Nationwide Building Society modern slavery statement summary (2024)

Organisation address

Nationwide House,
Piper Way,
Swindon,
Wiltshire,
UK,
SN38 1NW

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for all 6 recommended areas

What is a modern slavery statement?

UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.

Link to full statement

Go to full modern slavery statement on organisation’s website

PDF version of the statement

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Modern Slavery Statement - Nationwide 2024.pdf

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About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Contents

Organisations covered by the statement

Nationwide Building Society modern slavery statement for 2024 is a group statement covering 6 organisations. See the full list of organisations covered by this statement

Legal requirement to publish

Nationwide Building Society has confirmed it is required to publish a 2024 statement by law.

Statement period and sign-off details

The statement covers the following period:
5 April 2023 to 4 April 2024

The statement was signed off by:
Debbie Crosbie (CEO)

It was approved by the board (or equivalent management body) on:
19 June 2024

Recommended areas covered by the statement

Government guidance encourages organisations to cover a range of areas in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended areas in the statutory guidance.

We asked the organisation to tell us which areas its statement covers.

Areas recommended by government guidance	Organisation’s response
The organisation’s structure, business and supply chains	Covered
Policies	Covered
Risk assessment	Covered
Due diligence (steps to address risk)	Covered
Training about modern slavery	Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time	Covered

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

• Financial, insurance and real estate activities

Turnover

Its turnover in the financial accounting year of this statement was:

Over £500 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.

What does 'turnover' refer to in group statements?

If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:

More than 5 years

How does this work for group statements?

If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.

Policy provisions we asked about	Organisation’s response
Freedom of workers to terminate employment	Included
Freedom of movement	Included
Freedom of association	Included
Prohibits any threat of violence, harassment and intimidation	Included
Prohibits the use of worker-paid recruitment fees	Included
Prohibits compulsory overtime	Included
Prohibits child labour	Included
Prohibits discrimination	Included
Prohibits confiscation of workers' original identification documents	Not included
Provides access to remedy, compensation and justice for victims of modern slavery	Not included
Other	We are signatories of the UN Global Compact and have process and practices aligned international human rights standards and the UN Sustainable Development Goals.

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.

What counts as training?

We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.

We asked who the training was for	Organisation’s response
Your whole organisation	Yes
Your front line staff	Yes
Human resources	No
Executive-level staff	No
Procurement staff	Yes
Your suppliers	Yes
The wider community	No
Other	Economic crime teams

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.

We asked who the organisation engaged with	Organisation’s response
Your suppliers	Yes
Trade unions or worker representative groups	Yes
Civil society organisations	No
Professional auditors	Yes
Workers within your organisation	Yes
Workers within your supply chain	No
Central or local government	No
Law enforcement, such as police, GLAA and other local labour market inspectorates	Yes
Businesses in your industry or sector	Yes

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.

What are social audits?

A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.

Social audits we asked about	Organisation’s response
Audit conducted by your staff	Yes
Third party audit arranged by your organisation	No
Audit conducted by your supplier’s staff	No
Third party audit arranged by your supplier	Yes
Announced audit	Yes
Unannounced audit	No

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.

We asked if workers could raise concerns this way	Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app	Yes
Through trade unions or other worker representative groups	Yes

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:

Nationwide all-colleague speak up mechanisms and engagement surveys, sickness and absence data, staff turnover, press monitoring.

Modern slavery risks (optional)

Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.

We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

The flow of money through our accounts

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your own operations.
Who was it most likely to affect	Organisation’s response: Women Migrants Refugees Children Anyone with characteristics of vulnerability could be affected, such as (but not limited to) those with addiction, low mental capacity, mental health condition, poor literacy or numeracy skills, poor English language skills, learning difficulties, low emotional resilience, homeless, recently bereaved, victims of domestic abuse.
In which country	Organisation’s response: United Kingdom
Actions or plans to address this risk	Organisation’s response: We conduct transaction monitoring on customers, looking for behaviours and patterns of transactions linked to specific high-risk factors relating to human trafficking and modern slavery. The insights and intelligence we gain allows us to enhance and refine the criteria used to identify activity which may be indicative of exploitation and the proceeds of modern slavery. We will report cases where a suspicion has been identified.

Priority risks for this organisation (2 of 3)

Labour exploitation in our supply chain

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your supply chains. Tier 1 suppliers Provide their products and services directly to your organisation. Tier 2 suppliers Provide products and services to your organisation via your Tier 1 suppliers. Tier 3 suppliers and below Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect	Organisation’s response: Women Migrants Refugees Children
In which country	Organisation’s response: Bulgaria United Kingdom Malaysia South Africa
Actions or plans to address this risk	Organisation’s response: Our country risk assessment is based on suppliers’ primary and service delivery locations using external data such as the annual US Trafficking in Persons Report. Enhanced monitoring is conducted within certain higher risk areas of our supply chain, including but not limited to, EcoVadis sustainability assessment, evidence-based testing of compliance with our Third Party Code of Practice, and Sedex SMETA audits in our uniform supply chain.

Priority risks for this organisation (3 of 3)

Vulnerable customers at risk of exploitation

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your own operations.
Who was it most likely to affect	Organisation’s response: Women Migrants Refugees Children Anyone with characteristics of vulnerability could be affected, such as (but not limited to) those with addiction, low mental capacity, mental health condition, poor literacy or numeracy skills, poor English language skills, learning difficulties, low emotional resilience, homeless, recently bereaved, victimas of domestic abuse.
In which country	Organisation’s response: United Kingdom
Actions or plans to address this risk	Organisation’s response: We are continually looking to find ways to identify, address and support those in vulnerable circumstances. We have the ability to record customers circumstances and support needs on our systems, and we explore options for alternative identification to open and service bank accounts, where appropriate. We provide customer-facing colleagues with vulnerability training, toolkits and guidance, and our Specialist Customer Support teams are available to manage more complex cases.

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.

What are ILO indicators of forced labour?

The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour

Organisation’s response

The organisation told us its statement does not refer to finding any International Labour Organization (ILO) indicators of forced labour.

Demonstrating progress (optional)

We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks. They provided the following answer:

Our Statement includes a suite of KPIs (p15) that measure the effectiveness of some of our controls, while our progress summary (p14) provides an ‘at a glance’ view of the progress we have made in the reporting year, and our ambitions for further progress in the following year.