Our code of conduct

Alongside our policies, and behavioural and compliance standards, our code of conduct ensures we operate ethically and sustainably. Together they demonstrate our commitment to respect the rights, dignity and wellbeing of our members, colleagues, supply chain and communities.

As a responsible business, our high labour standards and duty to protect the environment are key principles of our code. Our sustainable governance structure helps to ensure integrity, accountability and inclusivity. It leaves no tolerance for corruption in the way we work.

Mandatory training and responsibility statement

All colleagues are requested to undertake annual, mandatory training courses across several topics. These topics are those that have potential for high risk, or where there is a regulatory requirement. They include:

  • 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 also required to approve a Personal Responsibilities Statement. This statement confirms 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, diversity and discrimination. And there are related risk committees on hand to support where appropriate.

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

Conduct risk : making informed decisions and judgements to create good outcomes for members. We want to do the right thing.

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. 

We also offer courses on climate change risk. Completing this training is widely encouraged, and 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.

Helping our colleagues to thrive

Our policies and standards set out expectations around behaviours and the way we conduct ourselves.

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 groups help to embed and promote them.

Our policies that support colleagues include:

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

Expected behaviour standards

Our policies set out the expected standard of behaviours for our employees, and our temporary workers and contractors where appropriate. We also have a supplier policy suite which promotes the values and behaviours expected of our supply chain.

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

About our policies

Policies are agreed in conjunction 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 member outcomes every time. But this is more than a compliance issue for us. It’s an integral part of all that we do. And it’s about living up to our PRIDE values – putting our members first and doing the right thing.

Last updated: February 2023