process, agreeing this timeline with the external auditors and signing off the statements and financial notes and recommending these to Board. This includes all other aspects of assurance including compliance with standards, relevant law, codes of conduct and this Code of Governance, as standard items included in the accounts.

The Board at Great Places receive Risk Reports throughout the year and maintain overall responsibility for risk management and oversight. The Audit and Assurance Committee also carry out deep dives into specific risks, as well as reviewing and recommending the risk appetite of the organisation before recommending to the Board for approval. As well as oversight of the risk register, we also maintain watch-lists for new and emerging risks and changes in the sector and specific documents also relating to health and safety risks which are a high priority. The Audit and Assurance Committee similarly receive these reports at their meetings throughout the year.

In conjunction with the Finance Team, risks are also considered as part of the annual business planning process as part of carrying out stress testing and developing the mitigations schedule; in assessing what potential risks could ‘break’ the plan. This has been significantly enhanced this year with multi-variate stresses being considered and these were positively received by the Board and our stakeholders. Alongside the robust business continuity planning at Great Places, these offer us strong resilience to potential risks faced by the organisation.

Great Places has a ‘Speak Up’ Policy which covers our arrangements for whistleblowing and is clear on the process to be followed if anyone has concerns about the conduct of any of our colleagues or Board Members. The Chair of the Audit and Assurance Committee is the designated contact for issues which may require independent investigation, or where people may be uncomfortable escalating to the Chief Executive.