Why we are engaging with Sanctuary Scotland Housing Association Ltd (Sanctuary Scotland)
We are engaging with Sanctuary Scotland about its service quality, development plans, a small transfer of homes and because it is a systemically important landlord.
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 Sanctuary Scotland’s size, turnover and level of debt we consider it to be systemically important.
Sanctuary Scotland is one of the largest developers of new affordable housing in Scotland and has plans to grow through a considerable programme of new homes for social rent and mid-market rent. Sanctuary Scotland will receive significant public subsidy to help achieve this.
To assess the risk to social landlords we have reviewed and compared the 2023/24 service quality performance of all social landlords to identify the weakest performing landlords. We will therefore engage with Sanctuary Scotland about percentage lets to homeless, repairs and factored owner satisfaction.
Sanctuary Scotland will also progress a small transfer of homes from Inverclyde Council.
What Sanctuary Scotland must do
Sanctuary Scotland must:
- send us copies of its Board and audit committee minutes as they become available;
- send us an update on its development programme by 31 October 2025. This will include its latest report to the governing body/appropriate committee about development and details of the scale and tenure mix, timescales for delivery and any material delays or changes to the programme;
- tell us if there are any material adverse changes to its development plans which might affect its financial position or reputation, in line with our notifiable events guidance;
- review its performance for percentage lets to homeless, repairs and factored owners and consider what improvement action it needs to take; and
- provide updates on progress with the transfer of homes from Inverclyde Council.
What we will do
We will:
- review the minutes of the Board and audit committee meetings and liaise as necessary;
- observe Sanctuary Scotland’s Board;
- meet with Sanctuary Scotland’s senior staff to discuss its business plan and any risks to the organisation;
- review the development update and engage as necessary;
- review Sanctuary Scotland’s service quality performance as part of our 2025/26 risk assessment;
- review the update on progress with the transfer of homes from Inverclyde Council and engage as necessary; and
- update our published engagement plan in the light of any material change to our planned engagement with Sanctuary Scotland.
Regulatory Returns
Sanctuary Scotland 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.