This policy relates to the Residential Tenancies Act 2010
NRSCH Performance Outcome 1 – Tenant and Housing Services


The purpose of this policy is to guide staff in the identification of and management of Unreasonable Complainant Conduct.


Unreasonable Complainant Conduct (UCC) – is any behaviour by a complainant which, because of its nature or frequency raises substantial health, safety, resource or equity issues for staff, other service users and complainants or the complainant themselves.
UCC can be categorised into five conduct types:
Unreasonable persistence – e.g. unwilling to accept reasonable and logical explanations including final decisions.
Unreasonable demands – e.g. demands that have a disproportionate and unreasonable impact on the organisation- e.g. insisting on conversing with an Executive manager when it is not appropriate or warranted.
Unreasonable lack of cooperation – e.g. unwillingness to cooperate with staff or engage with the complaints system and processes, leading to an excessive and disproportionate utilisation of services, time, or resources.
Unreasonable arguments – e.g. arguments that are devoid of rationale or logic, are incomprehensible, false, or inflammatory, trivial etc…
Unreasonable behaviours – e.g. conduct that remains unreasonable under all circumstances, irrespective of the complainant’s level of stress or frustration, as it unreasonably jeopardises the health, safety, and security of staff or the complainant.


This policy applies to all SCH staff in responding to a complaint by a current or former tenant, client and/or a member of the public, where the complainant’s conduct is deemed unreasonable as defined above.


This approach provides for all complainants to be treated with fairness and respect with the nature of their complaint, influencing the allocation of resources dedicated to resolving their issue.

The escalation process is not necessarily linear, for instance, any threats of violence will immediately be determined as unreasonable complainant conduct, leading to the implementation of appropriate restrictions.

What constitutes unreasonable client conduct is clearly defined, providing specific examples, when possible, to guide understanding.

SCH will establish clear channels of communication to address and resolve issues related to unreasonable conduct and encourage open dialogue to understand concerns.

Comprehensive records of instances of unreasonable client conduct, including communication records and any actions taken to address the behaviour will be maintained.

SCH will implement a graduated approach to addressing unreasonable conduct, beginning with warnings or discussions, and escalating to more severe measures if necessary.

Client confidentiality will be maintained while addressing and resolving issues related to unreasonable conduct.

SCH ensures that this policy aligns with legal and ethical standards, and that actions taken are in accordance with applicable laws and regulations.

Staff will be provided training to recognise and handle instances of unreasonable client conduct effectively, encompassing conflict resolution and de-escalation techniques.

SCH clients will be informed on acceptable behaviour and the consequences of unreasonable conduct, fostering a collaborative and respectful working relationship.


All staff are to acquaint themselves with this policy so that they can effectively address inappropriate behaviour.

Managers in consultation with their General Manager and/or Deputy CEO, are to determine whether the complainant is unreasonable and the appropriate response (including nominating a future contact person).

A review of a decision will be conducted by the relevant manager in accordance with the Response Level as referenced in the procedure.

An Appeal review will be conducted by a manager independent of the original decision.

The Audit & Compliance Officer will maintain a Central Register of UCCs as well as categorising the entity in Greentree.

Documents Related to this Policy

Related Policies

  • M20 Complaints Policy
  • M14 Work Health & Safety Policy

Other Related Documents

  • NSW Registrar of Community Housing Guidelines for Managing Unreasonable Complainant Conduct.
  • Managing Unreasonable Complainant Conduct, Practice Manual (2nd Edition) – NSW Ombudsman
  • Managing Unreasonable Complainant Conduct – a Model Policy and Procedure, NSW Ombudsman
  • Antisocial Behaviour Management Policy DCJ