Information:

Following the acquisition of Virgin Money on 1 October 2024, this policy statement is written on behalf of the combined Nationwide group, including Virgin Money.

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Our commitment to customers

We’re committed to providing our customers with the right information at the right time. It should be easily understood so they can make well informed decisions and take appropriate timely action to fulfil their financial goals. This is so we meet our customers’ needs with good outcomes and protect them from harm. Our standalone Communications Risk Policy commits us to responsible practices, by communicating in a clear and fair way that does not mislead our customers. It helps them understand the information we’re sharing. That’s not just the letters we send – it's also online content, texts, emails and product literature.

We are committed to designing, selling and managing products and services in a responsible and sustainable way. We have a set of policies, tools and processes, including an established governance route, for building products and services that are inclusive, meet customers’ needs and deliver good outcomes.

A big part of how we offer our products and services responsibly is how we talk about them. We have controls that ensure that our marketing practices comply with data protection requirements.


Our communication and content

We understand that everyone is different, with a wide range of needs and preferences. This includes how they access information. We offer our customers a range of ways to get the information they need, in an easy-to-understand way.

Our internal framework of policies, tools and controls help our colleagues to write and approve communications and content. This includes everything from traditional media like printed letters, to anything digital like emails and our website. The controlled way we produce this content gives us opportunities to consider some important points, such as:

Clear information

When creating our marketing materials and other communications, guidance is available to ensure they are not overly complicated or confusing, so that our customers will understand them. We also want to make sure they will not mislead a customer into making a decision that isn’t right for them.

We carry out testing on a sample of our communications to ensure they are understandable before we share them with our customers.

We need to balance giving detailed, factual information on our products while ensuring the information is easily understood for a range of literacy and numeracy abilities. We have a team dedicated to researching the best ways to do this. They also provide training and create guidance documents. We consider many factors, including reading age, functional numeracy skills, the easiest-to-read colours, font sizes and placement of words. We also strive to not hide key information in small print.

Accessibility, vulnerability and inclusion

We make sure that customer vulnerability is always a focus, and that our products and services meet the expectations set out in the FCA’s guidance on the fair treatment of vulnerable customers. For example, we consider how we describe the information needed in easy-to-understand language, and in what format we share this to meet the different needs of our customers including braille, large print or audio. These considerations are integrated during our creative process, to ensure we don’t inadvertently disadvantage certain groups of customers.

When a customer tells us they need communications in different formats, we follow documented processes to best meet those needs. We do this to ensure we deliver good outcomes to customers, regardless of their communication requirements.

Training

All colleagues engaged in marketing materials and other communications undertake formal training to equip them with the right skills and knowledge to support our customers. Competency and understanding are thoroughly tested before colleagues are permitted to use our communication systems. This knowledge is kept up to date with regular training refreshers. We also quality check a percentage of our communication processes to confirm they’re being followed correctly.  

Legal, regulatory and mandatory communications

These are the communications that we must, either by law or regulation, send to our customers at a certain point in time. This may be because of factors such as a change in the Bank of England Base Rate, which may change a customer’s mortgage payment. We have documented processes in place to identify when communications are mandatory, and processes to check they have been created and sent at the correct times. These processes are regularly tested to make sure they continue to work to an acceptable standard.

Throughout all phases of the communications process, various risk assessments and testing take place. Results are reported and monitored to make sure we understand and address any themes or weaknesses we find.

Marketing material

These are discretionary communications which we choose to share with our customers or potential customers to inform them of products, propositions or services that may be of interest to them. We have documented processes in place to make sure these have been created, and approved, by appropriate subject matter experts before they are shared.


About our approvals process

Communications are created, amended or reviewed, and then approved, in line with an approved, documented process. This includes review and approval by, for example, Legal, Data Privacy, Accredited Financial Promotion experts and accountable individuals from Product teams. We have systems in place to minimise the risk of communications being shared with customers without the proper approval steps taking place.

When we are making any claims within our communications (e.g. ‘best’ or ‘green’ claims), we always ensure that these are substantiated and can be evidenced. Each of our specific claims are reviewed regularly to make sure they remain accurate. Whenever a claim ceases to be true, our communications are withdrawn.


How we monitor distribution and data

We aim to ensure our communications process achieves good customer outcomes. To support this, we measure how understandable our communications are before they are distributed, that they have been distributed appropriately in the right formats through the right channels, and that they are not causing customers harm. We do this to ensure our customers can make well-informed decisions that lead to them taking appropriate, timely action to fulfil their financial goals.

We take our responsibility to look after customers’ data seriously. Our data privacy policy clearly sets out how and why we collect data, as well as how we use and protect it. Customers are able to update their marketing preferences at any time. Find out more about how we use your information.


Policy governance

Our Communications Risk Policy guides the production and distribution of marketing materials and communications across the Group. This policy is overseen by internal committees, attended by Senior Managers and experienced risk professionals, from across the Nationwide Group. We also engage with external stakeholders and initiatives to share best practice, expertise, and ways of improving marketing and communications for the financial services industry as a whole.


Last updated: March 2026


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