Update - The Pubs Code Adjudicator has concluded its review of Star’s reported breaches of the Pubs Code in relation to failures by Business Development Managers to provide meeting notes

How did Star breach the Pubs Code?

The Pubs Code Adjudicator (PCA) was made aware by Star in July 2024 that some notes of meetings between Star Business Development Managers (BDMs) and tied tenants were not provided to tied tenants within 14 days of the relevant discussion having taken place and in some cases were not provided at all. These notes, which Star calls Business Review Sheets, relate to meetings that happened between 2018 and 2024 with tenants on tied agreements.  

Under the Pubs Code, a pub company must ensure that the BDM provides tied pub tenants with a record of discussions in connection with matters set out in regulation 41(4)(a) within 14 days of the discussion.

Action taken by Star

Prior to contacting the PCA, Star audited a sample of over 15,000 Business Review Sheets from 2023. This audit identified four different methods which had been used to complete the Business Review Sheets, including where copies were saved to Star’s internal system, but not emailed to the tenant. 

Star informed the PCA that it had taken a number of remedial measures to prevent a repeat of the breach, including retraining BDMs through regional development programmes. Star further informed the PCA during its evidence that it had transitioned to a new IT system in respect of the completion of BDM notes for onboarded tenants.

Following the breach report, the PCA was not satisfied with the steps Star had taken to understand tenant impact. The PCA sought further information from Star to understand the nature and extent of the breach, and Star’s remedial steps. Following the collection and consideration of all appropriate evidence from Star, the PCA took the decision to issue a Call for Evidence in July 2025 to better understand the issue of impact on tenants.

Outcome

The PCA has carefully considered the evidence provided by Star, the responses from tied tenants (and former tied tenants) to the Call for Evidence and evidence from other sources.  Although the number of breaches of regulation 41 identified was very high, there was only limited evidence to show that there had been significant detrimental impact on individual tenants.  Star has, as a result of PCA intervention, provided sufficient opportunity for affected tenants to contact them regarding any such detriment.

The PCA has issued a written censure to Star on the basis that a substantial number of breaches was allowed to occur and persist over an extended period. However, taking all the available evidence into consideration, the PCA does not consider it appropriate to take further regulatory steps at this time and welcomes the comprehensive mitigating actions taken by Star. The PCA has published a report on its consideration of the breaches reported by Star.

The PCA reserves the right to take these breaches into consideration when determining any future regulatory action it may take in relation to Star’s duties under the Pubs Code, including under regulation 41.

Enquiries about this matter can be sent to Star’s Code Compliance Officer, Lynne Winter at [email protected]

The PCA office can also be contacted at [email protected]