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 commitment to 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 when working for Nationwide. This commitment is managed through our policies, processes, practices and related 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.

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 the environment. 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 dignity¹ 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

Nationwide’s commitment to the UN Sustainable Development Goals (SDGs), and in particular, SDG 8: Decent Work and Economic Growth (opens in a new window), supports 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 participate in collective bargaining³. By promoting freedom of association, the ILO seeks to prevent discrimination against trade union members and officials. We recognise the importance of colleague representation and believe having access to, and being represented by, a trade union is an important aspect of employee voice. We work closely with the Nationwide Group Staff Union (NGSU) and Unite the Union to collaborate and consult on, or negotiate terms and conditions of, employment, by means of our collective agreements. This ensures our colleagues are represented and treated fairly.

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 agreements with the NGSU and Unite the Union
• Encouragement of trade union activity and feedback
• Monitoring labour rights risks
• Managing disputes, grievances cases and investigations
• Supporting colleagues to take up public duties

Nationwide is committed to its role in helping eliminate forced and child labour and we will never knowingly engage in any form of forced or compulsory labour, or child labour. All our policies are informed by UK employment regulation and we conduct additional due diligence checks through our recruitment process.

Our resourcing policies prohibit recruitment fees being charged to workers. We recognise the risk of debt 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 our own Nationwide / Virgin Money businesses will 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.

Combatting discrimination at work is something we take seriously at Nationwide. We do not tolerate prejudice, discrimination or harassment in any form.

We are committed to building an inclusive working environment, where everyone is valued, rewarded fairly, and supported to reach their full potential. Our Mutual Good Commitment to better reflect the diversity of the communities we serve further supports our ambitions and reduces the opportunity for discrimination to emerge.

We create this inclusive and supportive culture for our workforce through the provision of equal access to training, career development and promotion opportunities. Our Nationwide sub-group discrimination policy statement and Virgin Money Code of Conduct - PDF, 7.5MB (opens in a new window) express our intolerance for discrimination and commitment to providing equal opportunities.

We are committed to paying the ‘Real Living Wage’ (opens in a new window) for all our employees who we hire directly, which includes apprentices, temporary workers, and contractors, going further than the Government’s National Living Wage. We review our pay levels annually, informed by external market movements and changes in Living Wage.

We also seek to reduce our gender and ethnicity pay gaps (Nationwide gender and ethnicity pay gaps; and Virgin Money gender pay gap - PDF, 7.5MB (opens in a new window)), publishing our progress annually.

Our family friendly, flexible working, time off and hybrid working policies help to ensure that our colleagues are not unfairly disadvantaged, regardless of personal characteristics, family or caring circumstances, or lifestyle preferences.

Our Employee Network Groups bring together colleagues, including those who share similar characteristics or life experiences and who want to connect with others, as well as welcoming allies. They help us learn from lived experiences, fostering a supportive community and promoting belonging and inclusion. Our networks act as a collective employee voice, working collaboratively with the business to help deliver initiatives that support our ambition of being an inclusive employer, including supporting 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 employment⁴. As a UK-centric organisation, our working environment is controlled by UK health and safety regulations. We are committed to providing a positive and proactive working environment that fully supports the health, wellbeing and safety of our employees, customers and third parties alike. We have appropriate management controls in place to mitigate risks and investigate and respond to any occurrences . Our health and safety policies (Nationwide’s health and safety policy and Virgin Money's health and safety statement - PDF, 146KB (opens in a new window)), measures and controls, colleague training and robust governance, further reinforce this responsibility.

We actively engage with our colleagues, 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 channels 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, employee network groups and a framework of formal regular meetings with the NGSU and Unite the Union and their elected representatives.

We provide several ways for our colleagues to speak up whenever they witness or experience actual or potential misconduct, wrongdoing, or unacceptable behaviour, and we want them to feel confident to do so without fear of retaliation. We have arrangements in place for employees, contractors, and temporary workers across the Group to raise concerns, as outlined in our Nationwide Whistleblowing Policy Statement and Virgin Money Whistleblowing Policy Statement - PDF, 197KB (opens in a new window). This includes being able to raise concerns confidentially or anonymously (if preferred) via whistleblowing channels, including online portals hosted by independent third parties.

We continually develop, evolve, and apply our policies and processes to support “decent work” for our colleagues across the Group, and ensure we are doing all we 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.

It is important to us that our suppliers reflect our values and ambitions. Our Third Party Codes of Practice (Nationwide Third Party Code of Practice - PDF 324KB (opens in a new window) and Virgin Money Supplier Code of Conduct - PDF, 1.2MB (opens in a new window)) outline the environmental and social standards we expect our suppliers to uphold, beyond applicable legal requirements, which includes our expectations around ethical working practices, including anti-modern slavery practices, and respecting the values and human rights of their workers. This includes, but is not limited to, prohibiting the use of child, forced, or involuntary labour, and to respect labour rights including those relating to discrimination and whistleblowing. Within our Nationwide sub-group, we also encourage third-party suppliers to pay the real Living Wage through our Third Party Code of Practice, our tender questions, and our standard contractual terms.

During our onboarding process, new suppliers are requested to confirm compliance with the Codes. Within the Nationwide sub-group, we tier expectations based on the size of the third-party organisation.

In addition, our Nationwide sub-group conducts evidence-based controls testing on a prioritised set of third parties to check compliance with the Third Party Code of Practice, and to request action where gaps are identified. Factors such as the criticality of service and ESG risk are considered in the selection of third parties tested. Where gaps are identified, action is requested, and outcomes are tracked.

We continually monitor and manage third-party supplier sustainability performance. Our Nationwide sub-group works with EcoVadis, an international sustainability ratings provider, to help us monitor third-party supplier sustainability performance across environment, labour, human rights, ethics, and sustainable procurement activities. We plan to identify which Virgin Money suppliers we will onboard onto the same platform. The EcoVadis methodology is built on international sustainability standards, including the United Nations Global Compact (UNGC) principles, allowing us to assess supplier compliance with international labour rights standards. We have set a minimum benchmark sustainability rating for suppliers. Where a third party scores below this, we ask that corrective action is taken ahead of their next annual assessment.

We have processes to monitor and manage working conditions with our trade unions and with Executive Committee members, including our Group Chief People Officer, who has internal responsibility for labour rights. These processes provide a route for escalating significant labour rights issues and contain provisions for external mediation should it be required to resolve an issue or dispute.

We review our policy suite and related practices that protect labour rights annually. Workforce-related risks are reported to the Executive Risk Committees of the Nationwide sub-group and Virgin Money sub-group.

We believe in transparent reporting of labour rights performance. We disclose relevant information through our environmental, social and governance disclosures, pay gap reporting (Nationwide gender and ethnicity pay gaps; and Virgin Money gender pay gap (opens in a new window)), and dedicated platforms (such as the UNGC).

Our assurance practices include the following:

Supply chain assessments: We extend our assurance efforts to our supply chain, with our Nationwide sub-group conducting evidence-based controls testing of third-party compliance with the Third Party Code of Practice PDF, 324KB (opens in a new window), against a prioritised set of third parties. At our Nationwide sub-group, enhanced monitoring, such as audits, is also conducted within certain higher risk areas of our supply chain. This helps us to uphold labour rights standards across our value chain.

Internal monitoring and reporting: We use these mechanisms to regularly assess our adherence to labour rights standards.

Stakeholder engagement: We regularly engage with colleagues, 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.

Transparency and external reporting: We believe in transparently reporting our labour rights practices and performance. We regularly disclose relevant information, for example as part of our pay gap reporting and in our environmental, social and governance disclosures.

These 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 wellbeing of all colleagues involved in our organisation.

This labour rights standard applies to all colleagues across the Group, and forms part of a suite of policies and standards. We consult with the Nationwide Group Staff Union (NGSU) and Unite the Union on our policies and statements. More on our policies and statements can be found on our Nationwide website and Virgin Money website (opens in a new window), as well as in our environmental, social and governance disclosures.

In addition, we consult with relevant internal and external stakeholders and charitable organisations, that provide best practice guidance on human rights issues (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 trade unions and approved by Executive Committee members at the most senior level of the organisation. Where applicable, Nationwide mandates the completion of online learning and training to support the implementation of these policies and standards.

Last updated August 2025