6th Annual Audit – England & Wales


Pub Sector – England & Wales TENANTED Code of Practice (1-499 Tied Pubs)
Pub Sector – England & Wales LEASED Code of Practice (1-499 Tied Pubs)

The annual audit of companies operating tied public houses covered by either of the above codes of practice was carried out between August and September 2022 and covered the period 1st August 2021 – 31st July 2022.

A full list of those companies covered by each code can be found in Annex A.
Those companies not covered by the government’s Pubs Code (those operating fewer than 500 tied pubs) and the Pub Governing Body agreed that the good practice enshrined in the Industry Framework Code that preceded statutory regulation of the larger chains should continue. Additional improvements and updates were made to the codes during the audit period.

The Board also introduced a trade mark for companies to use on their web sites, brochures and on social media to show to prospective tenants they are signatories to the Code.
Scotland has its own Pub Governing Body, the report as per last year has been split into two parts, one for England & Wales and one for Scotland.

The PGB Board England and Wales consists of :
Sir Peter Luff – England and Wales Chair
George Barnes – Shepherd Neame Ltd
Martin Caffrey – Federation of Licensed Victuallers Association
Michael Clist – British Institute of Innkeeping
Nick Griffin – The Licensees Association
Emma McClarkin – British Beer and Pub Association
Kate Nicholls – UK Hospitality
Jayson Perfect – The Liberation Group
Bill Sharp – Guild of Master Victuallers
Andy Tighe – British Beer and Pub Association


The Board is pleased to see that the data in the sixth annual report once again shows there is a high level of compliance with the Tenanted and Lease codes governing signatory companies in England & Wales.
The Board welcomes the full compliance regarding both business plans and Pre-Entry Training in lettings where a waiver does not apply. We would encourage the rent reviews that are outstanding to be completed as soon as possible.

On training, the Board are happy to see that following last years request to re-commence training following furlough there are now only 6 BDM’s in training the remainder all have achieved Level 4 or above.

Commenting on the sixth annual audit report, Pub Governing Body Chairman Sir Peter Luff said:
“Perhaps the most significant statistic in this report is zero – the number of referrals to both the Pubs Independent Conciliation & Arbitration Service and to the Pubs Independent Rent Review Scheme. The fact that no tenant has had to resort to these dispute resolution services over this twelve-month period is the clearest proof that the Codes overseen by the PGB are working.

Indeed, the sixth report of the board of the Pub Governing Body shows the highest level of compliance with those codes yet, and this after five very encouraging years of reports.

Times remain immensely difficult for all involved in the hospitality sector, with labour shortages and rising fuel bills following hard on the heels of the Covid-19 pandemic. Last year we expressed the hope that the previous five years of progress would not be reversed in such difficult conditions, but in fact the opposite has happened and compliance has improved still further.

With self-regulation working so effectively, I have concluded this is the right time for me to stand down as Chairman of the PGB, and I will do so at the end of the year. I am delighted that my last annual audit report clearly demonstrates how the industry has embraced self-regulation. This is important because, as I said in last year’s report, “… we believe the work of the PGB remains a vital component in continuing confidence among tenants, commentators and politicians in the effectiveness of self-regulation of smaller pub companies.”

My one specific hope is that the coming year will see greater use by companies of the PGB ‘kitemark’. A risk to continuing self-regulation of the sector is the small number of pub companies who have not yet signed up to the codes. Wider use of the ‘kitemark’ would help prospective tenants both to be clear whether or not their pub company supports the codes and to reach informed decisions about doing business with them.

The sixth annual audit report is the product of the work of many people and I would like to congratulate all involved in this success – pub companies, tenants, my colleagues on the board of the PGB and those who support the board. The spirit that you have brought to the work of the PGB has made my role both enjoyable and rewarding. I am sure that spirit means the seventh report next year will demonstrate your continuing success.”

The Board would like to take the opportunity to thank Sir Peter for Chairing the Pub Governing Body for the past eight years during which time there has been a strengthening of the Codes and excellent compliance. The Board also wishes to announce that they have appointed James Anderson a Partner of the Licensing Solicitors Poppleston Allen to the position of Chair commencing 1st January 2023. James is already Chair of PICA Services and has attended the Board in that position which places him in the best possible position to take over the full Chair’s role.


The full list of companies covered by the respective codes can be found in Annex A.
(Figures in brackets are 2020-21)

Pubs surveyed
• 2,581 (2,541) tied pubs are covered by the codes of practice for under 500 companies (England & Wales).
• Of these, 2,141 (2,008) are classified as tenancies and 238 (286) as leases.
• The number of TAW’s/Closed is 202 (247).

Code compliance
• 294 (264) final interviews took place for leases and tenancies in the survey period.
• 294 (264) business plans were completed being 100% with non outstanding.
• Pre-Entry Awareness Training (PEAT) was completed in 197 (172) cases 67% (65%). The remaining 33% (35%) were waived as applicants were multiple retailers, had three years previous tenanted/leased experience or already had an existing successful tied pub with the company concerned.

Rent reviews
• In the survey period, there were 382 (351) rent reviews triggered.
• Of these 333 (272) or 87% (77%) were negotiated and settled within the same period.
• 49 (79) or 13% (23%) were still under negotiation.

Business Development Managers
• 75 (71) BDMs were employed by companies over the survey period.
• 69 (58) of these 92% (81%) were BIIAB Level 4 trained.
• The remaining 6 (13) have joined the company recently (the Code allows for training within 24 months of being appointed) or are waiting for courses to become available.

PIRRS and PICA-Service
• There were no referrals to PICA-Service in the survey period.
• There were no referral to PIRRS in the survey period.
‘Protected’ agreements

• The total number of pubs with substantial agreements was 2379 (2294) of which 1918 (1909), 81% (83%) are Landlord & Tenant Act ‘protected’. The remaining 461 (385) or 19% (17%) are ‘unprotected’ agreements.


Adnams plc
Arkell’s Brewery Limited
Camerons Brewery Limited
Charles Wells Limited
Daniel Batham & Son Limited
Daniel Thwaites plc
Everards Brewery Limited
Frederic Robinson Limited
Fuller Smith & Turner plc
George Bateman & Son Limited
Gray & Sons Limited
Hall & Woodhouse Limited
Harvey & Son (Lewes) Limited
Heavitree Brewery plc
Holdens Brewery Limited
Hook Norton Brewery Company, Limited
Hyde’s Brewery Limited
J.C. & R.H. Palmer Limited
J.W. Lees & Co. (Brewers) Limited
Joseph Holt Limited
Liberation Group Ltd/Butcombe Brewery
McMullen & Sons Limited
Mitchells & Butlers plc
St Austell Brewery Company Limited
Shepherd Neame Limited
Timothy Taylor & Co. Limited
Trust Inns Limited
WH Brakspear & Sons Limited
Wadworth and Company Limited

October 2022

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