Getting to know our Star Pubs & Bars Code Compliance Officers

Chris Moore - Code Compliance Officer


Lynne Winter - Code Compliance Manager

Code Compliance Officer: Chris Moore


Code Compliance Manager: Lynne Winter

Q: Tell us something about yourself and your paths to becoming a Code Compliance Officer and Compliance Manager?

Chris: I’m a Chartered Surveyor with 26 years’ experience in pubs. I joined the industry to get a years’ experience, and loved it so much I never left! I’ve worked in managed and leased & tenanted business models, in both property and operations roles. I’m the Property Director for Star Pubs & Bars and Heineken UK, and I oversee the teams delivering our big and ambitious capital investment programmes. I sit on the Star Pubs & Bars Leadership Team so have insight into all aspects of our business. Whilst I don’t have direct line management responsibility for our Business Development Managers (BDMs), I influence our policies and processes to ensure that as a business we are responsive to the changing compliance landscape. Day to day in my role of Code Compliance Officer I’m supported by Lynne Winter, our Code Compliance Manager.


Lynne: I started working in the industry as a graduate back in 2001. Originally, I worked as a regional Estates Surveyor before going on to do a number of different estates and commercial roles.  I am a Chartered Surveyor and I also have a Masters in Commercial Property Law - so my Compliance Manager role allows me to put both elements of my experience into practice.  I have also spent a couple of years working as a university lecturer so helping others to understand and implement the Code allows me to draw on the skills I learnt in a different sector.  Chris in his role as CCO is responsible for the Star Pubs Code strategy and I do more of the day to day implementation, working particularly closely with our Estate Management, BDM & head office colleagues.

Q: What achievement as CCO are you most proud of?

ChrisStar Pubs & Bars were one of the first companies to call for the publication of arbitration awards, we were pleased to lead the debate and get the industry to a consensus. I believe strongly in openness and transparency - in that respect the tied pub sector is leading the rest of the UK real estate market.

We are leading the way in granting investment waivers that demonstrates our commitment to the Great British Pub. We see a positive role and bright future for well run and well invested pubs – which is why we announced a further investment of £50 million in our pubs this year.

Having tripled the size of our pub business in 2018, with the acquisition of 1,900 pubs from Punch Taverns, training and embedding complex and evolving legislation to so many new colleagues has been challenging – but also rewarding in equal measure.


LynneThe implementation of the Pubs Code has led to greater transparency across the industry.  The ingoing process for new licensees is great – fully trained and informed at the point of entry means the lessee has a greater chance of running a successful & sustainable business.

Being involved with the Pubs Code and its implementation on a day to day basis I am particularly proud of how open and adaptable my colleagues are. There is a real determination to ensure that we are treating lessees fairly and providing them with enough information, to allow them to make informed & balanced choices at all stages of their time with Star.

Q: What are the most challenging aspects of your CCO role?

ChrisThe pubs code is a complex piece of legislation, and like all new law the interpretation and application can be challenging – this has also coincided with a massive transformation of our business from 1,000 to 2,900 pubs. As our understanding of the legislation has evolved, we’ve had to adapt our business accordingly. This has meant overcoming many business process, system and training challenges – not all have landed right first time, but what has made me proud is the commitment and energy of my colleagues to get it right and the right things.


LynneThe Pubs Code and its implementation is constantly evolving and as a result so is the way that we do things.  This can be particularly challenging in terms of changing ways of working, processes and keeping colleagues up to date with any changes.  In a large organisation it takes time and effort to do these things, but I am pleased to say that Star as an organisation is committed to doing this and we have plenty of people working behind the scenes to ensure we stay on track.

From a personal point of view, I took on the role of compliance manager at the same time we acquired 1,900 pubs – learning a new job at the same time as we tripled our estate was a bit of a steep learning curve!

Q: What would you most like to achieve in the next 12 months?

ChrisContinuing the sharing of information about the code with our licensees, which we do by signposting at stages of the process and regularly communicating with them. We ran some polls at our recent Licensee Forums and overwhelmingly the message was that they want more information about the code through their BDM, so we will be running some specific activity in the New Year to address this.

We will continue to engage constructively with the PCA’s office, our licensees and other stakeholders to ensure that Star Pubs & Bars are leading the way with compliance and that the code is enabling the industry to grow and thrive.

I hope that during 2019-20 we get to a place where everybody understands clearly what an MRO compliant agreement is, and that the PCA is able to accredit agreements to give confidence and certainty to both Pub Companies and tied tenants.


LynneI hope that through increased information being made available to licensees and through the communication and the publication of arbitrations more certainty on key issues will emerge. I believe this will be helpful to both the licensees and the Pub Owning Businesses. 

As greater clarity around elements of the Code emerges, I believe this will also allow negotiated settlements to be reached quicker.  There are still issues that are being experienced for the first time but this will diminish over time as knowledge and experience of the code increases.

Q: Would you like to give a message to the tied pub industry?

ChrisStar Pubs & Bars is committed to making the code work – both in spirit and word. Our ambition is to Build Britain’s Best Pub Company by attracting and retaining the best operators.

We will continue to listen and reflect on learnings and then transpose, adopt and innovate our systems, process and ways of working. Whilst the code lays down minimums, we strive to exceed those standards, and work openly with our licensees at all stages of recruitment, rent review and agreement renewal. It is my ambition that other real estate markets copy the tied pub sectors open and honest approach to doing business.

It is inevitable that, when parties involved in a complex commercial partnership governed by new legislation, differences and disagreements arise. If they do, I’m here to listen to licensees concerns and work with them to resolve issues.

I would like to finish by saying that the legislation can’t be judged by the number of licensees taking MRO’s. That many do look at MRO but still choose the lower fixed cost, lower risk, high support of continuing their supply agreement proves that the legislation is working. This means licensees are able to see that they are no worse off by remaining with us. MRO provides us with the opportunity to explain the benefits of the Leased and Tenanted model.


LynneI would echo Chris’s comments that we are committed to making the code work.  We are continually evolving our policies and processes and ways of working to ensure that we implement the code and to be as fair and open with our licensees as possible. 

This is still relatively new legislation and we are learning all the time. We are continually engaging with our colleagues, licensees and others across the industry to adhere to the Code, working closely with the PCA’s office.