Corporate Social Responsibility Report 2019
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Responsible sales and marketing

GRI:
  • [103-1] Explanation of the material topics and their boundaries
    Material topics:
    1) Responsible selling and prevention of misselling.
    2) Ethical marketing communication and reliable, comprehensible information about products and services.
    3) Regulatory compliance.
    Explanation of the material topics and their boundaries
    Material topics:
    1) Responsible selling and prevention of misselling.
    2) Ethical marketing communication and reliable, comprehensible information about products and services.
    3) Regulatory compliance.

    Go to indicator list
  • [103-2] The management approach and its components
    Material topics:
    1) Responsible selling and prevention of misselling.
    2) Ethical marketing communication and reliable, comprehensible information about products and services.
    3) Regulatory compliance.
    The management approach and its components
    Material topics:
    1) Responsible selling and prevention of misselling.
    2) Ethical marketing communication and reliable, comprehensible information about products and services.
    3) Regulatory compliance.

    Go to indicator list
  • [103-3] Evaluation of the management approach
    Material topics:
    1) Responsible selling and prevention of misselling.
    2) Ethical marketing communication and reliable, comprehensible information about products and services.
    3) Regulatory compliance.
    Evaluation of the management approach
    Material topics:
    1) Responsible selling and prevention of misselling.
    2) Ethical marketing communication and reliable, comprehensible information about products and services.
    3) Regulatory compliance.

    Go to indicator list
  • [417-2] Total number of incidents of non-compliance with regulations and/or voluntary codes concerning product and service information and labelling Total number of incidents of non-compliance with regulations and/or voluntary codes concerning product and service information and labelling

    Go to indicator list
  • [417-3] Total number of incidents of non-compliance with regulations and/or voluntary codes concerning marketing communications Total number of incidents of non-compliance with regulations and/or voluntary codes concerning marketing communications

    Go to indicator list
  • [419-1] Non-compliance with laws and regulations in the social and economic area – significant fines and non-monetary sanctions for non-compliance with laws and/or regulations Non-compliance with laws and regulations in the social and economic area – significant fines and non-monetary sanctions for non-compliance with laws and/or regulations

    Go to indicator list

Counteracting misselling

Responsible banking is an element of our bank’s business strategy and is based on two pillars – the corporate culture and inclusive and sustainable banking. Such an approach assumes that we take utmost care of the way our employees provide their services.

We require that each contact with the client is individualised, taking into account the needs and capabilities of the client. Employees are obliged to follow the sales procedures in force in the bank and to use sales materials accepted by the relevant approval bodies.

Kto decyduje – Obszar Zapewnienia Zgodności. Identyfikuje on zdarzenia missellingowe, poziom ryzyka misselingu oraz decyduje o nałożeniu kary

Wysokość wynagrodzenia

Kara może być nałożona za każdy stwierdzony przypadek:

  • sprzedaży zidentyfikowanej jako zdarzenie missellingowe,
  • wskazany przez Obszar Zapewnienia Zgodności, który nie spełni wyznaczonego poziomu ryzyka missellingu.

Wysokość kary zależy od rodzaju zidentyfikowanego zdarzenia missellingowego. Może ona dotyczyć:

  • pojedynczej lub,
  • całej sprzedaży zrealizowanej w danym okresie.

Wewnętrzne przepisy banku szczegółowo opisują sposób rozliczenia:

  • pracowników,
  • osób współpracujących z bankiem
  • osób wykonujących czynności agencyjne

Etyka – Jeżeli osoba współpracująca z bankiem dopuściła się nieetycznych działań w celu uzyskania korzyści w związku z wykonywaniem czynności i nałożoną na nią karę, to nie wyklucza się wobec niej zastosowania kolejnych konsekwencji wynikających z innych uregulowań. Decyzje w tym zakresie podejmuje Członek Zarządu zarządzający Pionem Bankowości Detalicznej, po zasięgnięciu opinii Komisji Etyki Biznesu.

GRI:
  • [102-12] External initiatives and externally-developed economic, environmental and social charters, principles, or other initiatives to which the organization subscribes External initiatives and externally-developed economic, environmental and social charters, principles, or other initiatives to which the organization subscribes

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Other guidelines:

We signed the Responsible Sales Declaration. The 2019 project is our contribution to promoting fair sales practices.

Our bank is one of the initiators of the Responsible Sales Declaration. Together with other financial institutions we have established this project to:

  • raise and disseminate ethical standards in customer relations;
  • educate business and consumers;
  • increase confidence in the financial industry;
  • counteract unfair practices.

The self-regulations contained in the Responsible Sales Declaration cover the above objectives and we believe that they will also provide the Polish market with a source of knowledge about the highest standards in finance. The initiators of the project are committed to increasing the positive impact of the financial industry on the environment and building relationships with consumers and business in such a way that they can better serve society and the economy.

The use of financial services concerns everyone, so it is important that the whole sales process should be transparent, clear any doubts that might occur and take into account the needs of particularly vulnerable groups. Financial institutions should also take care of after-sales relationships, including ensuring secure use of the product and promptly taking into account any complaints. Regardless of the stage, it is also in the interest of banks to educate the public about the finance and bank products. It is also important to prevent unfair practices and to react quickly whenever they are discovered.

It is worth noting that this is the first cooperation of this kind of business organisations that care about improving the quality of banking services.

The activities of financial institutions are not ordinary commercial activities. The bank is an institution of social trust which is particularly committed to conducting its business ethically. That is why it is so important for Santander Bank Polska to initiate and participate in all activities that strengthen the industry’s ethical standards. We want them to include not only the principles developed at the international level, such as UNEP UNEP FI Responsible Banking Principles, of which we are a co-initiator and signatory, but also to respond directly to the diverse and changing needs of specific consumers and businesses. Self-regulation is the best way to do it.

Michał Gajewski
CEO

Each company that signs the Responsible Sales Declaration once must renew it every 12 months, subjecting itself to further audits. In the case of a negative result of such annual audit or failure to submit to it, the institution loses the right to use the Declaration’s sign.

For more information on the principles contained in the Responsible Sales Declaration, the obligations of the signatories and guidance for all those who wish to join the initiative, go here.

 

 

Responsible marketing and labelling

We ensure that products and services comply with regulations and that our marketing communications are ethical. These issues are regulated at the bank by the following documents:

  • Santander Bank Polska advertising and marketing communication manual

  • Procedure for the preparation and verification of communication and advertising materials at Santander Bank Polska

  • Product communication and advertising guidelines for retail and corporate customers

Compliance with regulations on responsible sales and marketing

GRI:
  • [417-3] Total number of incidents of non-compliance with regulations and/or voluntary codes concerning marketing communications Total number of incidents of non-compliance with regulations and/or voluntary codes concerning marketing communications

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  • [417-2] Total number of incidents of non-compliance with regulations and/or voluntary codes concerning product and service information and labelling Total number of incidents of non-compliance with regulations and/or voluntary codes concerning product and service information and labelling

    Go to indicator list
  • [419-1] Non-compliance with laws and regulations in the social and economic area – significant fines and non-monetary sanctions for non-compliance with laws and/or regulations Non-compliance with laws and regulations in the social and economic area – significant fines and non-monetary sanctions for non-compliance with laws and/or regulations

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In 2019:

  • there were no cases of non-compliance with regulations and voluntary codes on labelling and product and service information at the bank;
  • compliance with the regulations on responsible sales and marketing was not examined or decided by the regulator. No financial penalties were imposed on the bank for non-compliance with laws and regulations on responsible sales, marketing and/or labelling of products and services.
  • we recorded one case which was classified as a ”misselling event”. The data came from a phone check initiated by the bank. The result of the detection was the withdrawal of 100% of the sales bonus to the employee.