transitional housing not meeting these standards, even though in many cases the motels are used as long-term housing well beyond the intended 12 weeks.48 As with emergency accommodation, we are concerned that motel-style accommodation may be entirely inappropriate for long-term transitional housing. Some transitional housing residents have reported stays of years at a time while they wait for permanent housing that meets their needs. We also highlight the safety concerns some residents have shared with us. We have heard from people who went back to sleeping in their cars because they felt safer there than in emergency housing (both emergency accommodation and transitional housing). Concerns raised included accommodation which was not adequately safe and secure (e.g. broken doors or locks) and inadequate or inappropriate security firm practices. b) Emergency housing must also meet other key features of the right to a decent home Emergency housing must be delivered in accordance with principles of equity, equality, and non-discrimination. Emergency housing policies and practices must be fair, reasonable, proportionate, and culturally appropriate. Based on what we have heard and observed, the government’s delivery of emergency housing (via emergency accommodation and transitional housing) does not appear to be meeting these human rights standards to an adequate degree. The way the emergency housing grant initiative is designed has created a situation where commercial accommodation suppliers (particularly private moteliers) are neither landlords nor social service providers but are nevertheless tasked with a key role in the government’s homelessness response. 46 Human Rights Commission In contrast, transitional housing providers are required to undergo accreditation as approved social service providers.49 The Level 3 Social Sector Accreditation Standards require providers to “treat people with respect and deliver services in a manner that has regard for their dignity, privacy and independence,” by promoting client-centred practice, evidence of which may include: • providing services that are accessible to disabled people • providing services free from any discrimination, coercion, harassment, and sexual, financial or other exploitation • service recognition and respect for clients’ ethnic, cultural and spiritual values and beliefs Transitional housing providers are also required to provide services consistent with community wellbeing, including welfare and interests of children.50 The Accreditation Standards explicitly set out requirements for staff capability and capacity (including compliance with the Human Rights Act 1993), vetting, induction, training and support, and obligations to establish complaints processes and accountability over service delivery. We are seriously concerned that there does not appear to be any accountability mechanism within the emergency housing grant system to ensure that commercial accommodation complies with human rights obligations owed to accommodation recipients. We have heard of instances where individuals and whānau have been refused accommodation and the refusal appears to be based on a prohibited ground of discrimination (such as pregnancy, ethnicity, disability, or health status including mental health or addiction). Residents may make a complaint to the Human Rights Commission leading to mediation between the parties, but only in relation to discrimination, not other alleged breaches of the right to a decent home.51