About our code of conduct
Our code of conduct is covered by policies on our internal intranet site. The policies inform and guide our people on the standards of conduct and behaviour we expect from them so that we operate with integrity.
What's on this page
Mandatory training and responsibility statement
The areas that pose a potential high risk to members and us financially, and that we must comply with, are topics covered as part of our mandatory training and reported on to risk committees. These areas include:
- conflicts of interest
- anti-bribery and corruption
- gifts and hospitality
- data protection
- information security
- market abuse
Colleagues are required to approve a Personal Responsibilities Statement, or discuss why they can’t approve it with their manager. This statement confirms they abide by all the standards set out within the policies.
Our mandatory, annual e-learning courses also cover conduct risk and rules as specific topics.
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.
Expected behaviour standards
The Communications and Privacy and Monitoring Policies set out the expected standard of behaviours for our employees, temporary workers and contractors to follow.
Our Code of Conduct policy includes topics not covered by these policies. These topics 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
- our commitment to provide a smoke-free working environment.
About our policies
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 maintaining it. 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.
All policies are overseen by the policy owner and reported to risk committees as appropriate.
Last updated: April 2022