Human rights standard

Nationwide holds a unique position in the UK financial services sector. As the largest building society, we can deliver the value, service and benefits of mutuality to our customers and members in a way banks are unable to. We are owned by our members (customers who have their current account, mortgage or savings with us). Our banking products and services seek to help our customers with managing their everyday finances, owning a home, and saving for the future. We also support landlords and those who rely on the private rented sector for their long-term housing needs through our buy-to-let business, The Mortgage Works. In addition, we offer a comprehensive range of wider retail financial services and products, including credit cards, personal loans and insurance.

Our strategy is centred around our purpose: ‘Banking – but fairer, more rewarding, and for the good of society.’ This states our ambition to make a positive difference for our members and customers, our communities and society as a whole.

We also seek to be a good employer. Our purpose and core mutual values inform how we respect, uphold and promote universally-accepted labour rights across our operations and value chain.

We believe in doing business in a way that promotes and respects the human rights of everyone who is impacted by Nationwide. We are committed to building positive relationships with all our stakeholders.

Through our policies and processes we seek to make a positive impact on our range of stakeholders. We will address and reduce, where possible, any potential negative human rights impacts that our business might have on those around us.

Nationwide’s respect for human rights is aligned with the United Nations Guiding Principles on Business and Human Rights (UNGPs), and those codified in international law through the International Bill of Human Rights. This requires us to protect, respect and remedy human rights in a business context, and consists of the:

• Universal Declaration of Human Rights (opens in a new window)
• International Covenant on Civil and Political Rights (opens in a new window)
• International Covenant on Economic, Social and Cultural Rights (opens in a new window)
• International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work (opens in a new window)

As a signatory to the UN Global Compact, we are aligned to its principles, including those encompassing human and labour rights. We are a signatory to the United Nations Environment Programme Finance Initiative (UNEP FI) Principles for Responsible Banking, reinforcing our commitment to the UN Sustainable Development Goals (SDGs). It is also our aspiration to support the UK in achieving its ambition to be net zero by 2050. Our Mutual Good Commitments demonstrate how our business aligns to and supports the UN SDGs. More information on our Mutual Good Commitments can be found in our Environmental, Social and Governance disclosures. In 2021, we became a member of the Net-Zero Banking Alliance (NZBA) and part of the Glasgow Financial Alliance for Net Zero (GFANZ). Recognising the potential impacts of climate change to our customers, communities, and wider society, we remain committed to playing our part in supporting the transition to a net-zero economy, and as a member of the Financing a Just Transition Alliance, we believe in supporting a just transition.

In 2023, we participated in the UN Global Compact’s Business and Human Rights Accelerator programme to help increase our understanding of best practice when conducting our due diligence with respect to human rights.

In accordance with the Modern Slavery Act 2015, we publish our annual Modern Slavery Act Statement on our website. This outlines the steps we take to mitigate the risk of slavery or human trafficking taking place across our business, operations, and supply chain.

We take great care in trying to identify and reduce any harm that may affect people, either directly or indirectly, by the way we do business. This is an ongoing process that we take very seriously, across our operations and value chain. The measures we have in place to support our customers, colleagues, suppliers and communities are described in our Environmental, Social and Governance disclosures. We have a suite of controls, policies and practices that support a culture of responsible behaviour across our business. More information can be found in our policies and statements.

Nationwide exists for its customers and members, helping with the management of everyday finances, saving for the future, and owning a home. Accessible financial services afford people dignity, security, equality, and inclusion. We recognise our responsibility in helping to reduce some of the risks and challenges that might prevent equal access to these rights.

We are guided by UK financial regulations such as the FCA’s Consumer Duty and the FCA Guidance on the Fair Treatment of Vulnerable Customers. These require Nationwide to put customer needs first, including recognising, understanding and responding to the needs of vulnerable customers to ensure accessibility and prevent harm.

We comply with applicable legislation such as the Equality Act 2010, which protects customers from discrimination, and we promote an open and responsive attitude to complaints that enables customers to report instances when they feel their human rights may have been harmed. Complaints may give us early warnings of human rights risks.

We provide customers with choice in the way they bank with us, including through our digital channels, on the phone, or in our network of branches (underpinned by our Branch Promise). We seek to make our channels accessible and inclusive for all, and have a range of initiatives in place to support our customers with disabilities, as described in our Environmental, Social and Governance disclosures.

We want to support and protect our customers’ financial wellbeing by helping to build their financial resilience. We do this by:

• Supporting good savings habits and increasing confidence in managing money.
• Working to address the challenges many people experience when buying and accessing quality homes, through our propositions, through our lending to the social housing sector, and through engagement with regulators and policymakers.
• Helping to protect customers from economic crime.
• Understanding and responding to vulnerable customers’ needs, including those in in financial difficulty, and providing specialist support where required.
• Applying a strong ethic of care, inclusion, and accessibility through the design and availability of our channels, our aims for financial inclusion, and in the way we design, sell and manage our products and services.
• Engaging with regulators and policymakers more broadly to champion the needs and interests of our customers.

We have a variety of initiatives in place to support our ambitions, as described in our Environmental, Social and Governance disclosures.

We continue to work to protect our customers from becoming the victims of crime, and to prevent Nationwide from being used to facilitate criminal activity, including economic crime. Strong governance, culture, policies, and defence systems, coupled with training, heightened awareness, and human interventions, all play their part in helping us to protect our customers.

We focus on:

• Ensuring our customers can transact safely, protecting customers from fraud and scams.
• Using policies, procedures, and regular training to help us operate with integrity, defend against economic crime, including modern slavery, financial abuse, and other forms of financial exploitation and crime.
• Keeping customers’ money and personal data safe and secure by managing cyber risks.
• Respecting and protecting our customers’ data, ensuring privacy.
• Providing a range of ways for customers to raise concerns.

Nationwide is committed to fighting modern slavery and human trafficking throughout its retail business, operations and supply chain. Our anti-slavery approach has three focus areas:

• Detect and disrupt
• Raise awareness
• Support victim-survivors

We mitigate and manage the risk of modern slavery through a range of controls and due diligence processes. These include:

• Reporting suspicions of modern slavery, identified through transaction monitoring and suspicious behaviours in our branches.
• Supporting the needs of vulnerable groups and individuals, who we recognise are at greater risk of exploitation.
• Providing alternative options to customers without standard identity documentation, and offering a basic bank account to ensure financial services are available to those who might otherwise be excluded from mainstream banking.
• Recruiting colleagues in a responsible way, providing training, decent work and a living wage, and promoting channels for speaking up and whistleblowing.
• Conducting due diligence within our supply chain processes, including requesting suppliers attest to comply with our Third Party Code of Practice and regularly testing the compliance of a prioritised set of third parties to the Code; working with sustainability ratings provider EcoVadis to monitor and manage third party supplier performance across themes including labour and human rights, ethics and sustainable procurement; and conducting enhanced monitoring within certain higher risk areas of our supply chain.
• An internal, cross-functional working group that enables us to co-ordinate initiatives, insights and learnings.

In addition, we work with modern slavery charities to build our own knowledge and understanding on how we can best respond to the needs of vulnerable customers.

Our Modern Slavery Act Statement outlines what we are doing to help fight modern slavery.

We believe that our colleagues should be treated with respect and dignity and work in an environment that is free from harassment and unlawful discrimination.

We are responsible for respecting and promoting the human rights of all our colleagues, which we do through:

• Our Human Resources policies and processes, which reflect best practice and legal requirements
• Providing our colleagues with a safe and healthy work environment that is free from discrimination
• Ensuring working hours are not excessive and that colleagues take appropriate rest breaks and holidays to ensure a work-life balance
• Providing fair remuneration and equal pay for equal work. We are an accredited Living Wage Employer, as per the Living Wage Foundation. We offer a generous package of family friendly leave (opens in a new window) and other competitive benefits
• Building a supportive, fair and inclusive environment for our colleagues, where our colleagues can thrive and develop rewarding careers
• Complying with the relevant legislation when employing those under the age of 18
• Complying with the relevant data protection legislation when processing colleague data
• Supporting our colleagues’ right to freedom of association and collective bargaining.

Our colleagues are encouraged to bring out the best in each other, to create a place where differences are valued. We continue to support our colleagues with their physical, mental, emotional, social, and financial wellbeing.

We carry out regular pay monitoring and test our approach through periodic equal pay audits. These make sure our policies are operating fairly and without bias. We also publish our gender and ethnicity pay gaps annually.

Our culture at Nationwide is built on a strong ethic of care that treats our people with dignity and respect.

For us this involves:

• Rewarding people fairly and creating a climate that enables people to perform better.
• Protecting and promoting our colleagues’ right to decent work.
• Balancing commerciality with our values and ethic of care so that, as we transform our organisation, our people still feel supported.

Our Labour Rights Standard provides further detail on our commitment to protect and promote labour rights for all colleagues at Nationwide.

Our Code of Conduct policy supports our commitment to promote a culture of honesty and integrity across Nationwide, enabling our people to do the right thing for our customers. We continually listen to our colleagues by providing regular opportunities for them to share their views, including through our culture and engagement surveys.

This frequent insight into our colleagues’ experiences means we can respond with agility and pace to support where and when it is needed. We gather insights through our employee network groups, engagement with Nationwide Group Staff Union (NGSU), and Employee Connect, an online forum that enables feedback from colleagues across the Society. We also hold question and answer sessions with our Executive Committee and Non-Executive Directors.

We support, promote and encourage our colleagues to speak up whenever they witness or experience actual or potential wrongdoing or misconduct, and want them to feel confident to do so without fear of retaliation. We have arrangements in place for employees, contingent workers, work placement students and any other party with whom we have a business relationship, to raise concerns. We also encourage our suppliers to share their concerns, as outlined in our supplier policies. For all parties, these can be raised confidentially or anonymously (if preferred) via a range of whistleblowing channels, including an online portal and mobile app, hosted by an independent third party.

Under our policies and processes, Nationwide does not tolerate bullying, harassment or unlawful discrimination of any kind, whether by our employees, contingent workers, suppliers or customers.

The fundamental ways in which Nationwide operates, from our social investments and charity partnerships, to our relationship with the environment, all leave their mark on the ability of our communities to thrive. Thriving communities offer secure homes, reliable access to finances, a good standard of education and learning, and positive job and career prospects. As a mutual, we seek to make a positive difference for our customers, communities and society as a whole. We commit at least 1% of our pre-tax profits each year to charitable activities. We also seek to use our voice to drive positive change, using our size, influence, and values to work for the good of society.

This includes engaging with the government and politicians to champion the interests of our customers and Nationwide, such as working with them to help overcome the barriers to owning a home, and on enhancing protection from fraud and scams. We are also engaged through our trade association memberships, including UK Finance and the Building Societies Association.

We recognise the value that our high street branches have for our customers, some of whom rely on our branches, prefer to speak with us face to face, or value choice in the way they bank. We have extended our Branch Promise, so that everywhere we have a branch, we promise to still be there until at least the start of 2028¹.

Take a look at what we are doing and read our Social Impact Report.

As a mutual, and a member of the Financing a Just Transition Alliance, we believe in supporting a just transition so that, as we transition to a net-zero economy, the most vulnerable in society are not disadvantaged.

Our Climate-related Financial Disclosures describe our understanding of the impact of climate change on Nationwide and our customers. It outlines the actions we are taking to understand and manage climate-related risk. 

Our Environmental Standard directs colleagues to the relevant policies, guides and training to support Nationwide's environmental ambition.

We’re different from a bank. Our assets must be largely formed of residential mortgages, which includes social housing and buy to let lending. Our treasury investment portfolio, held primarily for liquidity purposes, is made up of cash and low risk investments. We do not invest in corporate bonds or equities.

Nationwide Treasury aims to hold at least £2 billion of ESG assets, which includes bonds issued by multilateral development banks and green, social and sustainable labelled bonds. Multilateral development banks provide financial support for economic and social progress in developing countries, and help to advance the UN Sustainable Development Goals (SDGs).

Read about our approach in our Responsible investment statement.

It is important that our suppliers represent Nationwide and demonstrate a commitment to our policies and standards. Nationwide’s Third Party Code of Practice outlines the environmental and social standards we expect our suppliers to uphold, which includes our expectations to respect the values and human rights of their workers. This includes, but is not limited to: prohibiting the use of child, forced, or involuntary labour, and to respect labour rights including those relating to discrimination, whistleblowing and collective bargaining. They must adhere to the working hour practices outlined within the Ethical Trading Initiative Base Code (opens in a new window) or an equivalent recognised international labour standard.

At onboarding, all prospective suppliers are asked to agree to comply with our Third Party Code of Practice and, if they are required to produce a Modern Slavery Statement under the Modern Slavery Act, they are asked to confirm that they have produced a compliant statement. Supplier responses to these questions are also reviewed at point of a new or renewed contract. If either of the questions are answered negatively, we investigate and seek to negotiate a schedule to close the gaps in a defined timeframe. Should the supplier refuse, Nationwide’s Chief Procurement Officer will determine if there are grounds for dispensation.

Nationwide conducts regular evidence-based testing of third-party compliance with the Third Party Code of Practice, for a prioritised set of third parties. Where a subcontractor is used to provide a material service to Nationwide, the third party is tested on their supply chain due diligence. Where non-conformances are found, remediating actions are requested and followed up at the completion dates agreed.

Since 2021, Nationwide has partnered with sustainability ratings provider EcoVadis, to help us monitor and manage our suppliers’ performance across environment, labour, human rights, ethics, and sustainable procurement activities. The EcoVadis methodology is aligned with United Nations Global Compact (UNGC) principles, allowing us to assess supplier compliance with international human rights standards. Third parties are asked to complete the assessment on an annual basis. We have set a minimum benchmark sustainability rating for suppliers, and those that score below this are provided with a corrective action plan and requested to improve and reassess within 12 months. EcoVadis also provides a news monitoring service that can impact the company’s rating. Our supplier relationship management colleagues are expected to discuss their respective third parties’ EcoVadis performance annually, in line with our third party governance framework.

Responsible purchasing training is made available to all colleagues, to enhance understanding on why we must take action to manage the environmental and social impacts of our purchasing and supplier management activities. More on how we responsibly and ethically select and manage our third parties, can be found in our Environmental, Social and Governance disclosures.

Our Responsible Business Committee provides oversight of Nationwide’s Human Rights Standard.

We use research, policies, risk assessments, and other strategies and initiatives to support and protect the rights and dignity of our customers, colleagues, third parties and communities. The governance structures that manage and oversee these, each feed into their relevant Executive and Board sub-committees and into meetings of the Executive Committee.

Our Human Rights Standard is supported by policies and processes that help us to identify human rights coverage and any associated risks and gaps.

These include our:

• Anti-slavery standard and guidance
• Becoming a Parent policy
• Domestic abuse policy
• Fair treatment at Work policy
• Flexible Working Policy
• Gender transitioning and change of gender expression policy
• Health, safety and environmental policies
• Healthcare and protection benefits policy
• Hybrid working policy
• Inclusion and diversity policy
• Job security and redundancy policy
• Labour rights standard
• Payments and working arrangement policies
• Pensions policy
• Resolutions framework (which covers harassment and bullying)
• Rewards policy
• Third party code of practice
• Time Off policy
• Wellbeing policy
• Whistleblowing policy

We have adopted policies and procedures designed to ensure compliance with legal and regulatory requirements and which seek to prevent our products and services being used for improper purposes. These include our:

• Code of conduct policy
• Conflicts of interest policy
• Data privacy policy
• Economic Crime Policy and supporting Minimum Control Standards (MCS)
• Gifts and hospitality policy
• Market abuse policy
• Modern slavery statement
• Privacy and monitoring policy
• Regulatory conduct and responsibilities
• Security policy
• Tax policy

These include our:

• Responsible marketing policy
• Responsible products and services policy
• Technology policy

For more information, take a look at our policies and statements.

Last updated: August 2024