Joe Griffin: One of the key risks for us is the governance and management at the individual housing associations (HAs). Over the last 12 to 18 months in particular, we've seen a trend with more HAs being downgraded to non-compliant due to their governance with the regulator; they go from a G2 to G3 or in some cases even a G2 to G4 [on the regulator’s governance scale, which has four levels from G1 to G4].
"We don't want to be investing in HAs with poor management because
that's likely to lead to poor financial performance."
This happens for many reasons. We've seen some HAs overcharging tenants’ rent. There’s also been inadequate stock monitoring, which includes not knowing which units are compliant with fire safety standards – which is a concerning issue.
On the management side, there have been situations with poor reporting and poor treasury and debt management, particularly around governance, and cases of a lack of board oversight. There are sometimes weak controls around HAs and their development programmes, particularly the ones that are trying to ramp up too quickly.
This concerns us for several reasons. Firstly, on the credit side, we don't want to be investing in HAs with poor management and governance because that's likely to lead to poor financial performance and rating downgrades.
Secondly, some of governance downgrades threaten tenant safety, which is not acceptable.
On the Debt Treasury side, it's all quite standard. New primary issuances that we see are generally all benchmark size: 25 to 35 years. It would be nice for a few issuers to branch out to different sizes and tenors given our asset-liability matching business model. We have liabilities ranging from one year to 60 years, and it would be good to have some HA assets that aren't in that 25-to-35-year bracket.
Joe: It would be nice for us. I can see why they don't need to do it, though. Sterling HA issuances tend to be very oversubscribed. HAs know that if they want 25 years – which they do tend to want – they know that they can issue at that range, and they'll get enough appetite.
Joe: I'm sure we'll see a shake-up in the housing sector and will have a lot to think about – and it ties back to the operating environment.
We're not sure how it might impact grant funding and rent setting. Work will need to be done there and we'll speak to our external managers and rating agencies to get their views and see how that might impact our investing going forward.
Joe: We're committed to reducing our Scope 3 emissions by 50% by 2030 and we see the HA sector playing a key part in this reduction, in line with our broader objectives to further allocate towards positive social impact investments.
The current contribution of HA assets to the overall portfolio emissions intensity is lower when compared to other investments.
"We might look at a provider and see that 70% of their units are already at EPC C or above, which is good compared to the sector average."
However, to caveat that, I would say the data we have access to is of varying quality. This includes the HA sector, where data availability can be limited. We find, for example, for private residential assets obtaining accurate reported emissions data can be difficult, which means in some cases our calculations require a proxy.
We continue to incorporate climate change and specifically emissions as part of our investment decision making process. We see emissions as one of many other key factors. We are engaging with issuers and our external managers to improve the quality and availability of this data. When looking at an HA investment, we will consider the EPC ratings of their existing units. We might look at a provider and see that 70% of their units are already at EPC C or above, which is good compared to the sector average, which in the social housing sector was around 55% in 2021.
We look at the likely costs of what it's going to take to get those remaining units up to that EPC level. We consider the timeline and whether the HA is planning to front-load the work in the next couple of years or if costs are expected to be spread out over the period leading to 2030 and the potential effect on Capex and other relevant credit metrics.
This is mainly on the “E” side, but as mentioned earlier it is the “S” that is one of the biggest drivers of our assessment of HAs. We believe that by increasing affordable housing supply for low-income families, and by improving the safety of the tenants, our investments in this sector could have a positive impact on society.
