Freedom of association policy statement

Nationwide is guided by principles such as the International Labour Organisation (ILO) Core Conventions and those set out in the UN Global Compact. We comply with relevant applicable law and regulation, including the UK Modern Slavery Act 2015 and we publish an annual modern slavery and human trafficking statement.

We’re also committed to operating in accordance with the International Bill of Human Rights. This comprises of the Universal Declaration of Human Rights (UDHR), the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights.

Nationwide is committed to the principles of UN Global Compact (opens in a new window) including principles 3-6 in relation to labour:

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

Principle 4: the elimination of all forms of forced and compulsory labour;

Principle 5: the effective abolition of child labour; and

Principle 6: the elimination of discrimination in respect of employment and occupation.

Nationwide has collective bargaining arrangements with the Nationwide Group Staff Union (NGSU) and Unite the Union . Both unions are affiliated to the Trade Union Congress (TUC) and the Scottish Trade Union Congress (STUC).

NGSU and Unite the Union have negotiation rights over various matters, and we consult with them and provide information on a wide variety of aspects of employee engagement. We openly share information, including:

• Employee engagement feedback
• Career development programmes
• Equal pay and inclusion and diversity data (including gender, age, and ethnicity)
• Changes to all employee policies including Health and Safety

We actively encourage trade union membership and all employees can practise freedom of association, i.e. a right to join, leave or associate with any trade union or workplace representation group they wish. We do not discriminate against employees for trade union activity / membership. Any trade union recognised by Nationwide can take collective action on behalf of its individual members. In our Nationwide sub-group, 60% of employees are members of the recognised trade union NGSU.

We comply with UK trade union legislation relating to recognition. Recognition agreements underpin our relationships with NGSU for Nationwide sub-group and Unite the Union for Virgin Money sub-group. The agreements outline our intention to work effectively and collectively with the trade unions to jointly resolve issues, and we recognise their right to represent their members, and our duty to manage the business effectively. Our collective bargaining unit covers 99% of our permanent employees, and all operating divisions of Nationwide Building Society. Employee engagement is owned by the Group Chief People Officer in our Leadership Team. The agreements are jointly signed by the Group Chief People Officer or the Group Chief Executive Officer and the most senior union representatives. The recognition agreements are available to all employees on our intranet and outline the items covered by collective bargaining. These include:

• Pay
• Overtime and unsociable hours payments
• Working hours
• Holiday and time off (including parental leave and time off for political parties and voluntary groups)
• Our internal and external dispute mechanisms.

Trade union representatives attend our Health and Safety forums and provide feedback from members on all aspects of workplace safety and wellbeing. This includes stress management and verbal and aggressive behaviour by members of the public. The agreement outlines our commitment to open dialogue through local Business Committees, that allow trade union representatives to regularly meet with accountable management and raise issues.

We openly communicate the right to join a trade union on our intranet, providing direct links from our main page to NGSU and Unite the Union’s websites. In our Nationwide sub-group, we publish summaries of all our formal recognised union meetings on the Employee Involvement intranet site and all joint statements announcing employee policy changes. We publicise NGSU’s biennial conference to all employees and provide speakers and input for the conference content. Nationwide engages with the NGSU Green Advisory Group to support sustainability improvements and develop suggestions relating to Corporate Social Responsibility issues.

NGSU and Unite the Union are provided with space in our buildings and are allowed to recruit members at employee induction. We provide trade union contact details when there is an obligation to consult with employees. Employees have the right to freedom of assembly and representatives are provided with paid time off to perform trade union duties. We also allow all trade union employees free access to all our sites, as well as provision of dedicated private space, and access to our core IT systems and intranet. To support trade union representatives with their activities we provide e-learning courses to enable them to develop relevant skills. Our recognition agreements guarantee that elected officers and representatives may carry out their duties, without loss of basic salary, allowances and other benefits.

We notify employees of changes to terms and conditions via a joint statement or policy update agreed with NGSU and Unite the Union. These are emailed to employees and included in our weekly news updates. The communications provide links to NGSU’s and Unite the Union’s own communications, where applicable.

We operate internal processes to assess risk for Labour Rights and Decent Work related to our own operations and other business relationships. In our Nationwide sub-group, the People Risk Policy sets out our approach to managing employment risks in line with all relevant employment legislation and regulatory requirements. We operate a comprehensive Risk Management Framework through which risks are identified and managed according to an assessment of severity.

The approach to identifying, assessing, monitoring, mitigating and reporting on individual risks is implemented through a suite of policies supported by procedures and standards. These have been designed to ensure they align to our risk appetite and ongoing compliance with regulatory and legal requirements.

The objectives of this policy are to:

• Support the management of employment practices risks across Nationwide sub-group in accordance with our Risk Management Framework and risk appetite
• Outline the key controls in operation to manage associated risk which may impact the Society
• Document, at a high level, the approach to managing our exposure to employment practices risks
• Assign ownership and accountability for the maintenance and approval of this policy

This policy and the policy statements are designed to ensure that employment practices risks operate within the risk appetite set by the Nationwide Board which requires us to:

• Maintain minimal risk of major, severe or critical customer and reputational impact
• Operate within a moderate or minor level of risk to maintain an efficient and dynamic business with appropriate mitigations and action plans in place to manage the Society’s risk exposure
• Ensure that appropriate and adequate people controls are in place, effective to mitigate people related risks and are regularly tested
• Not tolerate any forms of bullying, harassment or discrimination and will provide and maintain an inclusive environment for each employee
• Comply with applicable employment legislation and will not tolerate breaches of legislation or regulation or breaches to Human Rights

In our Nationwide sub-group, we conduct an internal annual review of our trade union relationship and associated controls, focused on the effective operation of our recognition agreement with NGSU. Our Group Chief People Officer provides updates on our union relationship to the Executive Committee. NGSU have direct informal discussions with the Society’s appointed Non-Executive Director and meet annually with the Nationwide Board and Executive Committee to discuss employee issues.

The recognition agreements with NGSU and Unite the Union outline our agreed internal and external dispute resolution approach if parties fail to agree on specific items. In the Nationwide sub-group, we jointly agree and review our Fair Treatment at Work approach outlined in the recognition agreement and we operate a Dispute Resolution approach to improve resolution of employee grievances. In our Virgin Money sub-group, specified policies and procedures are agreed with Unite the Union. These are published and promoted on our internal intranet sites and are referenced in our contracts of employment. Management representatives meet with trade union officers monthly to discuss concerns relating to individual cases and to listen to feedback on related processes.

Nationwide has comprehensive speak up processes, whistleblowing helplines and online reporting systems. These are managed by external independent third parties to enable anonymous reporting of incidents and concerns. All employees are required to complete annual e-learning to enable them to understand how to raise issues in a confidential manner.

In some sensitive internal employee grievances and whistleblowing cases, external advisors have been appointed so that an investigation of any allegations can be completed independently.

We encourage all our colleagues to get involved with public duties in the community. This includes giving time off or flexibility to:

• Be an elected member of a local authority
• Perform duties for a political party
• Take roles such as a justice of the peace or magistrate
• Be a member of a jury or statutory tribunal
• Be a member of an education or health body.

Last updated August 2025