Ethics

We are guided by ethical values in every area of our operations, and we have zero tolerance for any deviations in this respect. Ethics is incorporated into our corporate values. By following these ethical principles, we conduct business in a transparent manner, showing respect for the law and internal regulations.

We have identified the following risks in the area of ethics and value management:

To avoid such situations we act preventively by promoting ethical standards among employees, and when an alarming situation is reported, we react rapidly.

Our activities are regulated by a number of domestic and EU guidelines, which ensure the safety of customer funds and stability of the banking system. The bank has an efficient ethical infrastructure founded upon the General Code of Conduct. It lays down ethical standards applied across the Group, covering specific situations.

The Code is supplemented by a number of additional regulations which set forth precise rules to be followed in respective areas, such as:

We are continuously improving and consistently promoting the policy of an open dialogue with employees, which provides them with the opportunity to report any breaches of the General Code of Conduct, encouraging them, at the same time, to share their observations and concerns.

Special communication channels whereby employees can report any irregularities and concerns:

Employees can make reports anonymously. The bank guarantees that all employees making a report will be guaranteed confidentiality and protected from any retaliatory action.

Methods of reporting breaches of ethical standards and other issues and concerns have been described in the Respect and Dignity Policy.¹ The document lays down the rules and procedure to be followed when dealing with incidents relating to breaches of law, banking procedures and standards or employee relations reported by employees.

¹ The “Respect and Dignity Policy” supplements the “Human Rights Policy of Santander Bank Polska S.A.”, and supports building a diversified working environment with respect for ethical standards and the dignity of each employee, which prevents such negative behaviours as discrimination, mobbing and harassment (including sexual harassment). The document describes how to proceed in the bank in case such situations take place. It also defines the responsibility of management and each employee for its implementation.

Anti-corruption is high on the agenda for financial institutions. In Santander Bank Polska, we create an environment free from any elements that could lead to corrupt practices and we promote anti-corruption knowledge among our employees.

The General Code of Conduct remains the foundation of internal regulations also in this respect. It contains a set of provisions concerning conflict of interest covering relations with the Group, banking transactions, investing into companies and relationships with suppliers and customers, as well as issues related to gifts, commission and other financial benefits. Additionally, the bank has a General Conflict of Interest Policy in place, which supplements the Code.

The bank’s approach has been presented in detail in the Anti-Corruption Programme document, which lays down the anti-corruption activities. The anti-corruption policy is binding on all employees.

In addition, we have introduced anti-corruption provisions into the “Bank’s Procurement Policy”, and “Supplier Management Procedure”, and mandatory anti-corruption clauses into agreements concluded with suppliers.

Corruption prevention is also covered in the Sustainability (CSRCorporate Social ResponsibilityCorporate Social Responsibility) Policy of Santander Bank Polska.

The bank has an Audit and Compliance Committee in place, which is mainly composed of independent members of the Supervisory Board. In addition to it tasks related to the assessment and review of the accounting systems, the control system and the risk management system, the Committee reviews the activities taken by the Management Board in terms of their conformance with the law, internal regulations, requirements of market regulators, codes of conduct and business ethics.

• In 2017, there were no cases of corruption reported in our bank.
• The bank was not subject to any fines or non-monetary sanctions for non-compliance with laws and regulations.

At the time of the launch of our Sustainability Policy, we extended the management of environmental and social risks to cover our relationships with customers from sensitive sectors. We respect the applicable international good practices concerning social welfare and environmental protection, in particular the Equator PrinciplesInternational project on social and environmental risks with the participation of financial institutionsInternational project on social and environmental risks with the participation of financial institutions, which cover the following aspects:

We are proud of the fact that as one of the first financial institutions in Poland we have implemented detailed sectoral sustainability policies concerning the financing of the defence industry and the energy and soft commodities sectors. The policies define, inter alia, activities which are excluded or restricted by the Santander Group with regard to the respective sectors. The examples of activities which are categorically prohibited include the manufacture, sale and distribution of mass destruction weapon or deforestation of areas classified as areas of special environmental value.

We have adopted a policy of not funding political parties. The bank, abiding by the principles of transparency, integrity and political neutrality, shall not accept any actions of its management or employees which could lead to a breach of the policy provisions or which could expose the bank to reputational risk. We do not make any political donations either.