Labour rights standard

Our labour rights standard is guided by the UN Guiding Principles for Business and Human Rights, which highlights the steps businesses should take to respect, protect and remedy human rights.

Nationwide’s commitment to human rights is aligned with these principles, and those codified in international law through the International Bill of Human Rights, consisting of the: 

• Universal Declaration of Human Rights
• International Covenant on Civil and Political Rights
• International Covenant on Economic, Social and Cultural Rights
• ILO Declaration on Fundamental Principles and Rights at Work

Our approach is further guided by our Mutual Good Commitments, our support for the UN Sustainable Development Goals, and the partnerships and affiliations that strengthen our understanding of labour rights and responsible business practices.

This Labour Rights Standard sets out the treatment, protections and working practices colleagues can expect when working for Nationwide. It is supported by our policies, processes, practices and related measures, which guide how we uphold labour rights across the organisation. The Standard serves as a point of reference in due diligence processes designed to identify, assess and embed labour rights across the organisation.

The Ten Principles of the UN Global Compact  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 supports the creation of well-paid quality jobs, promoting labour rights and safe and secure working environments, while contributing to the eradication of 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 our employee unions 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 helping eliminate forced and child labour. We will never knowingly engage in, support, or benefit from, any form of forced or compulsory labour, or child labour. All our policies are informed by UK employment regulation and international labour standards.

We require that all newly-hired employees and contingent workers complete background vetting checks before joining us, confirming their identity, personal information and work history, to help highlight any warning signs, including those that might indicate modern slavery. All verbal and written offers of employment or engagement, along with confirmation of start dates, are contingent upon candidates providing all required permissions, information, and documentary evidence.

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 business 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 and the International Labour Organisation’s definition on recruitment fees and costs. We will, similarly, never partake in deliberate practices to underpay, delay, or withhold wages, enforce involuntary overtime, or withhold identity documents.

Permanent hiring is usually managed through our strategic recruitment partner. All employees of our recruitment partner undergo annual compliance training designed to prevent human trafficking, forced labour and modern slavery. Where contingent resource is required across the organisation, only approved third-party recruitment suppliers may be used, and we expect the same high standards and principles as we do when recruiting new colleagues.

Our modern slavery statement sets out the activities and progress we make each year to help detect, deter and prevent modern slavery and human trafficking across our operations and supply chain.

Combatting discrimination at work is a priority at Nationwide. We do not tolerate prejudice, discrimination or harassment in any form.

Our Mutual Good Commitment is dedicated to building an inclusive working environment, that better reflects the diversity of the communities that we serve and represent. It enables our colleagues to thrive and reach their full potential.

We are committed to removing barriers to inclusion and progression, growing talent through data-led action, and enabling everyone to benefit from career development opportunities. Our discrimination policy statement expresses our intolerance for discrimination and commitment to providing equal opportunities

As an accredited Living Wage Employer, we are committed to paying the real Living Wage 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 salary ranges annually, informed by external market movements and changes in living wage.

We also encourage Nationwide’s third-party suppliers to pay the real Living Wage through our Third Party Code of Practice and our standard contractual terms. 

We are committed to reviewing our gender and ethnicity pay gaps and publish our progress annually (Nationwide gender and ethnicity pay gaps and Virgin Money Gender Pay Gap Report).

Our Life, Work & Time Off and Inclusion, Wellbeing & Support policies help ensure colleagues are not unfairly disadvantaged, regardless of personal, family or caring circumstances, or lifestyle preferences.

Our employee networks play an important role in helping colleagues connect, learn, and shape an inclusive culture. They bring together colleagues, who share similar characteristics or life experiences, as well as welcoming allies or those who want to connect with others. They share learnings from lived experiences, fostering a supportive community. 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 governed by UK health and safety regulation, and we are committed to providing a positive, proactive and safe 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 policy statement, 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 use a confidential reporting mechanism for reporting concerns or grievances.

We use a range of mechanisms to engage colleagues and their legitimate representatives on matters relating to labour rights, working practices and wellbeing. This includes scheduled performance and review meetings, employee surveys, employee network groups and a framework of formal regular meetings with our Unions 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. Employees, contractors, and temporary workers can raise concerns in line with our Whistleblowing Policy Statement. Concerns can be raised confidentially or anonymously through whistleblowing channels, including online portals hosted by independent third parties. We operate a zero‑tolerance approach to any form of victimisation or adverse treatment of those who raise genuine concerns.

We continually develop, evolve, and apply our policies and processes to support “decent work” for our colleagues, and ensure we are doing all we can to prevent risk, discrimination, exclusion, or bias.

We operate internal processes and maintain policies to identify, assess, monitor, mitigate and report on people related and health and safety risks our operations. This is underpinned by our Group Risk Management Framework, which ensures risks are managed in line with their severity and likelihood.

We also consider human rights impacts to colleagues through our human rights due diligence process, ensuring that labour related risks are considered alongside broader human rights risks across our operations.

It is important to us that our suppliers reflect our values and ambitions. Our Third Party Codes of Practice outlines the environmental and social standards we expect our suppliers to uphold, beyond applicable legal requirements. This includes our expectations around ethical working practices, anti-modern slavery practices, and respect for the values and human rights of their workers. These standards prohibit the use of child, forced, or involuntary labour, and require respect for labour rights including those relating to non-discrimination and whistleblowing. 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 our Third Party Code of Practice. We tier expectations based on the size of the third-party organisation.

We conduct 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, corrective actions are requested, and outcomes are tracked. These activities help us to uphold labour rights standards across our value chain.

We continually monitor and manage third-party supplier sustainability performance. We work 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. The EcoVadis methodology is built on international sustainability standards, including the UN 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 in place to monitor and manage working conditions through engagement with our recognised trade unions and Executive Committee oversight, including by our Group Chief People Officer, who has internal responsibility for labour rights. These processes provide a clear route for escalating labour rights concerns and include provisions for external mediation, where required, to help resolve issues or disputes.

Annually, we review our policy suite and related practices that protect labour rights annually. Workforce-related risks are reported to the Group Executive Risk Committee.

We believe in transparent reporting of labour rights performance. We disclose relevant information through our Environmental, Social and Governance (ESG) Disclosures, pay gap reporting and dedicated platforms (such as the UNGC).

Our assurance practices help us monitor, evaluate and strengthen how labour rights are upheld across our operations and supply chain. 

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

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. 

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.

This labour rights standard applies to all colleagues, and forms part of a suite of policies and standards. We consult with our employee unions on our policies and statements. More on our policies and statements can be found on our Nationwide website as well as in our Environmental, Social and Governance (ESG) Disclosures.

We also consult with relevant internal and external stakeholders and charitable organisations, that provide best practice guidance on human rights issues, including family friendly working, wellbeing, domestic violence and sexual orientation. We participate in Financial Services network groups to support continuous improvement of our regulatory policies and standards.

Following consultation, our policies are jointly issued with our employee 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 2026