Responsible products and services policy statement

We have a set of policies, tools and processes, including an established governance route, for designing and building products and services that are inclusive, meet customers’ needs and deliver good outcomes.

We operate policies that guide the design, sale and servicing of our products and services. Our product lifecycle management is a fundamental part of how we provide responsible products and services to our customers, manage conduct risks, and meet the requirements of the FCA’s Consumer Duty requirements. We also conduct ongoing monitoring as part of our product lifecycle management.

This framework enables us to consider and make informed decisions about some important points, such as:

Critical to our design process is the need to ensure that any product or service offers fair value for money for our customers. This includes pricing our products fairly, as well as ensuring the features and benefits are easy to use for the people for whom they’re intended.

Guidance is available to make sure our people consider many different factors as they explore how to price products fairly. This includes the detailed requirements we need to meet, and activities we need to undertake to ensure we are providing appropriate value to customers and adequately assessing our products. Considerations also include the cost of the product or service itself, what other banks or building societies are offering, and whether there are any offers or discounts that might be appropriate. These decisions are approved by our Pricing Committee, which is attended by senior leaders from across the business to ensure our products continue to represent fair value for our customers.

We are dedicated to ensuring vulnerability remains a priority consideration when designing and building products and services, and across the full end-to-end product lifecycle. We ensure our products and services meet the expectations set out in the FCA’s guidance on the fair treatment of vulnerable customers. This includes making sure customers with characteristics of vulnerability have been considered, and that any reasonable adjustments have been made to meet their additional needs.

Customer vulnerability, accessibility and inclusion requirements are embedded within our internal policies and standards to make sure we have considered the different skills, capabilities and needs of our customers. These requirements are considered when designing or changing products or services, including how we communicate with customers about them, to make sure we don’t disadvantage any customers, and that any reasonable adjustments to the design and operation of the product or service have been explored and implemented. We use customer research (i.e. engage with external parties and customers) to develop our approach to customer vulnerability and to provide products that support financial inclusion.

We ensure our terms and conditions are clear, fair and understandable in explaining key information, and any risks that could be associated with the product or service. This helps ensure our customers can understand their options and make informed decisions as to whether our products and services are right for their needs.

In line with our Communications Risk Policy, we carry out testing of our communications, including our terms and conditions, to ensure consumers understand them. Our communications approval process also ensures the right experts are approving these documents for clarity, balance, legislative and regulatory purposes. Our Terms and Conditions monitoring requirements set out how terms and conditions should be regularly monitored to ensure adherence.

We put the customer at the heart of everything we do to minimise and avoid possible harm to them. A key consideration in our design process is to ensure we understand potential areas of harm, and we work hard to proactively build our products and services in a way that does not cause harm to our customers in pursuit of their financial objectives. To help us understand the impact of such harms occurring, we have created a harms taxonomy that is in line with the FCA’s Consumer Duty requirements. This allows us to regularly monitor harms that may occur and report them to accountable individuals, forums, and committees, and take appropriate actions, where we see harms may be occurring. Our Customer Research team helps Nationwide make better decisions in our product and service offerings, by listening to what our customers think, feel and need. We do this by running research that gives clear and useful insights, so that customers stay at the heart of everything we do.

Nationwide has a Climate Change and Nature Risk Standard which aids the identifying, assessing, monitoring, managing, and reporting of climate and nature-related risk as a cause to Nationwide’s principal risks. The Standard articulates the principles and requirements that must be met to manage the risks arising from climate change, and how climate and nature-related risk may occur across our Group Risk Management Framework. To help understand the risks associated with climate change, including greenwashing, when designing new products and services we factor climate change and nature considerations into our Product and Service Approval Process, alongside potential liability and conduct risks.

Embedded in our processes is the need to consider the financial, economic, regulatory, societal and political landscape as a whole. Our Product and Service Approval Process, which includes fair value assessments, asks our subject matter experts to consider the impact of external factors like economic changes, political policy and changes to interest rates on customers and good outcomes. To make sure we remain responsible and fair, we actively prohibit anti-competitive behaviours, such as the creation of monopolies, or anything that could negatively impact the integrity of the financial market. Our Market Abuse Policy and mandatory training further reinforce our commitment to this.

Using a risk-based approach, we regularly test and review each of our products and services. This includes conducting risk assessments that make sure we identify, understand and manage any risks that might inhibit offering fair value, that might cause customer harm, or might create an obstacle to providing good customer outcomes, including to vulnerable customers.

Approval routes for our products and services are documented and take the form of reviews by accountable individuals, forums or committees, which are attended by experts from across the business. Together, they must approve or endorse decisions, with oversight by our Product Governance Forum which is chaired by a member of the executive committee and attended by several executive committee members.

We have documented sales journeys and distribution (sales) strategies which consider our target audience and market, and how well our sales channels meet the range of our customers’ needs. We also have processes in place that clearly outline our commitment to responsible marketing. This is backed by a Communications Risk Policy and a responsible marketing policy, which outlines what, when and how we should share information with our customers, and our responsible selling practices. Our responsible sales practices include:

All our customer-facing colleagues receive mandatory, formal training to make sure they have the right skills and knowledge to support our customers. All colleagues are required to complete mandatory annual training on Consumer Duty and Vulnerable Customers. Colleagues in regulated advice roles, such as mortgage advisors, are also equipped with the necessary role-specific qualifications, appropriate training and competency schemes. This level of skill is maintained with ongoing professional development relative to individual roles, and quality checking of a risk-based percentage of all processes to make sure they’re being followed correctly.

We prohibit any schemes that could encourage poor selling practices or aggressive sales techniques. This includes targets or rewards linked to individual sales performances. All eligible colleagues are enrolled in the same discretionary reward scheme. The outcome of this scheme depends on the business as a whole meeting certain financial, risk and customer experience measures.

We make every effort to ensure customers receive the right product by providing all the information they need and that it is clear, understandable, fair and not misleading. The information must also be in an appropriate format, provided in a timely way to allow customers to make informed decisions on the products and services that are right for them, that will support them in the pursuit of their financial objectives.

We aim to make our processes as easy as possible for our customers. We provide transparency in our sales journeys, and our systems include checkpoints to ensure key information is reviewed before a customer can take out a product. We carry out customer outcome testing to objectively assess whether the customer has received a good outcome.

We clearly set out our target market as part of product design, and we monitor where products are sold outside of that, to ensure suitability. By featuring our products on external comparison websites, customers can assess our products against a range of alternative options. We also provide in-house tools and guidance services to help guide customers with their choices. In the event a customer doesn’t qualify for their desired product or service, we tell them why. We also provide customer-focused educational tools, such as online calculators, and customers are able to provide feedback through a range of channels.

Making our products and services accessible to accommodate a wide range of needs and preferences is a key consideration in our distribution and servicing strategies. We continue to monitor accessibility throughout the product lifecycle and make changes wherever necessary.

Our servicing journeys and processes are well-documented and clearly outline our commitment to responsible servicing, including ensuring customers are not presented with unreasonable barriers. We also signpost customers to organisations (e.g. charities) that can offer non-financial support to them.

Our Product Lifecycle Policy, Communications Risk Policy, and responsible marketing policy support our approach.

Doing the right thing for our customers is deeply engrained within our culture, and is heavily reinforced in numerous ways, including:

We aim to deliver a brilliant experience for our customers and we measure and report on how satisfied our customers are with their interactions with us. We have a range of tools to understand whether our customers are receiving good outcomes and we also work with external independent bodies to compare our performance against others in the industry.

Our product and lending criteria are designed to meet customer needs and to avoid detrimental impacts to our customers. We use credit assessments to ensure we lend responsibly, and we also assess, through product and service design, how customers with vulnerability characteristics might be impacted by a product or service and consider how to best mitigate the risks.

However, we understand that circumstances can change, and that anyone can experience financial pressures. We are committed to supporting customers who may anticipate or find themselves experiencing a period of financial difficulty. We have defined overarching requirements in place to govern our approach to dealing fairly with customers in financial difficulty, payment shortfall, arrears, and debt recovery, and we offer forbearance options for customers that are tailored to their individual circumstances. Our Unsecured Arrears Standard, and Mortgage Payment Shortfall and Arrears Standard, outline what, when and how we should support customers in arrears, as well as outlining our responsible servicing practices.

We will work with customers to understand their circumstances and explore affordable and sustainable solutions based on their individual circumstances, so we can put the customer in the best possible situation as quickly as possible. We have a dedicated Specialist Support Team who have established procedures to help customers who are, or have become, vulnerable and need additional support in managing their finances. Where appropriate, we will signpost or make a referral for free money advice, or other support. In line with Consumer Duty, all employees in debt collection receive training on doing this in a responsible way.

Whilst we strive to deliver good outcomes for all our customers, we know that things can sometimes go wrong. We take our responsibility to manage customer complaints seriously and aim to investigate all complaints quickly and in a way that delivers a fair outcome and is in line with what customers expect from us, not just what regulation dictates. We ensure our complaints journey is accessible for all our customers, including customers with characteristics of vulnerability.

We undertake root cause analysis to identify the source, learn from our mistakes and provide a remedy. In doing so, we are committed to reducing the number of complaints we receive. Our customer-facing colleagues are given training in identifying and recording complaints, helping us to effectively manage the experience customers have with us when they approach us. Our Nationwide Group Board has oversight over our complaints review process.

Our Remediation framework sets out the requirements we need to meet to ensure we remediate customers fairly and consistently when conducting remediation activity. We have a dedicated team, the Remediation Centre of Excellence, which consists of specialists working together to apply our remediation principles and processes, enabling us to scope, design and deliver remediation projects repeatedly – meaning we can fix problems faster and keep our customers happier. The Remediation Executive Committee monitors and oversees all remediation activity.

Our main policy guiding the design, sale and service of our products and services is the Product Lifecycle Policy, owned by two of our Executive Committee members. The policy is overseen and approved by internal committees, that are attended by senior leaders (including Board members) and experienced professionals from across the business. Policy controls are tested independently to ensure appropriateness and effectiveness. We also engage with external stakeholders and initiatives to share best practice, expertise and ways of improving the financial services industry as a whole.

Last updated: April 2026