Speaking up and whistleblowing
We support, promote and encourage our colleagues to speak up whenever they witness or experience actual or potential wrongdoing or misconduct. Our colleagues, and suppliers are encouraged to use formal and informal channels, to raise concerns when they have experienced something that doesn't seem right or doesn’t match our values.
Encouraging a culture of speaking up
Speak Up @ Nationwide (including our intranet site, helpline and annual e-learning) informs all colleagues, including temporary workers and contractors, about the internal and external channels they can use to report concerns. We hope individuals raise concerns early through the normal reporting channels so they can be investigated, preventing issues getting bigger. However, we understand that this is not always possible. For those who want to discuss their concerns confidentially or raise them anonymously, they can do this through our whistleblowing process.
In the first instance we want people to feel confident to report issues to their manager, or any other senior employee. Alternatively, they can speak with the Case Management Team within People and Culture.
We use our annual employee survey, Viewpoint, to monitor how confident colleagues feel about speaking up. 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.
Whistleblowing policy statement
We have arrangements in place to allow employees, contractors and temporary workers to raise concerns in confidence about possible misconduct, wrongdoing and behaviours towards others, including non-financial misconduct.
We treat concerns raised by third parties in the same way. We ensure they are aware of the process by sharing our third-party whistleblowing policy with them through the supplier portal.
Whistleblowing process and investigations
Concerns can be raised through a variety of reporting channels which include a Progressive Web App (PWA), using a QR code and an online reporting form provided and managed by a third-party supplier, Navex. Whilst 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 Society-wide Internal Investigation Guidelines.
All investigations follow a robust governance and decision-making process with senior leaders from across the business (Economic Crime, Information Security, Internal Audit, Distribution, Legal, and People and Culture). These leaders make up a board that 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. Phil Rivett, Non-Executive Director and Chair of the Audit Committee, has responsibility for ensuring and overseeing the integrity, independence and effectiveness of Nationwide’s policies and procedures relating to whistleblowing. This includes those intended to protect whistleblowers from being victimised or treated differently for having disclosed reportable concerns.
Our board recognises that having effective and trusted confidential whistleblowing arrangements is key in supporting the Society’s open and honest culture. We provide the board with an annual report on the effectiveness of our whistleblowing arrangements and processes and provide visibility of any themes from the concerns we receive. In addition, the Board has reviewed the adequacy and effectiveness of the arrangements in place for the proportionate and independent investigation of concerns raised, including any required follow-up action taken.
Whistleblowing colleague training
We provide annual, mandatory training for all staff and check regularly on progress. All those that support the whistleblowing function at Nationwide are provided with annual investigator training as well. They must complete it before starting an investigation.
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.
Last updated: November 2022