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 when 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 (SDGs), 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 participate in collective bargaining³. 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 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

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. We strictly adhere to UK employment regulation and conduct additional due diligence checks through our recruitment process.

Our Resourcing Policy prohibits recruitment fees being charged to workers, 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.

Combatting discrimination at work is something we take seriously at Nationwide.  

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 race, faith and belief, sex, gender reassignment, sexual orientation, pregnancy or maternity, civil partnership or 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. 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. 

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 (employees, apprentices, and contingent workers) 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 family friendly, flexible working, time off 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) help to raise awareness of inclusion, diversity, equity and sustainability, including topics such as gender, ethnicity, religion, working families, mental wellbeing. Our networks act as a collective employee voice, working collaboratively with the business to help deliver our inclusion and diversity ambitions and 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 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 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 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 for independent and expert input and enable peer discussion on best practice on a variety of environmental, 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 ensure 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.

It is important that our suppliers represent Nationwide and demonstrate a commitment to our policies and standards.

Nationwide’s Third Party Code of Practice - PDF 324KB (opens in a new window) outlines the environmental and social standards we expect our suppliers to uphold, which includes our expectations to respect 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, whistleblowing and collective bargaining. They must adhere to the working hour practices outlined within the Ethical Trading Initiative Base Code (opens in a new window) or an equivalent recognised international labour standard.

At onboarding, all prospective suppliers are asked to agree to comply with our Third Party Code of Practice - PDF 324KB (opens in a new window) and if they are required to produce a Modern Slavery Statement under the UK Modern Slavery Act, they are asked to confirm they have produced a compliant statement. Supplier responses to these questions are also reviewed at point of a new or renewed contract. If either of the questions are answered negatively, we investigate and seek to negotiate a schedule to close the gaps in a defined timeframe. Should the supplier refuse, Nationwide’s Chief Procurement Officer will determine if there are appropriate and necessary grounds for dispensation.

Nationwide conducts regular evidence-based testing of third-party compliance with the Third Party Code of Practice, for a prioritised set of third parties. Where a subcontractor is used to provide a material service to Nationwide, the third party is tested on their supply chain due diligence. Where non-conformances are found, remediating actions are requested and followed up at the completion dates agreed.

Since 2021, Nationwide has partnered with sustainability ratings provider EcoVadis, to help us monitor and manage our suppliers’ performance across environment, labour, human rights, ethics, and sustainable procurement activities. The EcoVadis methodology is aligned with United Nations Global Compact (UNGC) principles, allowing us to assess supplier compliance with international labour rights standards. Third parties are asked to complete the assessment on an annual basis. We have set a minimum benchmark sustainability rating for suppliers, and those that score below this are provided with a corrective action plan and requested to improve and reassess within 12 months.

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 systems and, if necessary, subsequent investigations. The reporting enables us to assess employee issues relating to 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 through our environmental, social and governance disclosures, pay gap reporting, and 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 regular evidence-based 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. 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 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 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.

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 environmental, social and governance disclosures 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 wellbeing of all colleagues involved in our organisation.

This labour rights standard applies to all Nationwide colleagues, and forms part of a suite of policies and standards. We consult the Nationwide Group Staff Union (NGSU), our 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 (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 the NGSU 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.

• 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
• Domestic abuse policy
• Environmental and social conduct
• Expenses Policy
• Fair Treatment at Work Policy, which applies to the following policies / frameworks:
  • Performance and absence
  • Probation
  • Disciplinary
  • Resolution framework
• Financial Support and Benefits Policy
• Flexible Working Policy
• Freedom of association and collective bargaining – includes Recognition and Procedure Agreement with NGSU
• Further Education Policy
• Gender Transitioning and Change of Gender Expression Policy
• Health and Safety Policy Statement
• Healthcare Protection Benefits Policy
• Human Rights Standard
• Hybrid Working Policy
• Inclusion and Diversity Policy (includes anti-discrimination)
• Job Security and Redundancy Policy
• On Call Policy
• Overtime and Additional Allowances Policy
• Pensions Policy
• Privacy and Monitoring Policy
• Probation Policy
• Resolution Framework
• Resourcing Policy
• Reward Policy
• Secondment Policy
• Shift Working Policy
• Sickness Absence Policy
• Third Party Code of Practice PDF, 324KB (opens in a new window)
• Time Off Policy
• Wellbeing Policy
• Whistleblowing Policy

Last updated August 2024