The detailed plan released by Heineken’s pub arm and the operator of in the region of 2,500 pubs sets out a timeline of when Star intends to address each of the eight binding recommendations Dickie made after finding the company had committed 12 breaches of the pubs code.
The industry regulator concluded that the nature and seriousness of the 12 breaches uncovered had “frustrated the principles of the pubs code” and merited a financial penalty of £2m.
As well imposing the fine, which was based on the turnover of the whole of Heineken UK, Dickie also demanded that Star make all its free-of-tie tenancies code compliant and to ensure future code compliance.
These recommendations established what Star had to do to correct harm caused to tenants, including carrying out an audit of completed free of tie tenancies to identify any non-compliant stocking terms and offering to change them – or change their impact – without cost to the tenant.
In December the operator’s managing director Lawson Mountstevens confirmed Star’s intention to appeal the penalty.
On top of setting out how Star will meet the PCA’s recommendations, the new plan includes a pledge to review or adjust its processes as well strengthen internal checks and balances to demonstrate evidence-based compliance with the pubs code.
Star will also establish a “compliance cabinet” within its management system to ensure independent assurance.
“Star has provided a detailed plan for carrying out my recommendations and I welcome this,” Dickie said. “I will continue to monitor Star’s compliance with them to ensure they are implemented effectively and efficiently.
“I am currently engaging with Star on how the company is putting this plan into practice and will provide a further update on progress in due course.”
Star’s plan is available to view on the PCA’s website here.