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g320 Responds to NHF Code of Governance Review 2020

g320 welcomes the opportunity to respond to the final draft of the new NHF Code of Governance.

g320 are generally positive of the approach that has been taken by the NHF in this review and looks forward to members putting the code into practice.

About g320 London:

The g320 represents smaller housing associations in London, defined as those with fewer than 2500 homes. We act as advocates for smaller housing providers and represent their collective voice in the sector. G320 members play a strong part in developing housing solutions for our capital and we operate as a forum to promote good practice and to enable discussion and information sharing.

1) Are there any areas of the code you think are unclear? Our view is that this is a very comprehensive code which overall is well written, clear and concise. There are just a few areas where the drafting could be improved, for example in paragraphs 1.5 and 1.6, two sentences are repeated. Perhaps the section on integrity and conflicts of interest could be combined?

2) Is there anything significant missing from the code that we should consider adding? Generally, we think this covers the key areas. Perhaps a stronger emphasis on the positives of good governance – how it can energise and invigorate organisations – it’s not just a tick box exercise.

3) Is there any reason why your organisation would not be able to adopt the code?

No, we feel that there is nothing in it that would prohibit G320 members adopting the code. We believe the majority of our members currently follow the NHF Code of Governance 2015 and have found this helpful.

4) Are there any areas of the code where you believe further guidance or supporting documentation would be useful to support implementation?

We would like further guidance on applying the Code to group structures, particularly how the code will apply to both complex group structures and to simple ‘holding companies’ within a group. We would also like guidance on how Boards can obtain assurance on organisational culture and wonder whether an annual independent review of this may be onerous, depending on the size of organisation.

Some examples of ways in which the Code might work in practice would be helpful, including to different sizes and types of organisation, with and without group structures. These should not be prescriptive but would provide some suggestions to help Boards agree their own approach.

5) Are there any other observations you wish to make?

We agree with the four key principles underpinning the Code.

We welcome the focus on mission and values and on organisational culture. These drive our members’ strategy and delivery and are central to our assessment of Board and staff effectiveness.

We strongly agree that Boards must:

§ put residents at the heart of strategic decision making.

§ keep residents and staff safe and

§ identify and manage risk and that regular scenario testing is essential.

We welcome the increased focus on:

§ accountability to stakeholders, particularly to residents

§ equality, diversity and inclusion in governance.

§ sustainability.

Overall, we feel that this principles-based Code is very helpful. It is sufficiently challenging in a way that will help improve governance but not overly prescriptive.

For more information please contact:

Dean McGlynn, g320 Secretary


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