Fire Safety Policy

1.1 This Policy establishes how Stonewater Group will ensure compliance with its statutory duties in relation to fire safety as defined under the Regulatory Instruments listed under 2.2 below.

1.2 This policy applies to all residential buildings and associated structures either owned, leased or managed by Stonewater and its subsidiaries

1.3 To provide assurance regarding the robustness of its fire safety policy and plan, Stonewater will be seeking certification of its fire safety management system against BS 9997 during 2027-2029

1.4 This document has been drafted at a time of change in relation to building safety management. New requirements are constantly emerging and as such this policy document and the associated management plan will be subject to regular review to keep pace with change. Noting that Stonewater will seek to react and implement changes in line with regulatory requirements.

2.1 This policy, in conjunction with the Fire Safety Management Plan, is designed to provide clear direction for Stonewater and its subsidiaries in the application and management of its duties for undertaking effective measures for the control of fire safety risks.

2.2 In furtherance of its duties under the Regulatory Reform (Fire Safety) Order and the Fire Safety (England) Regulations Stonewater commits to ensuring:

• that they retain a competent source of advice for fire safety;

• that the principles of prevention are applied when implementing fire safety arrangements;

• that general fire precautions are taken, so far as reasonably practicable to ensure the safety of colleagues and other relevant persons;

• suitable and sufficient fire risk assessments are undertaken by a competent third-party certified consultant;

• that the organisation has suitable arrangements in place for the effective planning, organisation control, monitoring and review of fire precautions;

• all buildings are equipped with suitable fire detection and fire-fighting equipment, in line with best practice and sector standards;

• emergency evacuation routes and exits are maintained;

• suitable plans and resources are in place to manage emergency situations;

• that all fire safety passive and active systems are subject to a suitable inspection and maintenance regime;

• all colleagues and customers are provided with relevant information, instruction and training regards to fire safety risks

• that Stonewater Coordinates and Cooperates with other parties in respect of shared premises

• that all locations where commercial gas installation are present have a DSEAR assessment in place.

2.2 The following Acts and Regulations (list not exhaustive) are applicable to this policy;

• The Regulatory Reform (Fire Safety) Order (RRO)

• The Fire Safety Act

• The Fire Safety (England) Regulations

• The Building Safety Act and secondary instruments

• The Housing Act

• The Building Act and Approved Document B

• The Smoke and Carbon Monoxide (England) Regulations

• The Dangerous Substances and Explosive Atmospheres Regulations

• Social Housing (Prescribed Requirements) (England) Regulations

• Fire Safety (Residential Evacuation Plans) (England) Regulations 2025

3.1 Competent source of advice

3.1.1 The Head of Fire & Building Safety is the Groups competent source of advice for fire safety and is required to be able to demonstrate sufficient skills, knowledge, experience and behaviours, as defined by the Fire Safety Management Plan (FSMP) to fulfil this function.

3.1.2 Stonewater maintains a Primary Authority Agreement (PAA) with Hampshire and the Isle of Wight Fire and Rescue Service to enable it to attain assured advice regarding fire safety regulation.

3.2 Fire risk assessments (FRAs)

3.2.1 FRAs will be undertaken for all assets in scope of the RRO within management. FRAs will be undertaken from the commencement of the 2024 financial year by a third-party certified consultant, who can demonstrate that those completing assessments, hold membership of a UKAS accredited life risk assessors register and can demonstrate competence in accordance with BS 8674 competence standard

3.2.2 Completion of FRAs on commercial and office accommodation, where no sleeping risk exists will be retained internally via the Fire Safety team.

3.2.3 In creating the FRA, British Standard 9792 will be followed as the minimum standard.

3.2.4 The Type of FRA to be completed, as defined under the Fire Safety in purpose – built block of flats guidance (Home Office) and is detailed within the Fire Safety Management Plan.

3.2.5 Where Stonewater is not the Responsible Person (RP) for fire safety, it will make suitable enquiries to the RP to attain assurance that an FRA is in place for the building where it retains an interest.

3.3 The fire safety management plan (FSMP)

3.3.1 The FSMP documents Stonewater’s arrangements for the effective planning, organisational control, monitoring, maintenance and review of fire precautions. The management plan has been written in line with BS9997 – Fire Risk management Systems

3.3.2 Including the roles and responsibilities for operational delivery of this policy.

3.4 General fire precautions and fire safety equipment

3.4.1 When specifying general fire precautions including fire safety equipment Stonewater and its consultants will make reference to legal, best practice and sector guidance.

3.4.2 Stonewater understands that the application of Approved Document B (ADB) – Fire Safety in the design of new or refurbished homes, is a minimum design standard and that compliance with ADB does not demonstrate that Stonewater will meet its duty under the RRO to reduce fire safety risks as low as reasonably practicable at occupation.

3.4.3 As such Stonewater and its consultants will apply best practice requirements in all design work to ensure that the risk to residents and other relevant persons at occupation, are designed out at technical design stage.

3.4.4 Those employed by Stonewater to install or maintain active and passive fire safety systems will hold the relevant third-party certification and accreditations to be deemed competent.

3.4.5 In accordance with its duties under the Fire and Carbon Monoxide (England) Regulations, Stonewater will ensure all tenanted homes are fitted with hard wired fire detection. Carbon monoxide detection will be fitted in all homes where a domestic gas appliance is installed

3.5 Management of evacuation routes and exits

3.5.1 Stonewater maintains arrangements for the regular inspection and audit of communal areas of blocks or flats to ensure housekeeping is managed and routes are maintained.

3.5.2 Stonewater operates a zero tolerance housekeeping policy in the communal areas of general needs blocks of flats and a managed policy within its retirement living blocks, due to the enhanced level of fire precautions and management within these units.

3.6 Investigating emergency and significant hazards

3.6.1 Stonewater will work with its consultants and contractors to ensure that both emergency and significant hazards are addressed or investigated in relevant timescales.

3.6.2 The Fire Safety team will update customers at relevant intervals following completion of an investigation to confirm the outcome and progress of any remedial works. The team will liaise with colleagues in Homes Operations to ensure any remediation works required, are completed within statutory timescales.

3.7 Emergency Planning

3.7.1 Stonewater maintains business continuity and housing emergency plans which detail its arrangements for building related emergencies.

3.7.2 In furtherance of its duties under the Building Safety Act, building specific emergency plans are in place for Stonewater’s six high rise residential buildings (HRRBs).

3.7.3 Specific processes are in place for the identification of customers who are may be at enhanced risk from fire, due to physical, sensory, or other forms of vulnerabilities, which would impact on their ability to respond to or evacuate their homes.

3.8 Information, Instruction and Training

3.8.1 Customers

3.8.1.1 Stonewater maintains a fire safety communication plan which details, the content, form and frequency of fire safety communications to Customers

3.8.1.2 Customers living within HRRBs will receive bespoke communications via the Building Safety team, in addition to general communications.

3.8.1.3 In line with Stonewater’s duties under the Fire Safety (England) Regulations and Building Safety Act, Stonewater will ensure that customers receive key safety information annually and will provide upon request additional information, including a copy of the buildings fire risk assessment, as required by the Higher Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations

3.8.2 Colleagues

3.8.2.1 All colleagues must complete fire safety awareness training on induction as a mandatory training requirement. Training is then refreshed at three yearly intervals.

3.8.2.2 In addition, front line teams in our customer services, development and investment directorates will be required to complete Building Safety Awareness from Q3 2026.

3.8.2.3 Site based colleagues who work from specialised housing scheme and undertake weekly tests will receive a site based induction and training.

3.8.2.4 Copies of FRAs for our hub offices can be accessed alongside the workplace risk assessments via MySafety Stonewater’s H&S software system.

3.8.2.5 Colleagues can access copies of FRA’s for residential buildings via Stonewater’s compliance management system or by contacting the Fire Safety Administrative team.

3.9 Cooperation and Coordination

3.9.1 In furtherance of its duties under the RRO Stonewater will co-ordinate and cooperate with third parties to ensure fire safety risks are suitably controlled.

3.92 Further details are contained in the fire safety management plan and supporting processes

3.10 Management of Dangerous Substances

3.10.1 As a housing provider, Stonewater do not store, manufacture or process dangerous substances within its portfolio.

3.10.2 Stonewater manages 43 sites where communal mains gas plant is present and has completed DSEAR risk assessments for all locations.

3.10.3 Customers are not permitted under the terms of their tenancy agreement or lease to store contained gases within their homes, other than for medical use.

3.10.4 Customers are required to notify Stonewater where medical gases are in use to ensure local fire and rescue services can be advised. Oxygen registers are maintained at all specialised housing schemes.

4.1 Stonewater acknowledges that to meet our obligations we must maintain a robust approach to identifying the assets and components for which it has responsibility.

4.2 To ensure that integrity of our data we will:

• Maintain an up-to-date Master Database of all properties that have a requirement for an FRA (i.e residential buildings with a common part)

• Where a requirement exists, document the last FRA, the date it was completed and by whom, the overall risk rating of the building and the date it is next due for review.

• Where a requirement does not exist hold appropriate evidence to support that position.

Maintain current and up to date records of remedial works completed within each building. These records will include:

• Action description

• Action category

• Risk rating

• Target completion date

• Action owner

• Date of completion

• Evidence to demonstrate completion

4.3 Further details will be contained within the Fire Safety Management Plan.

5.1 Ensuring the safety of Stonewater’s homes is a strategic objective. As such landlord compliance, which incorporates fire safety forms part of the Groups strategic suite of Key performance indicators (KPI’s), with a performance target of 100%.

5.2 Risk tolerance for all compliance areas has been set at 98.5%,performance below this level will result in a service improvement plan being implemented.

5.3 Fire Safety reporting is provided to the Building Safety Group on a 6 weekly basis, KPIs tracked include:

• Number of fire incidents by type

• Number of fire enforcement notices by type

• Total number of residential blocks in the FRA review programme

• Number of blocks where an FRA has not been reviewed ahead of target review date

• Current Compliance position (%)

• Trend from previous month

• Total number of actions created in month

• Total number of actions closed in month

• Total number of open actions in high, medium and low priority ratings

• Total number of actions by risk rating which are overdue by 30, 60 and 90 days

• Number of blocks in the fire door inspection programme

• Number of blocks where door inspections have not been completed in target

• Current compliance position (%)

• Trend from previous month

5.4 Papers from the Building Safety Group pass through the H&S governance structure to Board. In addition a quarterly H&S and Compliance report is issued to Board quarterly.

5.5 The Chief Officers Group (COG) receive Tenants Satisfaction Measures (TSM) figures at the end of each quarter.

5.6 All letters of fire of deficiency (LODS) or enforcement notices (ENs) received from Fire & Rescue Services will be recorded in Stonewater’s H&S management system (MySafety) and will be managed to completion by the Head of Fire & Building Safety. Status updates will be provided as part of the Compliance report to the Building Safety Group.

5.7 Any fire incident resulting in death, major injury or requiring to be reported to the HSE (under Mandatory Reporting requirements) will be reported to Chief Officer Group, Board and Stonewater’s insurance team within 24 hours of the incident occurring or as soon as reasonably practicable.

5.8 Primary fire incidents (resulting in loss) will be investigated by the Fire Safety Team and the FRA reviewed on-site. Secondary fire incidents will have a proportionate review depending on quantum of loss and potential risk of reoccurrence. Resulting action plans will be created and tracked in MySafety.

6.1 The following Quality Assurance (QA) activity will be undertaken and reported in line with the Management Plan:

• The quality of FRAs will be subject to independent external audit, by Stonewater’s Compliance auditor. A minimum of ten percent of all FRAs completed will be subject to physical audit.

• The quality of passive fire safety work undertaken by Stonewater's suppliers will be inspected and audit via the Fire Safety team.

• The quality of active fire safety system installation and maintenance will be inspected by Stonewater's compliance auditor. Ten percent of all work completed will be subject to physical audit.

• Stonewater’s internal auditor will provide independent assurance on the operation and effectiveness of the fire safety management system. The frequency of audit will be agreed by the Risk and Audit Committee as part of the Internal Audit Programme.

• In addition once BS9997 certification is attained, the management system will be subject to regular audit by the certification body.

7.1 The following associated documents provide the detailed procedures to deliver the fire safety policy objectives and outcomes;

• GS-PR-025 Fire Safety Management Plan

• GS-PR-032 Managing leaseholder flat entrance doors

• GS-PR-028 Person centred risk assessment (PCRA) process

• GS-PR-028 A PCRA process for HRBs or blocks with interim measures

• GS-PR-030 Controlling and managing works to HRBs

• GS-PR-031 Managing secondary means of escape provisions

• GS-PR-033 Producing and managing personal emergency evacuation plans (PEEPs) for Customers

• GS-PR-34 Managing Building Safety Complaints

• GS-PR-035 Pre-acquisition due diligence (Building Safety)

• GS-PR-036 Managing secure information boxes

• GS-PR-041 External wall risk assessments – commissioning process

• GS-PR-42 Implementing interim measures

• GS-PR-47 Building Handover and Golden Thread requirements procedure

• GS-PR-59 Enforcement body communication management

• GS-PR-60 Managing enforcement notices

• GS-PR-061 Mandatory reporting process.

8.1 This policy is designed to deliver the following outcomes:

• Zero fire deaths within Stonewater’s portfolio

• Less than five fire enforcement notices received within each financial year

• Less than 10 fire safety related customer complaints per financial year

• A TSM reporting position of greater than 98.5% compliance

9.1 This Policy shall be reviewed and updated by Stonewater biennially or if there any major changes to current fire safety legislation and sector guidance.

9.2 Approved documents are valid for use after their approval date and remain in force beyond any expiry of their review date until a new version is available.