Policies and principles that enable us to operate with integrity
Read about how our policies, procedures and regular training help us operate with integrity, maintain an effective defence against financial crime and protect society.
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.
What's on this page
Anti-money laundering and sanctions
We continue to develop our strategies and capabilities to prevent, deter and detect financial crime through ongoing enhancements to internal policies, procedures and systems.
A dedicated Money Laundering Reporting Officer (MLRO) is in place to ensure we meet our money laundering requirements and help us understand and comply with regulations and individual responsibilities. We also have a suite of robust policies that help ensure we mitigate risks to our members and the Society.
Our Code of Conduct
We have a suite of policies on our intranet that cover Code of Conduct. They inform and guide our people on some of the standards of conduct and behaviour we expect from them.
The highest risk areas from a member outcome, financial and regulatory perspective (such as Conflicts of Interest, Anti-Bribery and Corruption, which include Gifts and Hospitality, Data Protection, Information Security and Market Abuse) are subject to mandatory training, which is overseen by the policy owner and reported to risk committees as appropriate.
As part of the training, employees are required to approve a Personal Responsibilities Statement (or discuss with manager if they can’t approve) to confirm that they can abide by all the standards set out within the policies.
Our mandatory, annual e-learning courses also cover:
- Conduct Risk – making informed decisions and judgements to create fair outcomes for members. We want to do the right thing. And that should drive every decision, big or small, whatever our people’s roles and responsibilities.
- Conduct Rules – the regulatory regime that strengthens individual accountability in the financial services sector, and the rules that everyone must adhere to. The Conduct Rules influence our culture, standards and policies, and promote positive behaviours.
Also included within the suite of policies are the Communications and Privacy and Monitoring Policies which set out the expected standard of behaviours for our employees, temporary workers and contractors but are not subject to mandatory training.
Additionally, our specific Code of Conduct policy includes topics not covered by the policies set out above. These are:
- competition law
- arrests and convictions
- drug and alcohol problems
- personal relationships in the workplace
- personal use of ancillary services and equipment such as computers, telephones and postal services, and
- our commitment to provide a smoke-free working environment.
Our policy is also clear that we won’t tolerate modern slavery in any form – directly or through our suppliers.
Policies are agreed in conjunction with Nationwide Group Staff Union (NGSU), subject to periodic review and are supported by user guides to support implementation. We also consider tone of voice to ensure that they are effective in driving understanding and action.
These policies reinforce the importance we place on good conduct and on everyone’s personal responsibility for good conduct. The Financial Conduct Authority (FCA) has focused on ensuring financial services firms’ culture and conduct lead to fair outcomes every time. For us, this is more than a compliance issue, it is also about living up to our PRIDE values – putting our members first and doing the right thing, embracing not just the letter of the law but its spirit too.
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. Nationwide takes a zero-tolerance approach to bribery and enforces 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.
We have additional policies and mandatory annual training requirements to cover our legal and regulatory requirements on:
- bribery and corruption
- money laundering
- insider dealing
- conduct risk, and
Policies are also in place for our third-party relationships.
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.
Encouraging a culture of speaking up
We support, promote and encourage our colleagues to speak up whenever they witness or experience actual or potential wrongdoing or misconduct. Our permanent colleagues, temporary workers and third-party suppliers are encouraged to use various channels, both formal and informal, to raise things when they don’t seem right or don’t match our values.
Speak Up @ Nationwide (including our intranet site, helpline and annual e-learning) informs all colleagues, including temporary workers and contractors, about the many internal and external channels they can use to report concerns. We hope individuals will feel able to raise concerns early through the normal reporting channels so their concerns can be investigated, preventing small issues getting bigger. However, we understand that this is not always possible. For those who want to discuss their concerns in complete confidence or to raise their concerns anonymously they can do this through our whistleblowing process.
However, in the first instance we want people to be confident they can report issues to their manager, or any other senior employee. Alternatively, they can speak with the Case Management Team in the People and Culture team.
We use our annual employee survey, Viewpoint, to monitor how confident colleagues feel about speaking up. In order to ensure we understand and respond to any concerns in relation to speaking up, we invite colleagues to take part in open and honest discussions about what is preventing them from speaking their mind, and to explore what peers could do to better support their psychological safety. Senior colleagues and line managers are also asked to role-model effective listening practices.
Nationwide has arrangements in place to allow employees, contractors and temporary workers to raise concerns in confidence about possible misconduct, wrongdoing and/or behaviours towards others, including non-financial misconduct.
We do not treat concerns raised by third parties any differently to the concerns raised by our own employees. We ensure that this is communicated via our third-party Whistleblowing Policy which is available on our third-party supplier portal.
Whistleblowing process and investigations
Concerns can be raised through a variety of reporting channels which include a mobile phone app and online reporting form provided and managed by a third-party supplier, Expolink. While all concerns raised to the Nationwide Whistleblowing Team will be treated confidentially, reporters can raise their concerns anonymously if they so wish and no attempt will be made to try and identify them.
A dedicated whistleblowing team stays in touch with and supports those individuals who raise concerns. Additionally, we don’t tolerate instances where individuals are treated differently as a result of raising their concerns and we take such matters very seriously. We treat any act of retaliation as a disciplinary matter.
All concerns raised are investigated thoroughly, fairly and in accordance with our Whistleblowing Policy, Whistleblowing Procedures and the Society-wide Internal Investigation Guidelines.
All investigations follow a robust governance and decision-making process with senior leaders from across the business (Fraud, Information Security, Internal Audit, Distribution, Legal, and People and Culture) meeting regularly to agree and oversee the outcome of investigations. If we find evidence of wrongdoing, we consider further action, in accordance with HR principles and processes.
As required by Regulation, we have appointed a Whistleblowers’ Champion to oversee the entire whistleblowing process at Nationwide. We also provide the Board with an Annual report on the effectiveness of our whistleblowing processes and provide visibility of any thematics from the concerns we receive.
Whistleblowing colleague training
We provide annual, mandatory training for all staff and check regularly on progress. Additionally, all those that support the whistleblowing function at Nationwide are provided with annual investigator training too, which they must complete before embarking on or undertaking an investigation that has resulted from a whistleblowing concern being raised.
Additionally, the annual training also includes information on how employees can raise a whistleblowing concern directly with the Financial Conduct Authority or Prudential Regulation Authority, without first reporting internally. We also provide similar information on our intranet site and within the body of our policy documents.