Yes we had to do it and as a small charity with only 7 almshouses and four trustees it was extremely difficult to do this in such a short time frame (they gave us about 5 days from me receiving their email to their deadline date) it was very in depth. We had a basic complaints policy but now have had to put alsorts of other policies in place that we didn’t have. Luckily we have one trustee who is used to dealing with things like this.
We haven’t had any complaints since i became a trustee over 25 years ago! It seemed very much for larger housing associations rather than small almshouse charities.