Responsible products and services policy statement

We have a set of policies, tools and processes in place that help us to build products and services that are inclusive and meet the needs of our customers. A key part of this is the requirement to follow a set path of governance when we design each product or service, and ongoing monitoring. This gives us opportunities to make informed decisions about some important points, such as:

Critical to our design process is the need to ensure that any product or service offers a fair exchange for our customers’ money in pursuit of their financial objectives, as well as whether the features and benefits are easy-to-use for the people for whom they’re intended. We also consider whether customers have reasonable alternatives across the rest of the financial market and make efforts to ensure we do not disproportionately impact particular groups of customers, such as those with characteristics of vulnerability. Guidance documents exist to ensure the risk of this happening is thoroughly tested and controlled.

We are dedicated to ensuring vulnerability remains a priority consideration at all points when thinking about our products and services. Customer vulnerability, accessibility and inclusion requirements are enshrined throughout our internal policies and standards to make sure we have considered the different skills, capabilities and needs of our customers. These requirements are considered when designing or changing products or services to make sure we don’t disadvantage any customers, and that any reasonable adjustments to the design and operation of the product or service have been explored and implemented.

Our Terms and Conditions Monitoring Standard sets out how terms and conditions should be written – to make sure they are clear and fair in explaining key information, and any risks that could be associated with the product or service. It is important that our customers can understand their options and make informed decisions on whether our contracts are right for them. Approval of these Terms and Conditions is managed through our Communications Policy, which ensures the right experts are approving these documents for clarity, balance, legislative and regulatory purposes. We monitor those terms for any changes that need to be made, measure whether they are being adhered to by our customers, consider the potential harm this may cause, and take appropriate action.

Guidance is available to make sure our people consider many different factors as they explore how to price products fairly. This includes the detailed requirements we need to meet, and activities we need to undertake to ensure we are providing appropriate value to customers, and adequately assessing our products. Considerations such as the cost of the product or service itself, what other banks or building societies are offering, and whether there are any offers or discounts that might be appropriate. These decisions are approved by our Pricing Committee, which is attended by senior leaders from across our business to ensure our products continue to represent fair value for our customers.

We put the customer at the heart of everything we do to minimise and avoid possible harm to them. This is a key consideration in our design process to ensure our products and services do not cause harm to our customers in pursuit of their financial objectives. To help us understand the impact of such harms occurring, we have created a harms taxonomy that is in line with FCA’s Consumer Duty requirements. This allows us to regularly monitor harms that may occur and report them to accountable individuals, forums, and committees, and take appropriate actions, where we see harms may be occurring.

Nationwide has a climate change risk standard which aids the identifying, assessing, monitoring and managing, and reporting of climate-related risk as a cause to the Society’s principal risks. The climate change risk standard articulates the principles and requirements that must be met to manage the risks arising from climate change, and how climate-related risk may occur across our Enterprise Risk Management Framework. To help understand the risks associated with climate change, including greenwashing, when designing new products and services, we factor climate change considerations into our Product and Service Approval Process alongside potential liability and conduct risks.

Embedded in our processes is the need to consider the financial and political landscape as a whole. Our product and service approval process, including fair value assessments, ask our subject matter experts to consider impact of external factors like economic changes, political policy and changes to interest rates on customers and good outcomes. To make sure we remain responsible and fair, we actively prohibit anti-competitive behaviours, such as the creation of monopolies, or anything that could negatively impact the integrity of the financial market. Our Market Abuse Policy and mandatory training further reinforce our commitment to this.

We regularly test and review each of our products and services, including risk assessments that make sure we identify, understand and manage any risks that might inhibit offering fair value, that might cause customer harm, or might create an obstacle to providing good customer outcomes.

Approval routes for our products and services are documented and take the form of reviews by accountable individuals, forums or committees attended by experts from across the business. Together, they must approve or endorse decisions.

We have documented sales journeys and distribution (sales) strategies which consider our target audience and market, and how well our sales channels meet customer needs. We also have processes in place that clearly outline our commitment to responsible marketing. This is backed by a Communications Policy and a responsible marketing policy, which outlines what, when and how we should share information with our customers, and our responsible selling practices, which includes:

All our customer-facing colleagues receive mandatory, formal training to make sure they have the right skills and knowledge to support our customers. Colleagues in regulated advice roles, such as Mortgage Advisors, are also equipped with the necessary role-specific qualifications. This level of skill is maintained with ongoing continuing professional development relative to individual roles, and quality checking of a risk-based percentage of all processes to make sure they’re being followed correctly.

We prohibit any schemes that could encourage poor selling practices. This includes targets or rewards linked to individual sales performances. All eligible colleagues are enrolled in the same discretionary reward scheme. The outcome of this scheme depends on the business as a whole meeting certain financial, risk and customer satisfaction measures.

We make every effort to ensure customers receive the right product by providing all the information they need and that it is clear, understandable, fair and not misleading. The information must also be in an appropriate format, provided in a timely way to allow customers to make informed decisions on the products and services that are right for them, and supports the pursuit of their financial objectives.

We want to make processes as easy as possible for our customers and we do this by ensuring our sales journeys provide transparency, alongside systems that include checkpoints to ensure key information is reviewed before a customer can take out a product.

By featuring our products on external comparison websites, customers can assess our products against a range of options. We also provide inhouse tools and guidance services to help guide customer choice. In the event a customer doesn’t qualify for their desired product or service, we tell them why. We also provide customer-focused educational tools, such as online calculators and customer talkback sessions.

It’s important that we provide different ways for our customers to understand and choose from our products and services, and that we accommodate a wide range of accessibility needs and preferences without unnecessary barriers. Understanding the impact of not offering a product or services across all channels, at the point of design, ensures we are well positioned to take reasonable steps to remedy this. This is a key consideration as part of our distribution and servicing strategies. We continue to monitor this throughout the product lifecycle and make changes wherever necessary.

Our servicing journeys and processes are well-document and clearly outline our commitment to responsible servicing, including ensuring customers are not presented with unreasonable barriers. This is backed by our Product Lifecycle Policy, which outlines what, when and how we should share information with our customers, which communication channels we use, and responsible servicing practices. The information we share is always reviewed and approved by subject matter experts to ensure they are accurate and understandable. This is backed by our responsible marketing statements, and Communications Risk Policy. Doing the right thing for our customers is deeply engrained within our culture, and is heavily reinforced in numerous ways, including:

Customer satisfaction is at the heart of what we do. We aim to deliver brilliant service and have adopted a set of service principles that ensure we deliver more for our customers, more of the time. We also measure and report how satisfied our customers are with their interactions with us through all stages of their journey. We have a range of tools to understand whether our customers are receiving good outcomes and their overall levels of satisfaction with our interactions. We also work with external independent bodies to compare our performance against others in the industry.

We understand that circumstances can change, and that anyone can experience financial worries. When this happens, we are committed to making it easy for our customers to get the information and the support they need. We will work with them to understand their circumstances and explore the options and solutions available based on their individual circumstances. Where appropriate, we will signpost or make a referral for free money advice, or other support. We also have a dedicated Specialist Support Team who help customers who are or have become vulnerable and need additional support in managing their finances, by taking positive steps to prevent them getting into further financial difficulties. For example, we have a data-driven definition to help us monitor gambling usage and assist us in better preventing gambling-related harm.

We take our responsibility to manage customer complaints seriously and aim to do so in a way that is fair, delivers a good outcome and is in line with what customers expect from us, not just what regulation dictates. If unfair customer outcomes arise, or expectations haven’t been met, a set of processes, systems and guidelines are in place. Fully trained employees log, investigate and respond to all complaints. We’re committed to clear and timely customer communication, to help fix problems, ensure outcomes are understood, and that any appropriate remediation or compensation is received.

We pride ourselves on getting it right for our customers, first time. But occasionally there are times when we need to put things right. That's what remediation is all about, and we always aim to put customers back in the position they would have been in had the issue not occurred. Our Remediation framework sets out the requirements we need to meet to ensure we remediate customers fairly and consistently when conducting remediation activity, wherever this happens for customers. We also have a dedicated team, the Remediation Centre of Excellence, which consists of specialists working together to apply our remediation principles and processes, enabling us to scope, design and deliver remediation projects repeatedly – meaning we can fix problems faster and keep our customers happier.

Our main policy guiding the design, sale and service of our products and services is the Product Lifecycle Policy, owned by two of our Executive Committee members. It is overseen and approved by internal committees, that are attended by senior leaders (including Board members) and experienced professionals from across the business. We also engage with external stakeholders and initiatives to share best practice, expertise and ways of improving the financial services industry as a whole.

Last updated: February 2025