Freedom of association policy statement

Nationwide is guided by its own internal values as well as 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 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.

We have a collective bargaining arrangement with the Nationwide Group Staff Union (NGSU). NGSU is an independent union affiliated to the Trade Union Congress (TUC).

NGSU has negotiation rights over various matters and we consult with them and provide information on a wide variety of aspects of employee engagement. We considers our relationship with the Union so important that 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

Union membership is high; 60% of our permanent employees belong to NGSU, which makes up 89% of its members.

We encourage our staff to join NGSU. And all Nationwide employees can practice Freedom of Association, i.e., a right to associate with any group they wish, including joining or leaving the group. Any group recognised by Nationwide can take collective action on behalf of its individual members.

We comply with UK Trade Union legislation relating to recognition. Our relationship with NGSU is underpinned by a Recognition Agreement. This is a commitment to work in partnership, recognising the union’s right to represent its members, and Nationwide’s duty to manage the business effectively. The recognition agreement covers all of our UK employees, as well as all operating divisions of Nationwide Building Society. Employee engagement is owned by the Chief People Officer in our Leadership Team and the agreement is jointly signed by the Chief Executive Officer and NGSU General Secretary.

The Recognition Agreement is available to all employees on our intranet and outlines 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)

It also outlines our internal and external dispute mechanisms.

NGSU attends Nationwide’s Health and Safety forum and provides feedback from members on all aspects of work-place 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 union representatives to regularly meet with accountable management and raise issues.

We openly communicate the right to join a union on our intranet, providing direct links from our main page to NGSU’s details and website. We publish summaries of all our formal recognised union meetings on the Society’s Employee Involvement intranet site, where we also provide a link to the union’s website and all joint statements announcing employee policy changes. We also provide NGSU contact details when the Society has an obligation to consult with employees. We publicise NGSU’s biennial conference to all employees, allow access to the live stream, provide speakers and input for the conference content. In 2022 Nationwide welcomed NGSU’s decision to create a Green Advisory Group to support us making further sustainability improvements and suggestions relating to Corporate Social Responsibility issues.

NGSU are provided with space in our buildings and are allowed to recruit members at employee induction. Employees have the right to freedom of assembly and are provided with paid time off so union representatives can attend to union duties. We also allow all 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 union representatives with their activities we provide several E-learning courses to enable them to develop relevant skills. Our Recognition Agreement guarantees 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. These are emailed to employees and included in our weekly news update. The joint statement provides links to NGSU’s own communications, newsletters and videos where applicable.

We operate internal processes to assess risk for Labour Rights and Decent Work related to our own operations and other business relationships. The People Risk Policy sets out our approach to managing Employment Practices 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 other legal requirements as applicable to the Society.

The objectives of this policy are to:

• Support the management of Employment Practices Risks across Nationwide in accordance with the Society’s 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, how the Society manages its 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 for Nationwide operate within the risk appetite set by the Nationwide Board which requires us to:

• Maintain minimal risk of major, severe or critical member 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

We conduct an internal annual review of our union relationship and associated controls, focused on the effective operation of our Recognition Agreement with NGSU. Our Chief People Officer provides updates on our union relationship to the Executive Committee.

The NGSU have direct informal discussions with the Society’s Non-Executive Directors on at least every 6 months and every year have a formal meeting with the Nationwide Board and Executive Committee to discuss employee issues.

Nationwide’s Recognition Agreement with NGSU outlines our agreed internal and external dispute resolution approach if both parties fail to agree on specific items. We’ve a jointly agreed Fair Treatment at Work approach outlined in the Recognition Agreement and in 2022 we introduced a Dispute Resolution approach to improve resolution of employee grievances. These policies and approaches are published and promoted on our internal intranet and are in our contract of employment. The Society meets with trade union officers monthly to discuss concerns relating to individual cases and to listen to feedback on related processes.

Nationwide has a comprehensive speak up and whistleblowing helpline and online reporting system. These are managed by an external independent third party to enable anonymous reporting of incidents and concerns. And 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 people time off to:

• Act as a union representative for NGSU
• Be an elected member of a local authority
• Perform duties for a political party
• Take roles such as a justice of the peace
• Be a member of a statutory tribunal
• Be a prison visitor
• Be a member of an education or health body.

Last updated June 2023