Helen White is even more convinced about the importance of early engagement with the regulator after her recent experiences as chair of a housing association in England.
We need to make sure the focus on good governance remains at the top of the agenda. You will have heard me say this many times, chances are you’ll hear me say it again. I have always believed that part of the value I bring to the role of chair of the Regulatory Board for Wales is the lived experience of being a housing association chair.
The most valuable learning I have gained over the years has not been when things are going well. Quite the opposite. Working though the issues I have faced recently at Knowsley Housing Trust (KHT), when we believed as a Board that we had assurance on our regulatory compliance, only to find we didn’t, has been the hardest and most difficult challenge I have ever dealt with. It has made me ask the question many times, how did we get to this point?
Throughout it all I have remained focused on doing the right thing for our tenants, being open and transparent, and making sure we learn all the lessons and make the necessary changes to improve. I intend to do more on the lessons I’ve learnt in the future. But for now I would like to share this; if you identify an issue in your housing association, early, proactive and transparent engagement with the Regulator is vital. If you find yourself thinking.. should I tell the Regulator? The answer is.. YES!
Launch of the new Code
I welcome the launch of the new CHC Code of Governance. The Regulatory Board for Wales recognises the importance of the Code as a set of principles and recommended practice to support effective governance and regulatory compliance. The move towards a focus on organisation culture rather than process should be seen as a positive step forward, recognising the responsibility to shape appropriate and robust governance arrangements rests with each Association. I hope this really pushes Boards to think very hard about what great governance looks like for their organisation. CHC Chief Executive Stuart Ropke quite rightly set out his ambition for housing associations to be the best governed organisations, not only in Wales but across the whole of the United Kingdom and beyond. If this is to be achieved a ‘tick box’ process based approach to governance won’t be enough. I am pleased to see the shift of focus.
However, each Association must demonstrate to the Regulator that is has adopted the most effective governance model and it is being implemented correctly. One of the Regulatory Frameworks performance standards requires housing associations to adopt and comply with a code of governance. In Wales, almost all associations have adopted the CHC Code. The Board must be satisfied it can robustly demonstrate to the Regulator that is complies with the new Code. The need for board members to discuss the Code’s principles and recommended practice should drive lots of debate and discussion at Board meetings.
How do you know what you know?
I am acutely aware through my own experience as a Chair of a housing association that driving a more generative approach to governance can and should only be built upon a solid foundation. I know only too well that things can and do go wrong. Boards need to be very clear and confident in the processes in place that enable them to feel confident in the information they receive. I appreciate this is sometimes a difficult line to tread as a Board member. But how do you know what you know? How confident are you in the information you receive? This isn’t about questioning and challenging every statistic. It is about making sure the assurance framework you have in place is robust, applied effectively and tested often.
This, quite rightly, brings a greater focus on the role of the internal audit. This is an area I would like to see explored further in the near future to ensure Boards are clear on its purpose. As I’ve said previously about the role of the Regulator, internal audit should not be viewed by the Board as the ‘safety net’. It needs to be part of a much more considered approach to assurance and risk.
Of all the Board traits I witness, it’s those who bury their heads in the sand that are the biggest cause for concern. Now of course, I’m not saying every Board has major problems they don’t know about, but I am saying all Boards need to be acutely aware that no business is immune to at best, a bump in the road, and at worst a catastrophic event. So Board members, if you’re not feeling a tad anxious or slightly uncomfortable it’s time to get real. Think everything is perfect? Look again, as I guarantee it won’t be!
Helen White is chair of the Regulatory Board for Wales