Anti-corruption policies

Fair

As a bank, we have the status of a public trust institution. For this reason, our activities are regulated by a number of domestic and EU guidelines, which ensure the safety of customer funds and the stability of the banking system. In this context, anti-corruption is high on our agenda.

Zero tolerance for corruption

In our organization, the ”Zero Tolerance for Corruption” policy is in force. Anti-corruption provisions can also be found in the main ethical document of our bank i.e. the General Code of Conduct.

The subject of corruption is tackled in the following sections of the Code:

Conflicts of interest covering relations with the Group, banking transactions, investing into companies, relations with suppliers and customers, gifts, commissions and other financial benefits. In addition, both the bank and Santander Bank Polska Group observe the General Conflict of Interest Policy, which supplements the Code.
Cooperation with third parties and regulatory relations.
Prevention of money laundering and terrorism financing.
Corrupt practices.

The General Code of Conduct has a separate section dedicated to whistleblowing in which confidentiality of the reporter’s data is guaranteed and the rules of evaluation of the reported cases are laid down. Additionally, the consequences of violating the rules and the responsibilities of respective units are set out.

GRI:

[102-20] Management responsibility for social and environmental matters

Implementation of the Code is the responsibility of the Compliance Area units, the Committee for Compliance with Santander Group’s Regulatory Requirements, the Internal Audit, the Audit and Compliance Committee, the Supervisory Board, the HR function and the Business Ethics Council.

The bank’s approach to corruption is fleshed out in the Anti-Corruption Programme. The document emphasises the policy of “zero tolerance” for corruption, and sets out anti-corruptions rules. The following elements make up the Anti-Corruption Programme:

Controls:
- Register of gifts and invitations to public officials
- Actions taken by agents, intermediaries, advisers and business partners
- Activities in high-risk countries
- Accounting controls
- Offering gifts or entertainment to the bank’s employees and managers
Whistleblowing channel
Training
Responsibility of the corporate compliance area

In October 2018, the bank’s Management Board adopted a resolution amending the Anti-Corruption Programme. The main changes involved the integration in the Anti-Corruption Programme of the provisions of the Policy, procedures and guidelines and an increase in the acceptable gift value to PLN 100. The requirement to obtain a manager’s consent to acceptance of higher value gifts and to record such gifts in the gift register have been upheld.

Corruption prevention is also covered by the Sustainability (CSR) Policy of Santander Bank Polska, which refers to the bank’s and the Group’s approach to running the business responsibly and in keeping with the sustainable development principles.

Employee education

In connection with the implementation of the Code and supplementary documents, the banks employees have been trained in the anti-corruption policy and procedures.

GRI:

[205-2] Training for employees and management on anti-corruption policies and procedures

Percentage of employees who are familiar with the anti-corruption policy and procedures of the organization

*The year-to-year drop in the rate is a result of the integration of the former Deutsche Bank’s staff into the Santander Bank Polska’s structure a t the end of 2018.

Data table

Percentage of employees who are familiar with the anti-corruption policy and procedures of the organization	2017	2018
Group	100%	100%
Bank	100%	100%
Percentage of employees who completed anti-corruption training	2017	2018
Group	97%	93.4%
Bank	97%	92.0%*

Completion of anti-corruption training
Percentage of Management Board Members who are familiar with the organization’s anti-corruption policy and procedures	100%
Percentage of senior management members who are familiar with the organization’s anti-corruption policy and procedures	82%
Percentage of middle management members who are familiar with the organization’s anti-corruption policy and procedures	91%
Percentage of other employees who are familiar with the organization’s anti-corruption policy and procedures	92%
Percentage of Management Board members who have completed anti-corruption training	100%
Percentage of senior management members who have completed anti-corruption training	82%
Percentage of middle management members who have completed anti-corruption training	91%
Percentage of other employees who have completed anti-corruption training	92%

GRI:

[205-3] Confirmed incidents of corruption and actions taken

In 2018, there were no reported incidents of corruption in our bank.

Did you know …?

You can report any misconduct or breach of our rules and values in three different ways.
100% of the bank’s Management Board members completed training in anti-corruption policies and procedures.

In any business activity, ethics is the key foundation for credibility, integrity and reliability in daily business operations and, consequently, the source of trust from customers and employees of an ethical company. Prudent management requires that daily activities should be guided by ethical standards. Ethics reduces the degree of reputational risk and increases the stability and profitability of a business organization. The participation of Santander Bank Polska in the Polish Standard of Ethics is a clear message for the banking and financial sector that implementation of high standards is not only possible but also leads to the enhancement of the market position and a significant growth of trust. Investments in ethical operations simply pay off.

Kamil Wyszkowski, General Director of UN Global Compact in Poland

Our plans for 2019:

Launching a mandatory e-learning course for employees to enhance their knowledge on how to react to such forms of misconduct as bullying, discrimination or harassment and where to look for support in the event of violation of the ethical standards laid down in the Respect and Dignity Policy.
Regularly addressing employees with educational messages promoting responsible attitudes and behaviours and encouraging the use of whistleblowing channels.
Implementation of a tool for recording and managing all reported cases.
Development of regular reports on the evaluation of reports and the resulting recommendations.
Promoting ethical attitudes and behaviours across the bank.