Housing Leeds Asset Management Strategy 2022 to 2027

Executive summary

Leeds City Council as a registered provider of social housing owns and manages over 52,000 homes. Our annual repairs, maintenance and investment programmes total over £140m of annual spend, funded from the Housing Revenue Account. This investment presents a significant opportunity to make a material difference to the quality of homes and consequently the health, social and life chances of the tenants and the local communities we serve.

Leeds has enjoyed considerable growth and success over the last decade or more. There are, however, still significant economic and health inequalities in the city. Almost a quarter of Leeds' Lower-layer Super Output Areas are in the 10% most deprived in the country (source: ONS 2017).

This Asset Management Strategy (AMS) sets out the framework for managing the council’s social housing stock in order to provide high quality, safe and sustainable homes to meet the needs of our tenants, leaseholders and service users. It reflects our statutory responsibilities as a provider of social housing, promotes social value and supports the delivery of the council’s wider strategic ambitions.

The AMS also support the delivery of the 6 themes identified in the Leeds Housing Strategy.

  • reduce homelessness and rough sleeping
  • meet affordable housing need
  • improve housing quality
  • child and age friendly housing
  • thriving and inclusive communities
  • health and housing

We will achieve this through the delivery of our 4 asset management themes, all of which support the delivery of the council’s Best City Ambition while ensuring Housing Leeds delivers our statutory and non-statutory obligations as a social housing landlord:

  • building safety, quality and regulatory compliance
  • data management and intelligence-led investment
  • improving energy efficiency
  • place and space

Introduction

The scope of this strategy is to provide:

Our vision for the future of the retained housing estate, outlining our strategic themes and detailing our asset management objectives. It sets out how we will make decisions on developing, maintaining, refurbishing, or replacing our housing assets. It will enable us to direct resources to ensure that all our homes comply with applicable legislation and regulation and that residents feel safe, happy, and healthy in their homes.

By applying a thematic approach, with the customer at the centre, Housing Leeds will use data on housing stock condition and performance alongside tenant profiling information to deliver investment where it is most needed and where it will make the greatest impact.

This strategy aims to ensure that our assets are safe and well maintained to appropriate standards, are being used to maximum benefit and that opportunities are taken to unlock any untapped potential or deal with stock that no longer meets modern needs or is no longer ‘fit for purpose’, delivering outcomes that afford residents the benefit of a sustainable tenancy. This will include making challenging decisions about whether we continue investment in assets that no longer meet the sustainability threshold, or whether we dispose of assets in order to make room for re-provision.

Effective management of our housing stock, along with targeted, intelligence-led investment will support the delivery of the Leeds Ambitions, while ensuring value for money is maintained within the context of the HRA Business Plan, Medium Term Financial Strategy and wider regulatory landscape.

Current housing portfolio

The Housing portfolio comprises of housing assets, community space, land, garages and commercial units.

Using some key statistics (April 2025), this section provides an insight into our housing asset portfolio (including PFI and BITMO):

Total dwellings  52,246
Houses 27,550
Bungalows 3,009
High rise flats 6,548
Low and medium rise flats 15,139
18 metre plus blocks 121
Communal spaces 1,223
Retirement LIFE and Extra care 42
Leaseholders 2,697
Shops 358
Housing offices 29
Community centres 46
Garages 4,659

(Note: asset volumes will fluctuate due to variables such as property sales (Right to Buy), acquisitions, disposals and new build).

Leeds City Council has an extensive housing portfolio made up of 51 different archetypes including 121 high rise buildings in scope of the Building Safety Act (2022).

65% of the housing stock was built prior to 1964 and each construction type presents its own particular investment challenges, such as ageing infrastructure and building services. A targeted approach is required to tackle issues such as damp and mould, which are higher risk in some archetypes.

Housing stock numbers have continued to reduce through Right to Buy with an average 500 to 600 sales each year. The council Housing Growth programme has, to some extent, countered this, with 404 new council homes built and the acquisition of 468 properties since 2019. Across new build and acquisitions, 378 homes are in the approved pipeline with funding.

Around 2,700 council properties are currently included in two Private Finance Initiative contracts for improvements and repairs and maintenance. A further 1,800 are managed by Belle Isle Tenant Management Organisation (BITMO). Both BITMO and PFI properties are within the scope of this AMS.

Leeds City Council Corporate Plans

The AMS has been developed to actively contribute to the objectives of wider council and regional strategies, most notably the Leeds Ambitions and the Leeds Housing Strategy.

Additionally, the AMS contributes to the objectives and priorities identified by the West Yorkshire Housing Partnership.

National and legislative context

It is important that this strategy document is aligned to the relevant national housing regulation and policy context, with a specific focus on the following areas:

  • Social Housing (Regulation) Act (2023)
  • Building Safety Act (2022)
  • Decent Homes Standard
  • sustainability and improved energy efficiency of social housing stock
  • amplifying the voice of the resident
  • community wellbeing and social inclusion

Social Housing (Regulation) Act (2023)

The Social Housing (Regulation) Act strengthens tenant rights and improves housing standards by giving the Regulator of Social Housing more power to enforce new consumer standards. The consumer standards are:

  • Safety and Quality Standard
  • Transparency, Influence and Accountability Standard
  • Neighbourhood and Community Standard
  • Tenancy Standard

Key aspects include more frequent inspections, improved complaint handling, and requirements for landlords to be more transparent and professional. The act also incorporates provisions for Awaab's Law, which mandates that landlords must respond to serious health and safety hazards like damp and mould within specific timeframes.

In addition, registered landlords of social housing must submit key performance data known as Tenant Satisfaction Measures, on an annual basis.

Compliance with the Social Housing (Regulation) Act is a core priority of the AMS.

Building Safety Act (2022)

The Building Safety Act takes forward the Government’s commitment to fundamental reform of the building safety system. The Act gives effect to policies set out in the Building a Safer Future consultation response, published in April 2020. This detailed how the Government intends to deliver the principles and recommendations of Dame Judith Hackitt’s Independent Review of Building Regulations and Fire Safety, published in May 2018.

There is an ongoing sprinkler installation programme to high rise buildings which will continue over the period of this strategy. None of our high rise buildings contain ACM cladding. Housing Leeds is also committed to ensuring compliance with all primary and secondary legislation associated with the Building Safety Act.

Compliance with the Building Safety Act and delivering fire safety improvements to assets is a core priority of the AMS.

Decent Homes Standard

The Decent Homes Standard is a minimum standard for social housing in England that requires homes to be in a reasonable state of repair, have modern facilities, and provide thermal comfort. It also incorporates the statutory minimum safety standards from the Housing Health and Safety Rating Scheme (HHSRS).

Around 95% Housing Leeds stock meets Decent Homes Standards (April 2025). Investment in non-Decent homes will be prioritised in order to achieve compliance and improve housing quality.

Sustainability and energy efficiency

In 2019, Leeds City Council declared a Climate Emergency. Since then, investment in the council’s housing stock has sought to contribute to reducing carbon through improved energy efficiency of the estate, supporting residents in fuel poverty and utilising renewable heating solutions wherever possible. With support from external funding sources, since 2020 over £100m of investment in low-carbon heating and energy efficiency measures has been completed.

The average SAP rating for across the housing portfolio is a ‘C’, however some 18,000 homes currently fall below this rating. Improving energy efficiency to a minimum SAP C is a core priority of the AMS, supported by a ‘fabric first’ approach to energy efficiency measures. In addition, the installation of low-carbon heating will continue to be explored where possible.

Tenant engagement  

The voice of the tenant is critical to ensuring the AMS delivers on the priorities that matter most to tenants.

The AMS comes with a commitment that Housing Leeds will continue to fully consult and engage with tenants on matters relating to the delivery of the AMS. This will include learning from customer satisfaction surveys, Tenant Satisfaction Measures and from challenge from Tenant Scrutiny Board. Additional engagement and/or consultation sessions will be held as appropriate to support the delivery of the AMS.

Key achievements from the last strategy

This 2022 to 2027 Housing AMS builds on a wide range of initiatives that have been successfully completed through the previous Strategy.

The activities set out below demonstrate our ability to respond to the challenges within the sector, securing additional funding and making improvements that benefit our residents and improve the quality and performance of council housing.

Over the last 5 years we have invested £369m in our assets which includes:

  • £63m on decency works
  • £17.5m on fire safety work including sprinklers to high-rise buildings
  • £56.5m on energy efficiency measures
  • £30m on communal works
  • £11m structural works including concrete repairs
  • £110m on capitalised maintenance activity
  • £32.5m adaptation works

In addition to the above achievements further investment requirements were identified in relation to the Climate Emergency which led to projects such as the £3.8m project to install Solar PV to 1,000 properties across the City.

Here is a summary of some of the activities that we have completed:

  • increased energy savings by installing solar PV panels on the roofs of 1,000 homes
  • delivered improved renewable heating systems via the Leeds Pipes project and commenced a programme to install ground source or air source heat pump technology to other high-rise buildings
  • installed sprinkler systems to 72 high rise buildings
  • raised the average SAP energy performance to average Band C across the city
  • secured over £45m of external funding (for example, SHDF, ERDF, ECO)

Repairs performance

Repairs and maintenance data is used to inform and develop both proactive (predictive) maintenance programmes and future investment programmes. Data is used to highlight trends that can inform both the existing condition of assets and the potential future deterioration where intervention through proactive investment can provide more cost effective and customer focused outcomes.

Repairs and maintenance datasets used to inform these programmes include:

  • planned vs reactive maintenance
  • cost per repair
  • trade / workstream volume trends
  • repeat repairs
  • repair volume / type per asset type
  • repair volume / type per post code area
  • Tenant Satisfaction Measures (TSM)
  • disrepair data

Damp and mould

Leeds City Council is committed to a zero tolerance approach to damp and mould.

Damp and mould is one of the 29 hazards listed under the Housing Health and Safety Rating System (Housing Act 2004) and as such the council, in its capacity as a landlord, has a legal duty to mitigate. This responsibility is fully understood and embedded into operational procedures and wider strategies to ensure that all reports of damp and mould are assessed in a timely manner and that proactive prevention work contributes towards damp and mould reduction.

Damp profiling is undertaken as part of Stock Condition surveys, allowing any immediate risks to be highlighted and appropriate interventions implemented. Additionally, all voids properties are damp profiled, allowing interventions to be implemented prior to a new tenant moving in.

Through a combination of reactive maintenance, planned maintenance, predictive maintenance and planned investment, we aim to eliminate damp and mould from Housing Leeds homes as far as reasonably practicable.

Following the introduction of Awaab’s Law in October 2025, Housing Leeds will ensure full compliance with the legislation.

Key profiling information

Below sets out key data (Aug 2025) in relation to demand and tenancy information for our housing stock:

  • there are over 25,000 applicants on the Leeds Homes Register
  • 66% do not have an assessed housing need (Band C or D)
  • 17.29% of tenants identify themselves as having a disability or impairment
  • 26.6% of tenants are over 65 year of age
  • the ethnicity of our tenants is extremely diverse, reflecting the diversity across the city, with over 20 languages spoken as a first language
  • increased demand for Council Housing – average 461 bids in per property (compared to average 91 bids in 2016)
  • current demand on the register is 50% for 1 bed, 28% for 2 beds, 16% for 3 beds and 6% for 4 beds and more

Customer consultation and engagement

We are committed to maximising the use of customer feedback to shape and improve the quality of the services we offer, improve the tenant experience, and raise tenant satisfaction with their homes and where they live. The effectiveness of our tenant engagement and consultation will be monitored via our Tenant Satisfaction Measures results, as well as transactional tenant satisfaction surveys on completion of works or delivery of services.

We carry out a range of consultation activity, including large scale engagement, to more detailed discussions with smaller groups. The involvement offer includes using well established methods such as in person focus groups, engaging with resident in communities using the mobile office, through to digital approaches using Common Place, an online engagement platform, where residents are invited to give their views on a range of topics. The underlying principle of our engagement offer is that we give choice, making our engagement approach as inclusive and convenient as possible for residents to influence what we do.

Some examples of the opportunities to engage with tenants and residents in the delivery of the AMS are:

  • giving the opportunity for tenants and leaseholders to influence the procurement of future investment projects and service providers: what are their priorities and key drivers for tenants and how do we capture this in our procurement information
  • engaging with tenants who have recently experienced services to identify what works well with the existing providers and areas for improvement
  • helping identify and be involved in the scoping of added social value activity in partnership with our contractors and suppliers
  • consulting with residents about communal spaces and facilities: what residents like and what they would like to change

Strategic purpose

This strategy is forward looking, developed within the context of national policy and focusses on making best use of the council housing portfolio. It provides a structured set of objectives that underpin each of our strategic themes complete with specific targets that support their achievement.  

This strategy has been developed by Asset Management (Housing) in consultation with the Executive Board Member for Housing and the Director of Communities, Housing and Environment and, supported by dialogue and engagement with our key stakeholders which includes representatives from the following stakeholders:

  • Housing Management
  • Sustainable Energy and Air Quality
  • Council Housing Growth
  • Neighbourhood Services
  • Housing Projects, Contracts and PFI
  • Leeds Building Services (internal service provider)  

It sets out how the council will use its portfolio to meet the outcomes and priorities of the Best City Ambition and its key supporting strategies, in particular the Leeds Housing Strategy.

Vision statement

Our strategic themes

To enable us to meet our vision we have developed the following 4 strategic themes. Each of these will be underpinned with a series of objectives.

Building safety, quality and regulatory compliance

Ensuring our homes and communal spaces are places people are safe and feel safe. Ensuring compliance with our regulatory obligations and delivering high quality maintenance programmes, transparently reporting our performance across all areas of asset management.  

Data management and intelligence-led investment 

Ensuring we have a full and complete understanding of the condition of our homes by maintaining high levels of knowledge and information management, allowing us to use quality data to make investment decisions.

Improving energy efficiency

Ensure all our homes meet a minimum SAP band C through investment in energy efficiency measures. Maximise the use of low-carbon energy technologies to meet our net zero carbon goals, generate low-cost energy for our residents, and address fuel poverty through affordable warmth.

Place and space

Provide affordable and cost-effective homes for our residents, with clean safe and inspiring communal spaces for all who live and work there. Improvement to public realm and promote social inclusion and wellbeing.

Summary of each key theme

For each theme, we have summarised the objectives, how we will meet these objectives, how success will be measured and our key targets.

Building safety, quality and regulatory compliance

Objectives

We will:

  • ensure that we are compliant with all our regulatory and health and safety responsibilities, in line with the Consumer Standards with a particular focus on the Safety and Quality Standard and under the requirements of the Building Safety Act
  • focus on resident safety through high quality repairs and maintenance, as well as targeted investment in key areas contributing to this priority theme
  • identify and utilise new and existing technologies to assist with the effective management of assets and management of our data
  • ensure that we are fully transparent with our reporting of asset management related activities

How we will achieve this

  • Deliver our Stock Condition Strategy objectives, including ensuring 100% of homes receive a full stock condition survey at least every 5 years. 
  • Closely monitor our statutory compliance performance, reporting to relevant Boards via our Building Safety Dashboard and efficiently identifying and implementing and improvement requirements.
  • Ensure we have an effective procurement strategy for all asset management functions to supplement our work with Leeds Building Services in ensuring that service providers have the right skills, knowledge and experience to deliver services to the right standards and avoiding any breaks in service delivery.
  • Use data to identify emerging trends to reduce reoccurring issues, particularly repairs, maintenance and disrepair data.
  • Partnership working and collaboration with a range of stakeholders including tenants, leaseholders, peer groups and industry specialists

What success will look like

  • 100% compliance with our statutory asset management responsibilities. 
  • Develop and implement robust plans for the delivery of all actions identified during health and safety inspections. 
  • Positive regulatory judgment from the Regulator of Social Housing. 
  • Improved customer satisfaction across all asset management related Tenant Satisfaction Measures. 
  • Delivering business efficiencies through mobile working solutions.

Targets

  • Achieve 100% of all properties having received a full stock condition survey by the end of 2026, followed by an ongoing programme of c.11,000 properties to be surveyed per year
  • 100% compliance against our statutory asset management responsibilities, reported via our Building Safety Dashboard. 
  • Continued improvements in customer satisfaction, achieving upper quartile performance against our peer group.
  • Delivery of our annual capital investment programme, on time and on budget.
Data management and intelligence-led investment

Objectives

  • We will ensure that we have accurate and good quality data when making investment decisions.
  • We will use active asset management to identify key priorities for investment.
  • We will identify and utilise new and existing technologies to assist with the effective management of assets.
  • Support the Leeds Housing Strategy theme of Improving Housing Quality.

How we will achieve this

  • Deliver our Stock Condition Strategy objectives, including ensuring 100% of homes receive a full stock condition survey at least every 5 years.
  • Use data from across a range of services to identify emerging trends to reduce reoccurring issues, including repairs, maintenance and disrepair data.
  • Use feedback and engagement with tenants to inform investment decisions.
  • Utilise Options Appraisals to inform investment decisions on poor performing, potentially unsustainable or hard-to-improve assets.

What success will look like

  • Improved customer satisfaction with tenant perception of the quality of the home.
  • Investment is targeted into areas of most need and in line with strategic objectives and relevant legislation.
  • An improved integration with the Responsive Repairs service and an established asset led approach to reducing housing disrepair cases.
  • A reduced ratio of responsive repairs to planned maintenance spend.

Targets

  • Achieve 100% of all properties having received a full stock condition survey by the end of 2026, followed by an ongoing programme of c.11,000 properties to be surveyed per year.
  • Continued improvements in customer satisfaction, achieving upper quartile performance against our peer group.
  • Delivery of our annual capital investment programme, on time and on budget.
Improving energy efficiency

Objectives

  • To support the Leeds Ambitions.
  • Reduction in carbon emissions from Housing Assets.
  • Provide thermal comfort and reduce fuel poverty.
  • Support the Leeds Housing Strategy theme of Improving Housing Quality.

How we will achieve this

  • We will address and improve low SAP rated properties. All properties to be surveyed to determine additional energy efficiency measures.
  • Develop and implement a plan to ensure all homes meet a minimum EPC C rating.
  • Remove obsolete heating systems and replace with renewable / low-carbon heating systems.

What success will look like

  • Ensure the organisation has a good level of understanding in relation to energy efficiency.
  • There is a measured reduction of fuel cost though access to affordable fuel networks.
  • Access to additional grant funding is targeted and achieved in support of future projects.
  • Improvements in SAP ratings of homes across the estate at both an individual and portfolio (average) level.

Targets

  • A minimum EPC Band C by 2030 across the portfolio.
Place and space

Objectives

  • Effectively manage HRA public realm to improve the sense of place, space, and pride for residents.
  • Enhance resident involvement and community development to promote social inclusion and wellbeing.

How we will achieve this

  • Review land processes, developing guidance for Community groups to bring improved outcomes for local communities
  • Review waste management in our high-rise and medium-rise buildings.
  • Identify a programme of improvements to HRA owned roads and footpaths across our estates.
  • Review and update our garage strategy.

What success will look like

  • Improved tenant satisfaction, specifically:
    • satisfaction that communal areas are kept clean and well maintained
    • satisfaction that landlord makes a positive contribution to your neighbourhood
  • Waste management strategy for high rise and medium rise buildings completed in consultation with resident groups.

Targets

  • Waste management strategy objectives implemented.
  • Garage strategy implemented.
  • Upper quartile performance within peer group for TSMs identified above.

How we will deliver this Asset Management Strategy

To deliver the objectives of this AMS, robust links between the financial planning framework set out in the HRA Business Plan and the requirements of the stock are essential.

There are 4 key areas in which we will focus our efforts:

  • planning our delivery approach
  • maximising the use of data and management of information to support decision making
  • maintaining a strong governance framework
  • collaboration with key partners

Our delivery approach

This AMS will be used to inform a practical programme of investment that reflects best practice, through listening to the views and aspirations of all stakeholders and considering the impact of proposals on all residents, including our tenants and leaseholders.

Our investment programme will be based upon agreed area and delivery method objectives (over a programme period of not less than 5 years) and undertake as much work as possible in a planned way, to keep reactive works to a minimum.

Governance

All decision making is conducted in line with the council’s constitution.

This AMS will be subject to review on an annual basis throughout its term (2022 to 2027). Any amendments to the AMS, for example as a result of changes to legislation, will be subject to consultation with the following parties:

  • Executive Member for Housing
  • Director of Communities, Housing and Environment
  • Chief Officer, Housing
  • Housing Leeds Senior Management Team
  • appropriate tenant representatives

Capital Programme

The Capital Programme Board will provide oversight, scrutiny, performance monitoring, financial forecasting and risk management to all matters pertaining to the HRA Capital Programme within Housing Leeds. The Programme Board’s key focus will be on the delivery, risks, and financial forecasting. The collective responsibilities will extend to the following:

  • providing strategic guidance for all activities associated the HRA Capital Programme
  • providing appropriate challenge and support to operational teams and budget holders
  • reviewing key risks and issues associated with delivery and spend
  • operating as the link between the Budget Holders, delivery teams and the Senior Management Team
  • reviewing monitor and scrutinise progress against objectives
  • promoting a culture of support and cooperation which demonstrates the council’s values and drives continuous improvement

Procurement approach

The council will consider a range of options to identify the most appropriate procurement and partnership arrangements which take into consideration cost certainty, quality and added social value.

The use of local supply chain will be encouraged to assist in the growth of the local economy. Any procurement option selected will be designed to improve efficiency and eliminate the need for multiple or duplicated tendering exercises.

Working in partnership with the council’s Business Development and Housing Projects Team we will establish cross-functional teams comprising of service wide operational and management colleagues from within Asset Management (Housing), ensuring that we are fully equipped to deliver against operational targets with respect to the Procurement and Contract Management requirements of the council in line with Standing Orders, Financial Regulations and the Contract Procedure Rules (CPR’s) and where required the Public Procurement Regulations.

Leaseholders

A clear objective of the AMS is to deliver quality, value for money services to leaseholders and provide them with the opportunities to participate in developing and monitoring services. Leeds has over 2,600 leaseholders.

In accordance with the Leasehold Reform Act 2002, we will:

  • provide leaseholders with up-to-date and accurate information on investment and monitor satisfaction, supported by the development of a 5 year investment plan
  • ensure that Section 20 notices are fully compliant and issued in a timely manner so that the council can fully recharge for the cost of completed works
  • issue individually tailored leaseholders bills and statement of account and be able to accurately forecast future costs

The council has a duty to recharge leaseholders for a contribution to capital works, charges for building safety work and sustainability improvements to the existing asset, in line with current regulations.

We understand that the costs associated with such extensive stock investment is likely to be significant and result in high bills for leaseholders over the next 30-year period so will try to mitigate this by exploring repayment options where feasible.

Risk management

The council will review the impact and probability of specific risks materialising and will also evaluate the control arrangements in place to manage and minimise current and emerging risks.

Risks identified

The main risks and constraints for the delivery of the AMS are identified below.

Changes in legislation

This may impact the deliverability of the Strategy and will mean that investment priorities may have to be re-evaluated.

Change in climate policy

The Strategy establishes the long-term vision and responds to the council's ambitious net zero targets tackling local and national goals for the decarbonisation of heat at pace. Significant change in local or national policy will require a re-evaluation of the strategy, resource, and skills available, as well as the necessary growth in market capacity to deliver.

Financial certainty

The ability to develop accurate cost projection is fundamental to the effectiveness of the HRA business plan. Ongoing access to and utilisation of the asset planning tools to maintain a detailed forecast will be a key element in the success of the strategy.

Capacity and expertise

Additional technical expertise is required to support sustainability and retrofit. Recognising the need to manage the transition of an aging workforce and potential loss of skills.

Remaining on the corporate agenda

There will be a need for strong corporate leadership to sustain the momentum of implementation of the strategy over time. The ability to meet statutory targets for performance and compliance and maintain the reputation of the council and the safety of residents and relevant persons.

Environmental change 

The council cannot work outside the influence of extreme weather events. The impact of flooding, overheating and intensive periods of cold must be addressed if our assets are to be effective in providing necessary protection for tenants.

Changing service delivery models

Any changes to corporate and service strategies may have implications for the delivery of the Strategy.

This Strategy recognises that housing assets can also become liabilities, threatening the viability of the Housing Revenue Account, and significantly impacting on residents’ lives, carrying the following risks:

  • failures to manage Health and Safety compliance could put residents, staff, and contractors at risk
  • failures to meet statutory standards can carry significant criminal and financial penalties and will damage the organisation’s reputation
  • an incorrect scope or poor quality of stock investment will have a key influence on customer satisfaction, increasing reliance on the repairs service and other support structures
  • poor value for money in asset management will have a major impact on our finances as this represents a very large proportion of our business plan spend
  • failure to manage budgets through expenditure on items not included in the business plan, or at rates more than the business plan allowances
  • internal and external factors' impact on expenditure to make it the element of our landlord operations most vulnerable to increased costs

Regular processes to identify and assess risks are in place and actions agreed to manage risks to minimise impact.