Labour rights standard

Our labour rights standard is guided by the UN Guiding Principles for Business and Human Rights. This highlights the steps all states and organisations should take to foster respect for human rights.

Nationwide’s respect for human rights is aligned with these guiding principles, and those codified in international law through the International Bill of Human Rights, consisting 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)
• ILO Declaration on Fundamental Principles and Rights at Work (opens in a new window)

We are further guided in our approach by our Mutual Good Commitments and support for the UN Sustainable Development Goals. Our partnerships and affiliations also play a part in our approach.

This labour rights standard is intended to help colleagues understand the treatment and working practices they can expect working for Nationwide. This commitment should be felt and continually developed through our policies, processes and practices, as well as expressed and enhanced through targets and measures. As such, the standard should be used as a point of reference in due diligence processes designed to identify, assess, prevent and mitigate people risk, across the organisation.

Nationwide’s mutual purpose is implicit in its commitment to support and promote the labour rights of our workforce and value chain.

The Ten Principles of the UN Global Compact (opens in a new window) are intended to help organisations establish a culture of sustainability and integrity, by upholding their basic responsibilities to people and planet, and set the stage for long-term success. This includes labour commitments that are derived from the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work:

• The freedom of association and the effective recognition of the right to collective bargaining
• The elimination of all forms of forced and compulsory labour
• The effective abolition of child labour
• The elimination of discrimination in respect of employment and occupation
• A safe and healthy working environment

The ILO defines decent work as ‘productive work for women and men in conditions of freedom, equity, security and human dignity’¹. And covers²:

1. Employment opportunities
2. Adequate earnings and productive work
3. Decent working time
4. Combining work, family and personal life
5. Work that should be abolished
6. Stability and security of work
7. Equal opportunity and treatment in employment
8. Safe work environment
9. Social security
10. Social dialogue, employers’ and workers’ representation

Our commitment to providing decent work also ensures Nationwide’s support for the UN Sustainable Development Goals, and in particular, SDG 8: Decent Work and Economic Growth (opens in a new window). This goal seeks the creation of well-paid quality jobs for all, promoting labour rights and safe and secure working environments, while eradicating forced labour, human trafficking, and child labour.

Under the ILO Conventions, workers have the right to organise and for collective bargaining³. This right provides protection against anti-union discrimination and interference, enables collective agreements between workers and employees and provides protection at all stages of the employment relationship, from hiring to termination. By promoting freedom of association, the ILO seeks to prevent discrimination against trade union members and officials. We work closely with the Nationwide Group Staff Union (NGSU) to collaborate and consult on or negotiate the terms and conditions of Nationwide employment by means of our collective agreement.

Our freedom of association policy statement describes how we meet this commitment, including:

• The principles and conventions we follow
• The ability for employees to participate in collective bargaining
• Recognition of trade unions and our recognition agreement with the NGSU
• Encouragement of trade union activity and feedback
• Monitoring labour rights risks
• Managing disputes, grievances cases and investigations
• Supporting colleagues to take up public duties

Forced labour and child labour are universally condemned and yet many millions of people are still subjected to it. This occurs all over the world, including in the UK. The ILO estimates that more than 27 million people are currently victims of forced labour ⁴. And in the wake of the Covid-19 pandemic, the global progress against child labour has stalled, with millions of children put at risk ⁵.

Nationwide is committed to its role in helping eliminate this practice and we will never knowingly engage in any form of forced or compulsory labour, or child labour. We strictly adhere to UK employment regulation and conduct additional due diligence checks through our recruitment process.

Our Resourcing Policy prohibits recruitment fees, and states: ‘Nationwide recognises the risk of bondage arising from the use of recruitment fees and will never ask job applicants to pay recruitment costs, at any point in the recruitment process. Where migrant labour is used, recruitment suppliers and Nationwide should pay for all recruitment-related fees and costs (with the exception of personal visa costs), in line with the Institute of Human Rights and Business’ Employer Pays Principle (opens in a new window) and the International Labour Organisation’s definition on recruitment fees and costs (opens in a new window). We will, similarly, never partake in deliberate practices to underpay, delay, or withhold wages, enforce involuntary overtime, or withhold identity documents.’

Our modern slavery statement describes the activities and progress we make each year to help detect and deter incidences of modern slavery and human trafficking occurring through our operational activities and supply chain. The progress we make and activities that underpin them are reviewed by our Responsible Business Committee and overseen by the Executive Committee (Exco) and the Board.

Combatting discrimination at work is something we take seriously at Nationwide. Discrimination violates human rights and has social and economic consequences; it stifles opportunities, wastes talent, and accentuates social tensions and inequalities.

It is our policy to build an inclusive culture through the provision of equal access to training, career development and promotion opportunities. This is available to all colleagues regardless of their ethnicity, faith and belief, sexual orientation, marital status, age, physical or mental disability, or socio-economic background. Our discrimination policy statement expresses our intolerance for discrimination and commitment to providing equal opportunities.

We remain committed to building a supportive and inclusive environment for our workforce. And have a Mutual Good Commitment for the composition of our Society to reflect the diversity of the communities we serve. By promoting and measuring the diversity of our workforce, we are further reducing the opportunity for discrimination to emerge.

We track the composition of our workforce by gender, ethnicity, sexual orientation (LGBTQ+) and disability, and publish our progress in our Annual Report and Accounts. In 2022 Nationwide started to gather data on the socio-economic composition of our workforce, to help us benchmark against our peers and inform our future inclusion and diversity priorities.

Ensuring equal pay for work of equal value is a fundamental right. We are committed to building an inclusive working environment, where everyone is valued, rewarded fairly, and supported to reach their full potential. In addition to ensuring all our colleagues receive, at the very least, the ‘Real Living Wage’ (opens in a new window) our leaders are empowered and supported to make appropriate and inclusive salary decisions, guided by reward principles and guidance.

We also seek to reduce our gender and ethnicity pay gaps, publishing our progress annually. While there are imbalances in the distribution of women and ethnically diverse colleagues, we will have pay gaps, and so we regularly monitor pay to ensure our pay policies are not biased.

Our parental leave, flexible working packages and hybrid working policies help to ensure that our colleagues are not unfairly disadvantaged by a wide range of personal characteristics, family or caring circumstances, or lifestyle preferences.

Our Employee Network Groups (ENGs) are centred around:

• gender
• ethnicity
• sexual orientation
• disability
• social mobility
• faith and belief
• working carers
• working families
• veterans and reservists
• mental wellbeing
• sustainability

Our networks celebrate diversity and provide peer support to colleagues. They also act as a collective employee voice, working collaboratively with the business to help deliver our inclusion and diversity ambitions, including supportive policy changes. They provide a valued additional space to discuss, consult and, if appropriate, escalate ethical and work issues, and to help reinforce a fair, decent, and inclusive working environment.

Decent work includes having a safe and secure working environment. The ILO Constitution states that workers must be protected from sickness, disease and injury arising from their employment⁶. As a UK-centric organisation, our working environment is well controlled by UK health and safety regulations.

However, the risks our colleagues may be exposed to are different depending on whether they operate from our branches or administration centres. We closely monitor all risks and issues, responding to them wherever they might occur. Our health and safety policy, measures and controls, colleague training and robust governance, further reinforce this responsibility.

We actively engage with our workers, employee representatives, and relevant stakeholders to ensure their voices are heard and to identify any potential labour rights issues. We encourage open dialogue and provide channels for reporting grievances.

We use several tools to engage colleagues and their legitimate representatives on issues relating to labour rights, working practices and wellbeing at work. This includes scheduled performance and review meetings, and engagement through employee surveys network groups and a framework of formal regular meetings with the NGSU and their elected representatives.

We provide several ways for our colleagues to ‘speak up’ at Nationwide, including, but not limited to, our whistleblowing process. We work with several external bodies as independent and expert input and enable peer discussion on best practice on a variety of environment, social and governance (ESG) matters. We use insight from these sources, and other inclusion, diversity and wellbeing reporting and external audits, to understand how well we are doing, and where to focus our efforts. We also address individual issues related to labour rights as they might emerge to meet the needs of each case.

We continually develop, evolve, and apply our policies and processes to support decent work for our colleagues, and ensuring Nationwide is doing all it can to prevent risk, discrimination, exclusion, or bias.

To ensure we fully understand the potential or actual impacts of risks on people, we assess labour rights through our people risk processes in relation to specific characteristics, circumstances, and vulnerability drivers. This enables us to identify who may be affected, and to document and report the relevant risks and issues, along with the proposed activity to mitigate the risk or remediate the issue.

While people risks have always been understood on a localised level across the organisation, we have recently started reviewing people risk more holistically. This ensures the most salient of risks can be given significant strategic focus.

It is important that our suppliers represent the Society and demonstrate a commitment to our policies and standards

Nationwide’s Third Party Code of Practice defines our expectations to respect the values and human rights of their employees, to never use child, forced, or involuntary labour, and to ensure working hours are within local regulations and industry practices. Their employees must be free to join worker organisations and must be provided with clear disciplinary and grievance procedures.

At onboarding, and at intervals during our relationship, all prospective and existing suppliers are asked to agree to comply with our Third Party Code of Practice. This sets out expectations for environmental and social standards. Where they do not currently meet our standards, we request they close these gaps as a condition of doing business with us on an ongoing basis. Where a prospective supplier is unwilling to meet the standards stipulated in our code, we will not conduct business with them unless assessed as justifiable mitigating circumstances, by the Chief Procurement Officer.

Nationwide has partnered with EcoVadis to rate our third party suppliers’ sustainability performance, including their approach to human and labour rights. Ecovadis methodology is aligned with United Nations Global Compact (UNGC) principles, allowing us to assess supplier compliance with international labour rights standards and benchmarks. Third parties are asked to complete the assessment on an annual basis. If their overall score does not meet the minimum threshold that would suggest they are engaged in sustainability, Nationwide requires a corrective action plan and improvement within 12 months. EcoVadis also provides a news monitoring service that can impact the company’s rating.

It is important that we not only have ongoing assurance that our suppliers are operating to a standard that they agreed at onboarding, but that we have a comprehensive understanding of the risks to people through the wider value chain. This includes understanding the risks by industry, geography and of our suppliers’ suppliers. This is a complex process, and one that we are still exploring and mapping.

Our Procurement for Mutual Good programme embeds social considerations into our procurement policies and processes. It also helps us to build a greener, more inclusive and more ethical supply chain. To further promote social and environmental protection through our purchasing decisions, colleagues who make these decisions are asked to undertake our Responsible Purchasing Training.

We have established robust monitoring mechanisms to assess our compliance with labour rights standards. This includes regular audits and assessments conducted by both internal teams and external third-party experts.

Nationwide’s adherence to our policies and statements is reported on through our online HR systems failure demand reporting and if necessary subsequent investigations. The reporting enables us to assess employee issues relating to the policies and identifies areas for improvement so that we can mitigate and prevent repeat issues.

Our policy suite and related practices are reviewed on an annual basis. Monthly risk reports and proposed mitigations are presented at the Risk Executive Committee by the Chief People Officer. This outlines potential and emerging risks to our workforce and actions to respond to them.

We believe in transparent reporting of labour rights performance. We disclose relevant information regarding our efforts, progress, and challenges in meeting labour rights commitments through our sustainability report or dedicated platforms (such as the UNGC).

Our assurance practices include the following.

Independent audits: We engage independent third-party auditors to conduct regular audits of our operations, assessing our compliance with labour rights standards. These audits provide an unbiased evaluation of our practices and help identify areas for improvement.

Supply chain assessments: We extend our assurance efforts to our supply chain by conducting assessments and audits of our suppliers. This helps us to ensure labour rights standards are upheld across our entire value chain.

Internal monitoring and reporting: We have established internal monitoring systems to regularly assess our adherence to labour rights standards. This includes periodic internal audits, inspections and performance reviews conducted by dedicated teams within our organisation.

Stakeholder engagement: We actively engage with workers, employee representatives and relevant stakeholders to gather feedback, address concerns and ensure labour rights are being respected. This engagement helps us to identify any gaps or potential areas for improvement.

Continuous improvement mechanisms: We have established mechanisms to track and analyse people risks related to labour rights. This enables us to measure progress, set targets and implement continuous improvement plans to address any identified shortcomings.

Transparency and reporting: We believe in transparently reporting our labour rights practices and performance. We regularly disclose relevant information, including our assurance activities in sustainability reports and other public communications.

These robust assurance measures demonstrate our commitment to labour right standards and our determination to uphold them across our operations and supply chains. By implementing these practices, we aim to create a work environment that respects and promotes the rights and well-being of all workers involved in our organisation.

This labour rights standard applies to all Nationwide colleagues, temporary workers, and contractors, and forms part of a suite of policies and standards. We consult NGSU, the recognised trade union, on all of our policies and statements some of which are listed below.

In addition, we consult with relevant internal and external stakeholders and charitable organisations, that provide best practice guidance on human rights issues (e.g: family friendly, wellbeing, domestic violence, sexual orientation). We belong to specific Financial Services network groups for the purpose of continuous improvement to our regulatory policies and standards.

On conclusion of our consultation, our policies are jointly issued with NGSU and approved by Exco members at the most senior level of the organisation and applied to all of our operations. Where applicable Nationwide mandates the completion of online learning and training to support the implementation of these policies and standards.

• Policies and statements
• Becoming a Parent Policy
• Code of Conduct Policy
• Communications Policy
• Contractual Terms Policy
• Control of Substances Hazardous to Health (COSHH) Policy
• Data Protection Policy
• Disciplinary Policy
• Environmental and social conduct
• Expenses Policy
• Fair Treatment at Work Policy, which covers
  • Improving performance
  • Probation
  • Disciplinary
  • Ill health capability
• Harassment and bullying
• Financial Support and Benefits Policy
• Flexible Working Policy
• Further Education Policy
• Human rights standard
• Hybrid and Homeworking Policy
• Ill Health Capability Policy
• Inclusion and Diversity Policy (includes discrimination)
• Healthcare Protection Benefits Policy
• Job Security and Redundancy Policy
• Freedom of association and collective bargaining – includes Recognition and Procedure Agreement with NGSU
• On Call Policy
• Overtime and Additional Hours Policy
• Pensions Policy
• Privacy and Monitoring Policy
• Probation Policy
• Resolution Framework
• Resourcing Policy
• Reward Policy
• Secondment Policy
• Shift Working Policy
• Sickness Absence Policy
• Time Off Policy
• Transgender Policy
• Wellbeing Policy
• Whistleblowing Policy

Last updated June 2023