Human rights standard

Nationwide’s scale, mutual model, and strong reputation puts us in a unique position in UK financial services. It enables us to prioritise customer experience and value, while having a positive impact on society and growing our business to bring the benefits of mutuality to more people across the UK.

Our strategy is centred around our purpose: ‘Banking – but fairer, more rewarding, and for the good of society.’ This articulates our ambition to make a positive difference for our members and customers, our communities and wider society.

We also seek to be a good employer. Our purpose and mutual values inform how we respect, uphold and promote universally accepted labour rights across our operations and value chain.

Our approach to supporting human rights is informed by the UNGPs Reporting Framework, which provides a structured methodology for identifying, prioritising and reporting on our salient human rights risks – those with the greatest potential to cause harm to people if not effectively managed.

Our respect for human rights is grounded in internationally recognised standards, including the International Bill of Human Rights. These frameworks guide how we uphold labour rights, promote decent work and support safe, fair and inclusive treatment across our operations and value chain, and consists of the:

• Universal Declaration of Human Rights (opens in a new window)
• International Covenant on Civil and Political Rights (opens in a new window)
• International Covenant on Economic, Social and Cultural Rights (opens in a new window)
• International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work (opens in a new window)

As a signatory to the UN Global Compact and the United Nations Environment Programme Finance Initiative (UNEP FI) Principles for Responsible Banking, our business practices reinforce our commitment to the UN Sustainable Development Goals (SDGs). Our Mutual Good Commitments also demonstrate how our business aligns to, and supports, the UN SDGs.

We conduct an annual saliency assessment with stakeholders across the business, to identify and prioritise human rights risks across our customers, colleagues and suppliers. As part of this assessment, we evaluate each potential impact based on its severity and its likelihood, to determine which risks require the greatest focus, and take steps to reduce or prevent potential negative impacts. More information on our Mutual Good Commitments, and our identified salient human rights risks, are outlined in our Environmental, Social and Governance Disclosures.

We remain committed to a net-zero future. We recognise that climate change continues to present a risk to us and our customers, and it is our aspiration to support the UK in achieving its ambition to be net-zero by 2050. We believe in supporting a just transition – ensuring that the most vulnerable in society are not disadvantaged, as we transition to a net-zero economy.

Our expectations relating to ethical working practices extend to the business partners we work with. Our Third Party Code of Practice outlines the environmental and social standards we expect our suppliers to uphold, beyond applicable legal requirements.

In accordance with the Modern Slavery Act 2015, we publish our annual Modern slavery and human trafficking statement, outlining the steps we take to mitigate and manage the risk of slavery or human trafficking taking place across our operations and supply chain.

We work to identify, assess and reduce harms that may affect people, either directly through our own operations or indirectly through the products and services we provide, our customer relationships, and our supply chain. We recognise that these risks can arise across our business and may affect customers, colleagues, suppliers and wider communities.

To support this, we maintain a suite of controls, policies and practices that help embed responsible behaviour across our business. These include our human rights and labour rights standards, economic crime controls, speaking up and whistleblowing arrangements, supplier policies and due diligence processes. Together, these measures help us prevent, detect and respond to risks including exploitation, unsafe or unfair working conditions, financial abuse and broader human rights harms.

The steps we take to support customers, colleagues and suppliers, and to strengthen our approach over time, are described in our Environmental, Social and Governance Disclosures. Further information is also available in our policies and statements and Modern slavery and human trafficking statement.

Nationwide exists for its customers and members, providing financial products and services for them. We recognise that access to fair, accessible and inclusive financial services can support people’s rights to dignity, security, equality and inclusion. We also recognise our responsibility to reduce barriers and address risks that may prevent people from accessing these rights in practice.

Our approach is guided by applicable law and regulation, including the Financial Conduct Authority’s (FCA’s) Consumer Duty and the FCA’s Guidance on the Fair Treatment of Vulnerable Customers. We are committed to delivering good outcomes for all customers, including those in vulnerable circumstances, and to ensuring that customers are treated with fairness, care and respect. We have measures, processes and specialist teams in place to help us recognise, understand and respond to a wide range of customer needs, including those arising from vulnerability, disability, financial hardship, communication barriers or other life circumstances.

We aim to make it as easy as possible for customers to access and use our services in the way that works best for them. This includes providing choice in how customers bank with us, whether through digital channels, by phone or through our branch network, underpinned by our Branch Promise. We work to make these channels accessible and inclusive, including for customers with disabilities and those who may need additional support, and we continue to develop initiatives that help remove barriers to access and participation.

We value customer feedback as an important part of respecting customers’ rights and improving outcomes. We promote an open and responsive approach to feedback and complaints, and customers can share their views through a range of channels, including our business operating channels and customer experience surveys. We use these insights to help improve our products, services and the support we provide, with the aim of strengthening customer experience and delivering fairer, more inclusive outcomes over time.

Further information on how we support customers, including our approach to accessibility, inclusion and vulnerability, is set out in our Environmental, Social and Governance Disclosures.

Nationwide is committed to supporting customers’ financial wellbeing and helping them build long-term financial resilience. We recognise that financial security and access to a safe, secure and good-quality home are important foundations. As a financial services provider, we can help uphold these rights by working to reduce harm, remove barriers to inclusion, and support fair access to financial products and services.

We seek to protect and promote these rights through the way we design our products and services, support customers in vulnerable circumstances, and engage on the wider issues that affect financial resilience and housing access. We work to:

• support good savings habits and build confidence in managing money
• improve access to safe, quality housing through our products and propositions, our lending to the social housing sector, and our engagement with regulators and policymakers
• protect customers from economic crime, scams and financial exploitation
• understand and respond to the needs of customers in vulnerable circumstances, including those experiencing financial difficulty, and provide specialist support where needed.

We recognise that barriers to financial security and housing are often experienced most acutely by those in vulnerable circumstances. We therefore take a proactive and inclusive approach, seeking to ensure that our services are accessible, that support is available through the channels customers use, and that our approach reflects the diverse needs of the people we serve. Further information is set out in our Environmental, Social and Governance Disclosures and our Modern slavery and human trafficking statement.

Nationwide is committed to protecting customers from crime, and to preventing our products and services from being used to facilitate economic crime or exploitation.

We maintain a robust framework of controls, policies, standards and procedures designed to prevent, detect and respond to economic crime across our business, operations and relevant third-party relationships. This framework is supported by regular review, colleague training, specialist expertise and engagement with external partners, helping us to respond to evolving threats and strengthening our approach over time. We focus on:

• helping ensure customers can bank and transact safely, including through measures to detect and prevent fraud, scams, financial exploitation and abuse
• maintaining policies, procedures and training that support colleagues to operate with integrity and to identify, escalate and respond to risks of economic crime, including modern slavery, financial abuse and other forms of exploitation
• protecting customers’ money, accounts and personal data through appropriate security, monitoring and safeguarding controls
• identifying and responding to heightened risks faced by customers in vulnerable circumstances, who may be more exposed to coercion, abuse or exploitation
• working to ensure our services are not used to facilitate criminal activity, including through customer due diligence, transaction monitoring and wider economic crime controls
• providing clear and accessible routes for raising concerns, so that customers and colleagues can report issues and seek support when harm is suspected.

We also recognise the importance of partnerships in addressing these harms. We work with regulators, law enforcement, industry bodies and specialist organisations to strengthen our understanding of emerging risks, improve detection and support effective safeguarding and disruption where concerns arise.

Further information on the measures we have in place is set out in our economic crime policy statement and Environmental, Social and Governance Disclosures.

Nationwide is committed to detecting, deterring and preventing modern slavery and human trafficking across our business operations, customer relationships and supply chain.

Our anti-slavery approach has three focus areas:

• Raise awareness – helping colleagues, suppliers and other partners understand the risks, indicators and reporting routes associated with modern slavery and human trafficking
• Detect and disrupt – using controls, intelligence, due diligence and partnerships to identify, prevent and respond to exploitation
• Support victim-survivors – helping to safeguard vulnerable individuals and reduce barriers to financial safety, inclusion and recovery.

We mitigate and manage modern slavery risks through a range of controls, standards and due diligence processes across our business and value chain. These include:

• maintaining economic crime controls, customer due diligence and transaction monitoring to identify behaviours and patterns linked to human trafficking and modern slavery, and reporting suspicious activity to the National Crime Agency where required
• supporting customers in vulnerable circumstances, recognising that coercion, financial abuse, housing insecurity, limited identification documents and other vulnerabilities can increase the risk of exploitation
• providing inclusive and accessible banking options, including access to basic bank accounts and proportionate identification processes, to support financial independence and reduce financial exclusion
• promoting responsible recruitment and decent work, including pre-employment checks for colleagues and contingent workers, adherence to the Employer Pays Principle, and prohibiting recruitment fees to help prevent debt bondage
• maintaining labour standards that support fair and decent work, including our commitment to paying the real Living Wage to all colleagues we hire directly, and encouraging suppliers to do the same
• providing clear reporting and whistleblowing routes so that colleagues, contingent workers and suppliers can raise concerns confidentially and anonymously
• undertaking supply chain due diligence and ongoing monitoring, including through our supplier onboarding and contracting processes, risk assessments, controls testing and sustainability assessments
• working with external partners, charities, industry groups and law enforcement to strengthen our understanding of emerging risks, improve detection and support collective action.

We recognise that modern slavery risks can arise in different parts of our value chain, including through customer exploitation, colleague vulnerability, third-party labour practices and deeper-tier supply chains where visibility is more limited. We seek to take a continuously improving approach, strengthening awareness, oversight and response mechanisms. Our Modern Slavery Act Statement sets out the steps we are taking to identify, mitigate and manage the risk of modern slavery and human trafficking across our business and supply chain.

We believe all colleagues should be treated with dignity, fairness and respect, and work in an environment that is safe, inclusive and free from harassment, bullying and unlawful discrimination. We are committed to respecting and promoting the human rights of all colleagues, and to embedding fair and responsible employment practices that support decent work, wellbeing, inclusion and opportunity.

We support colleagues’ rights through a range of controls, policies and practices, including:

• embedding fair and responsible employment practices through our people policies, which reflect relevant legal requirements, international labour principles and good practice
• building an inclusive culture in which colleagues feel valued, can be themselves at work, and are supported to thrive and develop rewarding careers
• supporting colleagues’ physical, mental, emotional, social and financial wellbeing through a range of resources, benefits and specialist support, including for those experiencing domestic abuse, financial abuse or other vulnerable life circumstances
• providing a safe and healthy working environment, underpinned by clear health and safety standards and a zero-tolerance approach to bullying, harassment, victimisation and discrimination
• supporting fair working hours and work life balance through flexible working and family friendly leave, while providing fair remuneration and equal pay for equal work - including our commitment to pay the real Living Wage to all directly-employed colleagues
• carrying out regular pay monitoring and periodic equal pay audits to assess whether our policies and practices are operating fairly and without bias, and publishing our gender and ethnicity pay gap data
• complying with relevant legal requirements in relation to younger workers, including where colleagues are under the age of 18
• protecting colleagues’ personal data in line with applicable data protection legislation and internal controls
• respecting colleagues’ rights to freedom of association and collective bargaining, and working constructively with our recognised staff unions.

Our Labour Rights Standard provides further detail on how we protect and promote labour rights. More information on our approach to supporting colleagues, including our wellbeing, inclusion and employment practices, is also available in our Environmental, Social and Governance Disclosures. Our Code of Conduct and Business Ethics further supports this framework by setting out the standards of behaviour and integrity we expect across our business.

We provide regular opportunities for colleagues to share their views and experiences, including through colleague culture and engagement surveys, listening events with senior leaders, employee network groups and engagement with staff unions. These channels help us understand colleagues’ experiences, identify emerging issues and respond in a timely and effective way to colleague needs. They also support continuous improvement in our people policies, practices and wider working environment.

We are committed to creating a culture in which colleagues feel able and encouraged to speak up if they witness or experience actual or potential misconduct, wrongdoing or unacceptable behaviour. We want colleagues to feel confident raising concerns without fear of retaliation, victimisation or adverse treatment. Our Speaking Up and Whistleblowing Policy sets out the arrangements in place for employees, contractors and temporary workers to raise concerns safely and confidentially, and, where preferred, anonymously.

Colleagues can raise concerns through a range of whistleblowing channels, including an online portal hosted by an independent third party, as well as other reporting routes designed to be accessible and supportive. We promote awareness of these channels through training, communications and supporting resources, so colleagues understand how to raise concerns and the protections available to them. Our staff unions also play an important role in supporting colleagues who may need advice or reassurance when speaking up.

Nationwide has a zero-tolerance approach to bullying, harassment, victimisation and unlawful discrimination of any kind. We are committed to ensuring that concerns are listened to, handled appropriately and used to strengthen our culture, controls and ways of working.

Our remediation framework sets out the requirements we need to meet to ensure we remediate individuals fairly and consistently. We have a dedicated team, which consists of specialists working together to apply our remediation principles and processes, enabling us to scope, design and deliver remediation projects repeatedly.

We also encourage suppliers and third parties to raise concerns through the mechanisms set out in our supplier policies, and we expect suppliers to provide access to appropriate grievance and reporting routes for their workers.

We build colleague awareness of human rights through mandatory learning, targeted communications and role-specific guidance. All colleagues complete annual training on key topics such as speaking up and whistleblowing, customer vulnerability, anti-bullying and harassment, and economic crime, helping them to recognise risks, act responsibly and raise concerns where issues arise. We supplement this with additional awareness activity throughout the year, including internal communications, practical guidance and targeted resources for colleagues in higher-risk roles, to help embed respect for human rights across our business and culture.

We are guided by a social purpose and aim to have a positive and meaningful impact for our customers, communities and society as a whole. We therefore seek to use our capability, scale and influence to contribute to fairer outcomes and to help address some of the systemic issues that affect the communities we serve.

We commit at least 1% of our pre-tax profits each year to charitable activities, alongside wider initiatives that support our purpose. We also recognise the important role our branches play in supporting local communities and maintaining access to face-to-face banking and support. Our Branch Promise helps maintain access to essential financial services, particularly for customers who may be digitally excluded, prefer in-person support, or need help in sensitive or complex circumstances.

Our Fairer Futures partnerships also help us provide more targeted support where it is most needed. For example, through our partnership with Dementia UK, we host bookable dementia clinic appointments with Admiral Nurses in selected branches, offering free specialist support and advice to people affected by dementia. We also provide Safe Spaces in many of our branches, giving anyone experiencing domestic abuse or exploitation access to a private place where they can seek support discreetly and safely. These initiatives reflect our broader commitment to supporting people in vulnerable circumstances and reducing barriers to safety, independence and inclusion.

We also have a Colleague Grants programme, enabling colleagues who actively support a charity through volunteering or fundraising to apply for a grant to support the local causes they care about most.

Further information on how we support our communities, including through our partnerships and social impact activity are set out in our Environment, Social and Governance Disclosures.

As a mutual, we recognise that environmental issues can have important implications for people’s rights, wellbeing and resilience. Climate change and environmental degradation can disproportionately affect those who are already vulnerable, including through impacts on homes, health, livelihoods and the cost of living. We support a just transition to a net-zero economy, recognising the importance of ensuring that the transition is fair and inclusive and does not disadvantage those who are least able to adapt.

Our Climate-related Financial Disclosures sets out our understanding of the impacts of climate change on Nationwide, our customers and the wider communities we serve, alongside the potential impacts of our activities on climate change. They explain how climate-related risks and opportunities are governed, identified, assessed and managed across the business, and outline the metrics and targets we use to monitor progress and support accountability.

As a mutual, our asset base is fundamentally different from that of a bank and is closely linked to our purpose of supporting customers, members and communities. The majority of our assets comprise residential mortgages, including lending that supports home ownership, social housing and buy to let properties. We recognise that our financing decisions can have direct and indirect impacts on people’s rights and wellbeing. We therefore seek to apply a responsible approach to lending and investment, taking account of relevant financial, environmental, social and governance risks within our policies, controls and decision-making processes.

Our treasury investment portfolio is held primarily for liquidity purposes and consists mainly of cash and low-risk investments. We do not invest in corporate bonds or equities. Nationwide Treasury aims to hold at least £2 billion of environmental, social and governance (ESG) assets, including bonds issued by multilateral development banks and green, social and sustainable labelled bonds. These investments can support wider environmental and social outcomes, including economic and social development in lower-income countries and progress towards the UN SDGs.

Our approach reflects our broader commitment to acting responsibly, understanding where harms may arise, and using our financing activities in a way that supports fairer and more sustainable outcomes. Further detail is available in our Responsible Investment Statement.

Across our mortgage lending, we recognise the importance of housing quality, safety and vulnerability. Our lending to the social housing sector helps expand access to safe and secure homes, while our buy to let standards and due diligence processes enable us to assess and manage risks linked to housing conditions and potential exploitation.

We have policies and controls in place that aim to mitigate the risk that we might, through our business relationships, become indirectly linked to modern slavery and broader human rights risks. We aim to maintain a responsible and ethical approach to supporting our business customers. Our sensitive sector statement sets out the sectors and activities where ESG risks, including those linked to labour exploitation, are unacceptably high, and where we have limited or no lending appetite. We apply enhanced controls for sectors with heightened ESG risk, reflecting our commitment to operating responsibly. ESG considerations, including human rights and modern slavery, are embedded proportionately into our credit assessment and ongoing monitoring processes.

Our lending appetite is focused on businesses operating predominantly in the UK, where regulatory frameworks reduce (but do not remove) the risk of labour exploitation. Businesses with activities overseas require additional scrutiny, and certain high-risk sectors are restricted or prohibited. Ongoing anti-money laundering and Know Your Customer processes help identify potential links to economic crime, which can be associated with modern slavery.

We recognise that our third-party suppliers play an important role in the management of our business and in helping us provide products and services to our customers. We also recognise that human rights risks, including forced labour, child labour and other forms of exploitation, can arise within global supply chains. We are committed to working with our suppliers to strengthen transparency, uphold decent work standards and mitigate human rights risks across our supply chain.

Our Third Party Code of Practice (the Code) sets out the environmental and social standards we expect suppliers to uphold, beyond applicable legal requirements. This includes expectations relating to ethical working practices, including those set out in the Ethical Trading Initiative Base Code.

We have controls in place across the key stages of our supplier relationships, from onboarding and contracting through to ongoing monitoring and engagement. Our onboarding due diligence includes reviewing supplier responses to questions on ethical working practices and modern slavery risks, and our standard agreements set out expectations relating to ethical trading and anti modern slavery commitments.

We also monitor supplier sustainability performance on an ongoing basis. This includes screening relevant suppliers for adverse media, conducting controls testing against the Code, and engaging suppliers where concerns or gaps are identified. Where remedial actions are needed, we work with suppliers to support improvement and follow up on progress, escalating issues where appropriate.

Our approach is supported by external assessment tools. We use EcoVadis to help monitor and assess supplier sustainability performance, including indicators relating to human rights, labour standards, modern slavery and sustainable procurement. We prioritise suppliers presenting greater ESG risk and use these assessments, alongside our own annual risk assessment processes, to help identify areas requiring closer attention, corrective action or additional engagement.

We recognise the importance of supplier voice in maintaining responsible and ethical supply chain relationships. We encourage suppliers to raise concerns through the mechanisms set out in our supplier policies, and we expect relevant suppliers to provide access to confidential and, where appropriate, anonymous reporting channels for their workers.

More information on how we responsibly and ethically select, onboard and manage third parties, including our supply chain due diligence and ongoing monitoring processes, is available in our Modern Slavery Act Statement.

Our Group Responsible Business Committee is the executive-level committee accountable for overseeing our responsible business agenda and sustainability-related matters, including those related to human rights. We use research, policies, risk assessments, and other strategies and initiatives to support and protect the rights and dignity of our customers, colleagues, third parties and communities. More information on our ESG governance can be found in our Environmental, Social and Governance Disclosures.

Our Human Rights Standard is supported by policies and processes that help us to identify, prevent and address potential human rights risks. Our policies are subject to periodic review and are overseen by designated policy owners. We review them to reflect changes in legal and regulatory requirements, evolving good practice, internal learning and emerging risks. Supporting processes such as colleague training, risk assessments, customer and supplier due diligence, monitoring, escalation routes and assurance mechanisms help embed these policies in practice.

We also recognise the importance of stakeholder input in shaping effective policies and processes. Relevant policies and approaches are informed by colleague feedback, engagement with staff unions, specialist teams, external partners and wider stakeholder insight, helping us to strengthen how we protect and respect human rights over time. Further information can be found on our policies and statements page on our website, and in our Environmental, Social and Governance Disclosures.

Last updated: July 2026