Our code of conduct

Our code of conduct, policy suite, behavioural and compliance standards ensure we operate ethically and with integrity. Together they demonstrate our commitment to respect the rights, dignity and wellbeing of our customers, colleagues, supply chain and communities.

As a responsible business, our high labour standards form key principles of our code. Governance structures across our organisation help to ensure integrity, accountability and inclusivity with no tolerance for corruption in the way we work.

Mandatory training and responsibility statement

All colleagues are required to undertake annual, mandatory training courses across several topics including:

  • anti-bribery and corruption
  • conflicts of interest
  • data protection
  • financial crime (including modern slavery)
  • gifts and hospitality
  • health and safety
  • information security
  • market abuse
  • protecting member card data
  • speaking up and whistleblowing

Colleagues are required to approve Personal Responsibilities Statements. These statements confirm they will abide by all the standards set out within our Society policies.

A separate people risk policy supports the management and mitigation of risks relating to employee relations and diversity and discrimination. Our risk committees are on hand to support where appropriate.

Our e-learning courses also cover conduct risk and rules as specific topics.

Conduct risk : how our conduct as a financial institution can pose a risk to our members or customers.

Conduct rules: the minimum standards of individual behaviour 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. 

We also offer courses on climate change risk. Completing this training is widely encouraged, and it has been well received by our colleagues. Similarly, training on ethical procurement and modern slavery in our supply chains is given high priority for specific roles.

Exceptions exist in relation to Statement of Work Contractors, Non-Executive Directors and Pension Trustees, who are not required to complete annual mandatory training courses. These populations receive tailored training, as appropriate to their roles.

Colleague policies and standards

Our HR policies and standards set out expectations around behaviours and the way we conduct ourselves for our employees and, where appropriate, our temporary workers and contractors.

We're proud to have a high percentage of Union membership among our colleagues. And our approach to quality, inclusivity and fairness for all is a major focus. Our policies protect these interests, and our employee network group help to embed and promote them.

These policies include:

  • becoming a parent – covering
    • maternity and paternity leave
    • adoption
    • surrogacy
    • fostering
    • fertility treatment
    • premature births, and other aspects of support
  • disciplinary
  • domestic abuse
  • fair treatment at work
  • flexible working
  • further education
  • healthcare and protection benefits
  • hybrid working
  • inclusion and diversity
  • job security and redundancy
  • overtime and additional hours allowances
  • performance and absence
  • probation
  • reward
  • resolution framework (includes harassment and bullying)
  • sickness absence
  • time off
  • wellbeing
  • whistleblowing

Our code of conduct policy includes topics not covered by these policies. These topics are:

  • arrests and convictions
  • colleague sponsorship and collections
  • competition law
  • confidentiality
  • dress
  • drug and alcohol problems
  • hospitality and social functions
  • anti-slavery guidance
  • personal finance and money management
  • personal relationships in the workplace
  • personal use of ancillary services and equipment such as computers, telephones and postal services
  • smoke-free working environment

Supplier behaviour standards

We have a supplier policy suite that promotes the values and behaviours expected of our supply chain.

About our policies

HR policies are subject to consultation and, where necessary, negotiation with the Nationwide Group Staff Union (NGSU). They’re subject to periodic review and have user guides to support implementation. Our policies are each overseen by a policy owner. And we consider tone of voice to ensure that they’re effective in driving understanding and action across the business.

These policies reinforce the importance we place on good conduct and on everyone’s personal responsibility for maintaining it. The Financial Conduct Authority (FCA) is focused on ensuring financial services firms’ culture and conduct lead to good customer outcomes every time. But this is more than a compliance issue for us. It’s an integral part of all that we do.

Last updated: May 2024