Community Partnerships and Growth (CPG), Housing

SA

Contract Management Frameworkpertaining to the Community Housing Agreement

June 2015

Contents

Glossary 2

Foreword 4

Introduction 5

Scope 6

Key principles 7

Role of the parties 7

Contract initiation 8 1.1 New funding 91.2 Contract execution & handover 9

Contract performance management 10 2.1 Reporting 112.2 Monitoring 122.3 Performance management 132.4 Record keeping 16

Contract administration 17 3.1 Contract review, extension and variation 183.2 Contract termination 183.3 Core operating policy variation 193.4 Managing contractual disputes 19

Appendices 20 1. Key performance indicators & data sources 212. Contract initiation: new funding, contract execution & handover process 223. Contract management: reporting & monitoring process 234. Contract management: performance management process 245. Contract administration: contract variation process 256. Contract administration: management contractual disputes process 26

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GLOSSARY

community housing means housing for people on a very low, low or moderate income or for people with additional needs that is delivered by non-government organisations (registered community housing providers).

Community Housing Agreement means an agreement entered into between the South Australian Housing Trust (SAHT) and a community housing provider, pursuant to section 20 of the Community Housing Providers (National Law) (South Australia) Act 2013 and includes:

The Master Community Housing Agreement, including all attachments, annexures and schedules to it; and

Any agreement, deed or instrument executed under or which is subject to or bound by the Master Community Housing Agreement (including but not limited to project agreements, deeds of statutory charge and pre-existing agreements).

community housing assets has the definition as provided for by the Community Housing Providers (National Law) (South Australia) Act 2013.

Community Housing Customer Register (CHCR) means the register of that name which comprises a list of persons seeking access to community housing (or any replacement register determined by South Australian Housing Trust (SAHT) maintained by SAHT.

community housing provider means an entity that provides community housing.

Community Housing Providers (National Law) (South Australia) Act 2013 means the community housing legislation in South Australia.

contract manager means the Renewal SA employee responsible for managing the contractual relationship between the South Australian Housing Trust (SAHT) and the community housing provider under the community housing agreement. The contract manager will act as the key contact point for community housing providers regarding contractual matters.

core operating policies mean the policies published by the South Australian Housing Trust (SAHT) relating to the operation of community housing by community housing providers and includes, but is not limited to, the Core Operating Policy: Eligibility, Community Housing Maintenance Accommodation Standards and the Community Housing Rent Policies. The core operating policies in existence at the date of execution of the community housing agreement are attached to the Master Community Housing Agreement as Attachment E.

funder means the South Australian Housing Trust (SAHT).

Office of Housing Regulation (OHR) is the office established to support the Registrar, Community Housing to perform the duties assigned under the Community Housing Providers (National Law) (South Australia) Act 2013.

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party means a party to the community housing agreement.

performance report is the report to be analysed by contract managers periodically throughout the term of the community housing agreement. The performance report enables contract managers to assess the performance of a community housing provider in delivering the agreed contractual outcomes and also provides an early intervention mechanism for addressing any issues or concerns that may arise.

project property has the definition as provided for by the Master Community Housing Agreement.

Renewal SA is the trading name of the Urban Renewal Authority and has delegation to act on behalf of the South Australia Housing Trust (SAHT) in relation to the funding of community housing in South Australia. This includes, but is not limited to, responsibility for ensuring community housing providers comply with the terms of their community housing agreement with the SAHT to deliver quality community and affordable housing outcomes.

significant issue means a performance issue deemed to have the potential for serious negative impact on tenants, community housing assets or the reputation of the community housing sector. A significant issue may also exist where:

Minor performance issues continue to occur or escalate; or There is a continual lack of engagement by the community housing

provider to address the identified issue; or There is a continuing absence of adequate reporting required for KPI

assessment.

South Australian Housing Trust (SAHT) is the statutory corporation incorporated under the provisions of the South Australian Housing Trust Act (1995) (SA) that is party to a community housing agreement with a community housing provider.

unresolved failure means a community housing provider has not taken adequate action to remedy an identified significant issue and is deemed non-compliant with the requirements of their community housing agreement. Unresolved failure will be reported to the Office of Housing Regulation.

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FOREWORDCommunity housing providers have managed government subsidised social and affordable housing program properties and tenancies in South Australia since 1979. Providers’ management structures vary, as do their size, location and target group, however all providers deliver housing for disadvantaged South Australians on low to moderate incomes.

The Community Housing Providers (National Law) (South Australia) Act 2013 (‘the Act’) introduced a standard system of regulation for providers nationally. This led to the separation of regulatory, policy and funding roles at state government level and significant sector consolidation.

The new legislative and policy arrangements require providers to register under the Act by demonstrating compliance with the National Regulatory Code. The Office of Housing Regulation (OHR), established in 2013, is directly responsible for the registration and ongoing regulation of registered community housing providers against this Code.

Renewal SA, acting on behalf of the South Australian Housing Trust (SAHT), is responsible for funding community housing providers in South Australia. This includes pro-actively managing the contractual relationship between the two parties relating to the delivery of quality community housing outcomes for low to

moderate income South Australians.

All funding agreements previously contracted under the repealed South Australian Co-operative and Community Housing Act 1991 (SA) are to be re-negotiated and consolidated under one standard contract, the Community Housing Agreement (‘the Agreement’). This new Agreement streamlines reporting requirements and applies consistent performance monitoring by government across all project properties. A suite of core operating policies linked to the Agreement further establish how community housing properties are to be managed.

The purpose of this Contract Management Framework is to ensure the contractual relationship between the SAHT and community housing providers is managed equitably, transparently and accountably by Renewal SA.

Renewal SA will continue to work in partnership with the sector to further refine these working arrangements and practices.

Diagram: Links between legislation, policy and the community housing agreement

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LEGISLATION

SA GOVT POLICY & PROCEDURES

DEPARTMENTAL POLICY & PROCEDURES

COMMUNITY HOUSING CORE OPERATING POLICY & PROCEDURES

COMMUNITY HOUSING

AGREEMENT

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Introduction

SCOPEThis document sets out Renewal SA’s approach in this regard as it relates to a community housing agreement entered into by registered community housing providers, pursuant to the Community Housing Providers (National Law) (South Australia) Act 2013.

The document focuses on long term management contracts where title is held by the community housing provider. Contracts for development and construction are not dealt with in detail. Nor does the document deal with leasehold arrangements between SAHT and community housing providers.

A robust contract management framework will guide both contract parties to take action to improve community housing delivery.

It also assists Renewal SA (on behalf of the SAHT) to:

Ensure delivery of funding and support for the provision of social and affordable housing outcomes for low to moderate income South Australians;

Safeguard public contributions and advocate for the interests of the State Government;

Provide mechanisms which ensure tenancy services are fair and accountable;

Build strong working relationships with community housing providers;

Co-ordinate streamlined data collection for performance analysis and statistical purposes; and

Meet internal and external reporting accountabilities and responsibilities.

The framework is presented in three parts:

1. Contract initiation2. Contract performance management3. Contract administration

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KEY PRINCIPLESThe following key principles underpin this framework:

► Quality service – The delivery of quality housing outcomes for low to moderate income South Australians is at the forefront of all contract related actions and decisions.

► Professionalism – Applying best practice in contract and performance management, and implementing government policies without bias or favour.

► Trust and respect – Building strong working relationships between the contracted parties based on mutual understanding and appreciation of their objectives and constraints, and respect for their independence.

► Collaboration and engagement– Demonstrating a commitment to continued positive working relationships between the parties through open communication, early identification of potential performance concerns and constructive appraisal/feedback.

► Honesty and integrity – Demonstrating and valuing decision-making which is impartial, ethical and transparent.

► Courage and tenacity – Working persistently over the long term to ensure that contract outcomes are achieved and are in the best interest of tenants.

► Sustainability – Ensuring continued relevance and efficiency through regular review of both the mutual expectations of the parties and Renewal SA’s community housing contract management framework.

These principles closely align with the South Australian Public Sector Values which guide the behaviours and practices of all public sector employees, regardless of position, technical expertise, or location.

ROLE OF THE PARTIESContract management brings together the funder (SAHT) and the community housing provider in a relationship that works to deliver agreed social and affordable housing outcomes. The Community Housing Agreement, which encompasses the Master Community Housing Agreement and related project agreements, prescribe the obligations, rights, responsibilities and mutual intentions of the signatories.

South Australian Housing Trust (SAHT) is the legal entity that is party to the Agreement with registered community housing providers.

Renewal SA is responsible for administering the contractual relationship between the SAHT and registered community housing providers. Each provider will be assigned a contract manager within Renewal SA who will act as their key contact point for all contract related matters.

Community housing providers are responsible for achieving agreed outcomes and providing accurate, complete data in a timely manner to demonstrate

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achievement.

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Contract Initiation

Contract Initiation

Contract initiation relates to the arrangements preceding entry into a new community housing agreement. These arrangements include:

Determining funding allocation and related terms and conditions Contract execution and handover

1.1 New fundingRenewal SA will follow approved internal procedures relating to decisions about the allocation of available government funding for the delivery of community housing.

These procedures provide for:

Clear project deliverables and objectives to be established prior to release of available funding;

Application of relevant state government procurement processes; and Financial and contract approvals within appropriate instruments of

delegation.

1.2 Contract execution and handoverRenewal SA will follow approved internal procedures when negotiating and executing a new community housing agreement.

These procedures provide for:

An initial written request to the provider for authorised contact officers; Preparation of the Master Agreement including:

o Property details by reconciling property and project data held by Renewal SA on the community housing database (Schedule 1 of the Agreement)

o Portfolio profile (Annexure A of the Agreement)o Key Performance Indicators (KPIs) and agreed benchmarkso Project agreements and expiry dateso Core operating policies and procedures

Review and signing of the prepared Agreement; Opportunity for negotiated changes where necessary to address specific

circumstances of individual providers; Preparation of final Agreement for signature; and Assignment and notification of contract manager.

(Refer Appendix 2: Contract initiation - new funding, contract execution and handover process flow diagram)

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Contract Performance Management

Contract Performance Management

Contract management includes the processes for proactively managing the contractual relationship to ensure that agreed outcomes are achieved. These processes include:

Reporting (the data collected against Key Performance Indicators); Monitoring (how that data is assessed); Performance Management (the action taken where data provided does

not demonstrate agreed contractual outcomes have been met); and Record keeping.

2.1 Reporting 2.1.1 Key Performance Indicators :Key Performance Indicators (KPIs) are quantitative or qualitative measurements that help determine the extent to which agreed contractual outcomes have been achieved. The KPIs against which a provider’s performance will be measured are attached at Appendix 1 and broadly relate to:

1. Housing the right people;2. Providing fair and accountable tenancy services; and3. Managing project properties

These measures reflect key State Government expectations and priorities of providing affordable housing for people on low to moderate incomes, including vulnerable households requiring support to maintain their tenancy.

In setting these measures, Renewal SA has:

Allowed greater flexibility for the utilisation of project properties across the portfolio of individual providers;

Minimised reporting obligations of community housing providers; Developed a common minimum data set allowing for tailored thresholds

which reflect the individual requirements of programs and providers where necessary; and

Recognised that the parties’ expectations and/or the service environment may change over time and agreed program/provider specific requirements will require regular review.

2.1.2 Regular reporting:

Community housing providers are required to provide regular data returns (e.g. quarterly/annually as required) which demonstrate performance against the KPIs, agreed targets and/or benchmarks. Providers are also responsible for the correction of any identified data errors and for notifying their contract manager of any non-compliance with the requirements of their Agreement outside of the regular data collection and assessment period.

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In addition to the regular data return, other data held by government will also be utilised to assess the provider’s performance including (but not limited to):

The Australian Institute of Health and Welfare (AIHW) annual data collection;

Reporting extracted from the Community Housing Customer Register (CHCR) and other Renewal SA administered systems; and

Any performance related complaints received which directly relate to the requirements of the community housing agreement.

(Refer Appendix 1: Key Performance Indicators and data sources).

2.2 Monitoring2.2.1 Monitoring proportionate to risk:Monitoring intensity will be proportionate to identified program risks and the agreed outcomes for each individual provider. Renewal SA will:

Identify risk to contractual outcomes on a provider by provider basis; Evaluate risk and determine where impacts are greatest; and Manage contractual risks by developing appropriate risk mitigation

strategies. It is not intended that these strategies be onerous or complex but will require periodic review through the lifecycle of the contract.

For example: A file history of complaints regarding maintenance, and lower than

average capital maintenance expenditure may trigger:→ A focus on physical standards for a defined period; and/or→ Regular supportive contact by the contract manager

A provider with a large proportion of required specialised housing outcomes may need a stronger focus on program specific allocation targets and service partnership arrangements than a provider with a more general allocation profile.

2.2.2 Consistent engagement:Strong, effective working relationships between the parties are critical to ensure timely and accurate reporting is provided to meet agreed contractual requirements. Contract managers will take care to ensure that contact with providers is consistent and objective. Contact on all but the most minor matters will be in writing or confirmed in writing (email acceptable).

Providers will designate an individual or small group of individuals authorised to provide reliable and approved information to Renewal SA for the purpose of monitoring contractual performance. Renewal SA will assign a contract manager to each provider who will provide feedback on any identified trends or emerging performance issues requiring further scrutiny or discussion.

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Contract managers will engage with providers quarterly, as a minimum. Regular data returns will be required quarterly or annually in most cases.

Providers can liaise with their contract manager at any time to relay information that may impact their ability to meet reporting requirements or contracted outcomes.

2.2.3 Evidence-based analysis:

Data submitted will be validated by the contract manager against previously submitted information and checked to ensure it is reasonable and accurate. A performance measure will be assigned for each KPI together with agreed benchmarks where applicable. These will be outlined in the individual Agreement of each provider and may be varied on the basis of operational history. A consistent and objective assessment will be applied across all contracted community housing providers.

The contract manager will seek to promptly identify any emerging performance issues which potentially compromise the ability of the provider to meet KPIs in the longer term. The contract manager will identify any potential performance issues early and, together with the provider, agree on any remedial action required.

A quarterly performance report will be prepared for each individual provider identifying where:

► KPIs are met (no further action is required)► Potential performance concerns have been identified (further

investigation and remedial action to be agreed)► Significant performance issue/s are evident (urgent remedial

action required)

This performance report will be provided in writing to the provider as soon as practicable following the end of the reporting period.

Contract managers will not enter into discussions on matters regulated by the Office of Housing Regulation (OHR). Where such issues emerge, the contract manager will ensure any information exchange with the OHR is in accordance with the Operating Arrangements agreed between Renewal SA and the OHR.

(Refer Appendix 3: Contract reporting and monitoring process flow diagram)

2.3 Performance managementPerformance management refers to the process of ensuring both parties to an Agreement meet their obligations as effectively as possible in order to achieve the agreed outcomes.

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Provider performance against agreed contractual outcomes will be managed by Renewal SA in three stages:

This performance management approach assumes most issues arising should be able to be easily remedied without requiring any formal action.

Stage 1: General performance managementAny potential performance concerns will be discussed with the provider as soon as possible. Strategies to address these concerns will be developed in consultation between the contract manager and provider.

It is expected most issues arising during the performance management process will be easily remedied through agreed informal action.

Depending upon the severity and/or recurrence of the issue/s, a more formal approach may be necessary including:

Developing a formal Performance Management Plan to remedy the identified performance concern/s; and/or

Involving senior management from both parties in formal discussions.

Where a Performance Management Plan is required it will be developed in consultation between the contract manager and provider and will include:

Formal documentation of the issue/s; Any discussion or clarification required; A plan for resolution, with clear agreed action/s and set timeframes; and A method to monitor the plan through to successful completion.

In some cases monitoring and frequency of reporting may be adjusted temporarily to reflect a potentially higher contractual risk than applied at contract initiation.

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General performance management

Significant issue management

Breach management

Stage 3 -

Breach management

Stage 2 - Significant issue management

Stage 1 - General performance management

Stage 2: Significant issue managementAny identified performance concerns which have the potential for serious negative impact on tenants, community housing assets or the reputation of the community housing sector, will be deemed a significant issue.

Instances which may also prompt an issue/s to be deemed significant are:

The recurrence or escalation of more minor performance issues; and A continuing lack of engagement by the provider or evidence of effort to

address the issues; or An absence of adequate reporting by the provider to determine

performance against KPIs.

Any issues identified as significant will immediately escalate to stage 2 of the performance management process triggering further investigation by the contract manager. This may result in the earliest practicable issue of a Significant Issue Notice requiring the provider to remedy the issue/s within a specified timeframe or risk escalated performance action (Stage 3: Breach Management).

The Office for Housing Regulation (OHR) will be notified of any Significant Issue Notice issued, indicating unresolved failure by the registered provider to comply with the requirements of their community housing agreement. Should the provider remedy the performance issue/s within the agreed period provided by the Notice, the OHR will similarly be advised.

The issuing of this Notice may trigger the application of more rigorous reporting requirements until the matter has been resolved.

Stage 3: Breach managementWhere the provider has not remedied the identified performance concerns or refuses to enter into a Performance Management Plan, a breach of Agreement may be declared.

A breach may also be declared immediately (i.e. Stages 1 and 2 skipped) upon identification of an issue deemed by Renewal SA to be:

Serious i.e. has a serious negative effect or has the potential to have a serious negative affect on tenant health and/or wellbeing or on a project property/properties; or

Unlawful e.g. fraudulent activity, abuse etc.

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Where there is a confirmed breach, a prompt and thorough approach will be taken by Renewal SA acting on behalf of the SAHT. A Breach Notice will be issued formally declaring:

That the provider is in breach of contractual obligations; That the provider has failed to take action to remedy the breach as

directed; Whether the breach is a property specific breach or portfolio-wide

breach; and Action that will be taken should the breach not be remedied within the

time period provided*.

The Office of Housing Regulation will also receive notification of the declared Breach.

A provider may at any time exercise its right to resolve the matter through the dispute resolution procedure provided for in the Agreement (clause 31).

*Note: Enforcement of the statutory charge (‘the charge’) is available as an instrument of last resort. If a provider fails to comply with the terms of their Community Housing Agreement, the Charge over project property/properties may be enforced in accordance with the process prescribed by the Community Housing Providers (National Law) (South Australia) Act 2013 (Division 3, Section 23).

(Refer Appendix 4: Contract Performance Management Process Flow)

2.4 Record keepingRecords to be created and retained by Renewal SA during the life of the Agreement may include but are not limited to:

The initial Agreement and all variations made to the Agreement Contractual risk assessments All substantive communications with and from the provider Data returns Performance reports, desk top analyses Records of disputes, related discussions and negotiations Assistance or expert advice received Performance management plans Significant issue notices Breach notices

Documents created and all related communications between contract managers and contracted community housing providers will be securely stored and

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recorded in accordance with State Government Privacy Principles and records management protocols, processes and systems.

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Contract Administration

Contract Administration

Contract Administration includes:

► Contract review and variation;► Contract termination; ► Core operating policy variation; and► Managing contractual disputes

3.1 Contract review and variationProvisions to review and vary contract provisions are a standard feature of the Agreement. A review of the Agreement will be undertaken at least once every five years by consultation between the parties.

Any request for variation to the Agreement should be formally made in writing and assessed by Renewal SA to ensure it does not breach any existing legal, contractual or policy requirements. If agreed, a variation must be made to the Agreement and signed by both parties prior to any change being acted upon by either party.

Variations to the Portfolio Profile at Annexure A of the Agreement will be made as required to reflect changes to Project Property (e.g. sales, transfers, new acquisitions).

(Refer Appendix 5: Contract Variation Process Flow)

3.2 Contract TerminationThe Agreement may be terminated at any time by mutual written agreement between the parties. Renewal SA acting on behalf of the SAHT may terminate the Agreement:

Immediately upon written advice to the provider, if they cease to be registered under the Act; or

Where a provider purports to assign any of its rights or obligations under the Agreement which would cause them to be in breach of the Agreement. In this case the Agreement will be terminated after seven days’ written notice to the provider.

(Refer the Agreement Part 5, clause 23-24)

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3.3 Core operating policy variationThe Agreement prescribes a set of core operating policies including: eligibility, tenant allocations and tenure, appeals, disability access and inclusion, property acquisition and disposal, and rent management. These policies may be varied or added to from time to time by Renewal SA provided:

► Community housing providers have had prior notice of the proposed variation; and

► Have been consulted with prior to its implementation on the proposed variation or new policy

► Renewal SA has considered in good faith any issues raised by the Community Housing Provider through consultation.

Wherever possible the CHP will be given no less than three months’ prior notice of the commencement of the varied or new core operating policy.

Community housing core operating policies will cover general contractual obligations and will not include matters appropriately dealt with by the OHR.

3.4 Managing contractual disputesAs a general rule, a disagreement becomes a dispute when it is not possible for the parties to resolve it without resorting to a formal resolution mechanism.

Disputes and disagreements arise when the parties cannot agree on the interpretation of contract provisions, the definition of deliverables, meeting performance standards and /or the effect of unexpected events, or where parties enter into agreements without informed commitment to terms.

Most disagreements are of a minor nature and can be readily resolved informally between the parties. Where the parties cannot reach agreement, it is important that early action be taken to avoid escalating the issue and to minimise cost for both parties.

As provided for in the Agreement( clause 31), contract managers will follow approved procedures when managing all formal disputes. This involves:

The lodgement of a formal dispute notice by the aggrieved party; and Consideration of the issues by nominated independent representatives

of the Parties (the “Negotiators”).

Where the issue cannot be resolved by the independent representatives, the executive negotiators will meet to seek resolution. Legal action through the court system is considered an action of last resort.

(Refer Appendix 6: Contract dispute resolution process flow)

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Appendices

Key Performance Indicator Benchmark for Sector consultation Frequency Reporting sources100% new tenant allocations meet SAHT base government eligibility criteria as defined in core operating policies.

Quarterly data return (replaces monthly capital contribution report).

100% of new tenant allocations meet the income assets and/or needs test as per tenancy types defined in the Eligibility Core Operating Policy (general).

Derived from CHCR - no reporting by CHP required.

100% of new tenant allocations meet the income assets and/or needs test as per tenancy types defined in the Eligibility Core Operating Policy (supported).

Derived from CHCR - no reporting by CHP required.

100% of new tenant allocations meet the income assets and/or needs test as per tenancy types defined in the Eligibility Core Operating Policy (affordable).

Derived from CHCR - no reporting by CHP required.

No less than 95% of the Portfolio Profile Tenancy Type outcomes in the Annexure to Schedule 2 are met over a 12 month period to 30 June each year and reported by CHP during the term.

Annually Derived from the annual AIHW Data Collection.

No less than 85% of all new allocations made across the portfolio are identified as Category 1 tenants on the Community Housing Customer Register (for CHPs with all tenant types in their portfolio). Note % is determined at a CHP level, example only.

Derived from CHCR - no reporting by CHP required.

100% of new allocations of General Community Housing and Supported tenancy types as set out in the Eligibility Core Operating Policy are sourced from the Community Housing Customer Register.

Derived from CHCR and annual AIHW Data Collection.

CHP applies the relevant rent policies fairly and appropriately.

100% of tenant rents are being calculated in accordance with the Core Operating Policy relating to rent applicable to the tenant type.

AnnuallyDerived from the annual AIHW Data Collection (small sample to be selected annually for review by the Contract Manager).

CHP manages vacancies to optimise access to government-subsidised housing

Vacancies over 28 days do not exceed 3% of total tenancies within Project Properties per quarter as defined.

Quarterly Quarterly data return (replaces monthly capital contribution report).

CHP undertakes adequate planning to ensure quality of properties is maintained to designated standard

Tier 1 & 2: 100% of project properties are included in an annually submitted asset management plan that provides evidence of appropriate planning, budgeting and forecasting of funds for maintenance. Tier 3: 100% of project properties are included in the prescribed format, biennial Summary Maintenance Plan that provides evidence of appropriate planning, budgeting and forecasting of funds for maintenance.

Tier 1 & 2 Annually Tier 3 Biennially

Tier 1 & 2 via sighting 5yr asset management plan annually and tier 3 via 10 yr Summary Maintenance Plan biennially.

AnnuallyAnnual insurance certificate (certificate not required for debentured properties).

Man

agin

g Pr

ojec

t Pro

perti

es CHP maintains all Project Properties to the designated standard

All habitable Project Properties meet Community Housing Maintenance Accommodation Standards 2014 and Housing Improvement (Standards) Regulations 2007 (SA).

Quarterly data return - replaces monthly capital contribution report and will continue to include CCs & vacancy reporting at a property level (vacancy reporting will extend to all project properties).

Key Performance Indicators for sector consultation

AnnuallySmall sample to be inspected - 'high risk' properties to be identified from summary maintenance plan/stock inspection reports, or random sample.

CHP maintains appropriate insurance coverage across portfolio.

100% of Project properties have insurance coverage which complies with the insurance requirements under this agreement.

Hous

ing

the

right

peo

ple

CHP houses eligible people only

Quarterly with annual survey

verification

CHP makes appropriate tenant allocations to Project properties

Quarterly monitoring with

annual survey verification

Prov

idin

g fa

ir &

ac

coun

tabl

e te

nanc

y se

rvic

es

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Appendix 2

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Appendix 3

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Appendix 4

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Appendix 5

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Appendix 6

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