CLYDESDALE BANK LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation Your front line staff Human resources Executive-level staff Procurement staff Your suppliers

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Civil society organisations Professional auditors Workers within your organisation Workers within your supply chain Central or local government Law enforcement, such as police, GLAA and other local labour market inspectorates Businesses in your industry or sector

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Audit conducted by your supplier’s staff Third party audit arranged by your supplier Announced audit Unannounced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

We monitor working conditions internally through culture surveys and colleague engagement. We monitor suppliers through SMETA audits, health and safety checks, and worker voice surveys.

Demonstrated progress

The 2026 statement demonstrates progress over time through its “Our progress and ambitions” section, which summarises the actions completed during 2025/26 and sets out future ambitions. It also includes year-on-year KPIs showing how Nationwide measures improvement and tracks effectiveness over time.

Reported risks and mitigations

• Risk: The flow of illicit funds through our accounts
• Area: Within your own operations
• Group: Women Migrants Refugees Children
• Location: United Kingdom
• Mitigation: Nationwide will further improve controls that detect and disrupt potential modern slavery through customer due diligence, transaction monitoring and enhanced typologies. We will use intelligence from law enforcement, Public-Private Partnerships and specialist partners to improve detection of suspicious flows and escalate concerns to the NCA where required.
• Risk: Labour exploitation in our supply chain
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Location: Switzerland United Kingdom India Italy United States
• Mitigation: Nationwide addresses labour exploitation risks in its supply chain through supplier due diligence and risk based contractual expectations. Due diligence includes testing controls against the Third Party Code of Practice, reviewing FSQS and EcoVadis responses, and service-specific checks (eg Sedex SMETA audits on uniform factories). Corrective actions are requested and tracked where issues are identified. Nationwide promotes responsible purchasing practices through internal training and guidance.
• Risk: Vulnerable customers at risk of exploitation
• Mitigation: Nationwide will continue to support vulnerable customers through trauma-informed specialist teams, improved recording of support needs and accessible communication tools. We will strengthen colleague training to identify exploitation, expand safe spaces and Easy Read support, use intelligence to improve detection, and signpost customers to trusted charities, safeguarding bodies and law enforcement where needed.