Code of Conduct Policy

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in the event of a dawn raid. Certain groups of individuals have specific responsibilities, for example individuals who m
Code of Conduct Policy

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Contents CODE OF CONDUCT POLICY 1. 

What does this policy cover?

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2. 

When does this policy apply?

2.1  2.2  2.3  2.4  2.5  2.6  2.7  2.8  2.9  2.10  2.11 

What are your obligations in relation to confidentiality? What are your obligations in relation to Competition Law? What can you wear to work? What happens if you are arrested or convicted? What is expected at Nationwide social functions / corporate hospitality events? What happens when an individual is suffering from drug or alcohol problems? What happens if you are in a personal relationship with someone at work? Are you able to set up a collection/ sponsor a colleague? Are you able to use Nationwide equipment for personal reasons? Are you able to use Nationwide’s postal services? Does Nationwide operate a smoke-free environment?

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This policy applies to all employees on Nationwide terms and conditions, including Senior Executive level and above. Contractors and Temporary Workers must also comply with this policy. Parts of this policy apply to employees of Nationwide (Isle of Man) Ltd (NIoML). This policy is non-contractual (except where a particular section is expressly stated to have contractual effect) and does not form part of your terms and conditions of employment. Nationwide reserves the right to amend, modify or withdraw the terms of this policy, subject to consultation with the Nationwide Group Staff Union (NGSU). In addition the contractual elements of this policy are subject to reaching agreement through consultation with the NGSU.

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professional manner and avoid improper conduct and/or behaviour.

What does this policy cover?

This policy outlines our expectations of employees in terms of how they should conduct themselves.

We want to ensure that Nationwide is a great place to work for all our employees and we are committed to promoting a culture of honesty and integrity across Nationwide which enables our people to do the right thing for our customers. The purpose and aim of this policy is to raise awareness and provide guidance regarding some of the standards of conduct and behaviour that Nationwide expects from its employees.

2.1 What are your obligations in relation to confidentiality? This section is contractual and forms part of your terms and conditions of employment. While you are working for Nationwide you may have access to a range of information about our business which may include customer details and/or commercially sensitive information.

This policy covers the following:           

Confidentiality Competition Dress standards Arrests and convictions Behaviour at social functions Drugs and alcohol Personal relationships in the workplace Collections Personal use of Nationwide equipment (computer and telephones) Postal services Smoking

To protect our employees, Nationwide’s business, our clients, suppliers and customers during your employment or after you have left Nationwide you: 



However, the following area are covered by the Communications and Privacy Policy:   

Confidential information includes, but is not limited to:

Use of social networking sites Personal mobile phones IT and internet usage

  

This policy also applies to employees of Nationwide (Isle of Man) Ltd (NIoML); however there are also additional confidentiality requirements applicable to NIoML employees, which are communicated at a local level.

   

Failure to comply with this policy may result in action being taken under the Disciplinary Policy.

 

2.

will not, without the prior written consent of Nationwide or in the proper performance of your duties, make use of or divulge to any unauthorised person, firm or company any confidential information will use your best endeavours to prevent the publication or disclosure of any confidential information, unless this is in the proper performance of your duties

When does this policy apply?



We want to maintain a positive working environment where everyone working on behalf of Nationwide behaves in a way which is consistent with our PRIDE values. To enable us to do that, it is important that you conduct yourself in a

financial information relating to Nationwide customer information information relating to business strategy, expansions and acquisitions/ mergers employee information systems information confidential reports or research product planning, designs and launch information advertising, marketing or promotional campaigns not already in the public domain any information which you ought reasonably to know is confidential any information which has been given to Nationwide in confidence by agents, consultants, customers, suppliers or other persons

Your contractual obligations do not prevent you from making a protected disclosure within the meaning of Part 4A (Protected Disclosures) of the Employment Rights Act 1996. This includes

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making further protected disclosures about matters previously disclosed in accordance with the Whistleblowing Policy. For more information on Nationwide’s whistleblowing arrangements, refer to the policy.

the Financial Services sector, so it is important that you make yourself aware of your obligations in the event of a dawn raid. Certain groups of individuals have specific responsibilities, for example individuals who meet or greet customers or visitors as part of their role (including customer facing staff in the branch network); members of Group Legal & Compliance and members of the Executive. The Dawn Raid Policy and accompanying procedures explain what is expected of you in the event of a Dawn Raid.

2.2 What are your obligations in relation to Competition Law? Nationwide has an obligation to conduct its business in a way which does not breach Competition Law. Our commitment to achieving this is set out in the Competition Law Compliance Policy, which you must also read in conjunction with this policy.

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What can you wear to work?

Your terms and conditions will tell you whether or not you have a contractual obligation to wear corporate clothing.

Competition Law prohibits any agreement or behaviour between businesses that restricts competition and has an effect (or potential effect) on trade. An example of a breach of Competition Law would be where two companies have made an agreement to price the same services / products at the same level which results in limited customer choice.

You should maintain a smart appearance whilst at work, both on Nationwide’s premises and when representing Nationwide externally. Your general appearance should be neat, clean and tidy and your choice of clothing and general appearance should reflect our professional standards.

Breaches could result in fines or sanctions against Nationwide, as well as fines, criminal sanctions and / or imprisonment for the individuals involved.

If you are not provided with Corporate Clothing then the dress standards for all locations is smart casual, though you may choose to wear formal business attire if this is your preference. Where you are provided with clothing for Health and Safety reasons this must be worn.

If your role involves contact with competitor organisations, or if you come into contact with sensitive or commercially confidential information relating to competitors, it is important that you do not act in any way which would amount to a breach of Competition Law.

If your dress is inappropriate, your manager will in the first instance make you aware of this. If you repeatedly come to work dressed inappropriately, you may be asked to return home to change into more suitable clothing. Where this is necessary you will be expected to make up any time lost.

The Competition Law Compliance Policy explains more fully the types of behaviour that might breach Competition Law, and what to do if you are concerned about a potential breach or if you need further guidance on your obligations. Whilst it is usually permitted to carry out benchmarking using official independent benchmarking services which provide anonymous results, if you are involved in these activities it is important that you comply with your obligations under the Competition Law Compliance Policy.

To help make the right choices regarding your dress and for further information including guidance on cultural and religious dress, please refer to the Dress Standards Employee mini-guide and Dress Standards Manager mini-guide.

2.4 What happens if you are arrested or convicted?

Investigations into alleged breaches of Competition Law may be carried out by any competent National or European authority (for example, the Competition and Markets Authority or the European Commission) by conducting unannounced visits to any of Nationwide’s operating locations. These types of unscheduled visits are generally referred to externally as ‘dawn raids’. These raids are rare, but they can occur in

You will not be subjected to a detriment or face prejudicial treatment purely as a result of being arrested or charged with a criminal offence. However, depending on the nature of the offence we may have to assess whether or not this affects your suitability to continue to carry out your role.

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You must tell your manager if at any time during your employment with us you are arrested or convicted of a criminal charge; this includes motoring offences. We will then assess whether or not this affects your suitability to continue to carry out your role. If you are performing a role which falls within the Senior Manager, Certification or Approved Persons regimes, this would include an assessment of your fitness and proprietary to continue to carry out your role and may require Nationwide to inform the Financial Conduct Authority or Prudential Regulation Authority. More information can be found in the Regulatory Conduct and Responsibilities Policy.

you are dealing with drug or alcohol addiction, you will be given support and assistance whilst you are undertaking treatment to help you manage your condition. You are encouraged to talk to your manager and to seek medical advice, to help you deal with these issues. If you do have a drug or alcohol addiction and do not take action to address this, or fail to complete any treatments recommended to you and as a result of this your standards of performance/attendance or our public image are affected, we may consider taking capability and/or disciplinary action. If you are concerned for a colleague, you are encouraged to speak to your manager or their manager about your concerns.

Our approach to employees who have been arrested will depend on the individual circumstances but the underpinning approach will follow the principles that:  





2.7 What happens if you are in a personal relationship with someone at work?

a person is innocent until proved otherwise the nature of the alleged offence or conviction may have no relevance on an employee’s ability to perform or continue working for us a decision to require an employee to stay away from work pending a court appearance will be made jointly by a senior manager and HR disciplinary action will only be taken if it is considered absolutely necessary

We recognise that employees who work together may form personal friendships. In some cases close personal relationships or family relationships may exist. Whilst we do not wish to interfere with these personal relationships, it is appropriate for us to ensure that all employees behave in a professional manner at work and that we avoid the potential for a conflict of interest to arise. If you are involved in a close personal relationship with a colleague, contractor, client, temporary worker or a person involved with a supplier or potential supplier, you must not allow that relationship to influence your conduct while at work. You must inform your manager as soon as possible about the relationship. We may need to take appropriate measures after discussion with you to avoid any potential conflict of interests and this is explained further in the Conflicts of Interest Policy.

For further information please refer to the Arrests and Convictions - Employee mini-guide.

2.5 What is expected at Nationwide social functions / corporate hospitality events? Work social functions and hospitality events are good opportunities to relax and socialise with colleagues, suppliers and clients which usually take place away from the workplace and outside of normal working hours. It is important however, that when taking part in such events you conduct yourself in a way which is in keeping with Nationwide’s professional image and behave in a way which does not contradict our employment policies, or cause a risk or actual harm to our reputation.

For further information please refer to the Personal Relationships Employee mini-guide and Personal Relationships Manager mini-guide. There are also rules in place regarding carrying out any transactions on your relatives or partners accounts and you can find out more about these from the Internal Fraud Policy.

2.6 What happens when an individual is suffering from drug or alcohol problems? We recognise that drug addiction and alcohol abuse require medical diagnosis and treatment. If

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whilst driving on behalf of Nationwide at any time, by anyone. In addition, smoking is not permitted at entrances, exits, fire escape routes or in front of branches and offices.

2.8 Are you able to set up a collection/ sponsor a colleague? We recognise that there are many occasions where it feels appropriate to arrange a collection or provide sponsorship for a colleague. However, no one should be put under any pressure to contribute to a collection or to sponsor an individual.

Smoking (including the use of e-cigarettes) is only permitted in designated locations as follows: 

2.9 Are you able to use Nationwide equipment for personal reasons?



This section is contractual and forms part of your terms and conditions of employment. From time to time you may use Nationwide equipment (such as telephones and computers) for reasonable personal use. You must act responsibly when doing so and ensure your personal use conforms with the principles set out in the Communications and Privacy Policy. Any reasonable personal use must not interfere with business activities; disrupt colleagues or impact on productivity.

Administration centres - Areas that have been designated by Property Services and are clearly signed to indicate this Branch and satellite offices - Where requested, an external area can be agreed locally with the manager. This must take into account the guidelines above. Consideration must also be given to potential security implications and rear doors must never be propped open

All customers, visitors, temporary workers and contractors are required to abide by Nationwide’s policy on a smoke-free environment. You should inform customers, visitors, temporary workers and contractors of the requirements and record any breaches on the Smoking Ban Incident Form.

2.10 Are you able to use Nationwide’s postal services? This section is contractual and forms part of your terms and conditions of employment. You can have reasonable use of the internal postal system to send personal letters to an internal department or for onward distribution to the post office for external delivery. You must personally pay for and apply the correct postage to all personal items for external delivery before placing items in the postal collection facilities. Please do not send large items or valuable goods via the internal postal system.

2.11 Does Nationwide operate a smokefree environment? This section is contractual and forms part of your terms and conditions of employment. We guarantee a smoke-free environment to protect the current and future health of all employees, customers and visitors. Smoking (including the use of electronic cigarettes (e-cigarettes)) is only allowed in designated areas. It is not permitted in any other area of Nationwide’s premises, company vehicles or

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DOCUMENT CONTROL

CHANGES SINCE LAST VERSION Section 2.1 has been updated to confirm that your contractual obligations do not prevent you from making a protected disclosure within the meaning of Part 4A (Protected (Protected Disclosures) of the Employment Rights Act 1996. This includes making further protected disclosures about matters previously disclosed in accordance with the Whistleblowing Policy.

VERSION HISTORY Version 10.0 9.0 8.0 7.0 6.0 5.0 4.0 3.0 2.0 1.0

Date 5 September 2016 20 May 2016 11 January 2016 21 April 2015 24 April 2014 4 April 2014 28 February 2014 3 January 2013 24 September 2012 19 March 2012

SUPERSEDED DOCUMENTS Employees Who Are Arrested or Face Criminal Conviction Nationwide Dress Standards Policy Drug and Alcohol Policy Confidentiality Policy No Smoking Policy

02 September 2011 07 April 2010 15 October 2003 undated 29 March 2007

ISSUE CONTROL Owner: Approver:

Employee Relations Head of Employee Relations and Group Legal

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