Economic Crime Policy Statement
Nationwide is committed to tackling economic crime. We have a range of policies and programmes focused on preventing and minimising economic crime throughout all areas of our business and in our supply chain.
This area of our website offers information about some of the things we do as a responsible business. For more practical advice visit our fraud and security pages.
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Nationwide’s commitment to counter economic crime
At Nationwide, we have zero tolerance for the conducting or facilitating of money laundering, terrorist financing, contravention of sanction regimes, bribery and corruption, or fraud. Neither do we tolerate tax evasion, or the facilitation of tax evasion. We have policies in place to protect and reinforce these values, and we refresh these policies on a periodic basis. All policies apply to all colleagues (including the Board), customers, associated parties, third parties and any other business relationships.
Anti-money laundering and sanctions
A dedicated Money Laundering Reporting Officer (MLRO) is in place to ensure we meet our money laundering requirements. The MLRO helps us to understand and comply with regulations and individual responsibilities.
The MLRO has the responsibility for, and oversight of, Nationwide’s compliance with applicable economic crime rules and regulations. The MLRO reports to the Group Risk Officer (a member of the Nationwide Leadership Team). First line business areas are accountable and responsible in identifying and managing their own economic crime risks. They are required to provide regular management information of their local compliance programmes to the MLRO.
Anti-bribery and corruption
Bribery and corruption present a risk for organisations across the world, and a collaborative approach across governments, law enforcement agencies and businesses is taken to tackle the issue.
Nationwide is bound by the laws of the UK, including the Bribery Act 2010 which concerns conduct both at home and abroad. Our zero-tolerance approach to bribery is reinforced by the enforcement of effective systems and risk-based controls and procedures. These include a communication programme, mandatory annual staff training and awareness initiatives, a whistleblowing procedure, portal, helpline and app, and a regular review of the Anti-Bribery and Corruption policy and other related policies. This also extends to our supply chain.
Nationwide prohibits actions that can amount to bribery and corruption. This includes soliciting, accepting or receiving any benefit from any person as an incentive, favour or inducement for improperly performing a function or activity. We also prohibit the offering, promising, or giving any benefit, such as money, gifts, hospitality, or an advantage to another person as an incentive, favour or inducement for the improper performance of a function or activity. Or in the case of a public official, in order to use their influence in their office capacity to obtain or retain a business advantage.
Economic crime controls and procedures
We have a wide range of controls and procedures in order to minimise and prevent economic crime.
- Our compliance programmes define the responsibilities and accountabilities of our employees, including senior managers.
- We use risk assessments to establish Nationwide’s overall and first line business area risks and to proportionately mitigate specific exposure to economic crime.
- We engage in second and third-line testing of economic crime controls to ensure appropriate assurance of an effective programme.
- We ensure proportionate due diligence and screening is applied to Nationwide’s business relationships, including customers, third parties, associated parties, and its employees. This includes enhanced controls where the relationship is deemed of a higher risk, such as, but not limited to, higher risk countries or politically exposed persons.
- We have clear escalation mechanisms, including whistleblowing, where suspicions of economic crime are held and reported along with supporting investigations and corrective mechanisms.
- We have a clear definition of ‘conflict of interest’ and gifts and hospitality controls, to ensure that all business dealings are above board, transparent and that the appropriate approvals are obtained.
- We have an anti-corruption programme that covers bribery, including the prohibition of facilitation payments, which are payments made to expedite or speed up payments. The programme includes activities designed to prevent the facilitation of tax evasion.
Third parties controls and procedures
We monitor our business relationships to ensure that our suppliers have the equivalent of, or adhere to, Nationwide’s Anti-Economic Crime standards. This includes having policies and procedures in place, adequate training of their staff and a requirement to report any suspicion or knowledge of economic crime occurring including gifts and hospitality, bribery and corruption. We also provide accessible guidance to our third parties as appropriate.
It is important that our colleagues fully understand our business ethics and the behaviours we expect of them. Therefore training is conducted across the whole Society. We also offer bespoke training to employees or business areas exposed to higher or specific economic crime risks.
We have policies and mandatory annual training requirements to cover our legal and regulatory requirements on:
- bribery and corruption
- money laundering
- countering terrorist financing
- market abuse and insider dealing
- conduct risk, and
Many of our customer-facing colleagues also follow a ‘training by role’ schedule that helps them serve members in line with their roles and responsibilities.
Last updated: December 2021