Anti-corruption policies

GRI:

[103-1] Explanation of the material topics and their boundaries
Material topic: The role of values and ethics in the organizational culture, including building responsible employee attitudes.
[103-2] The management approach and its components
Material topic: The role of values and ethics in the organizational culture, including building responsible employee attitudes.
[103-3] Evaluation of the management approach
Material topic: The role of values and ethics in the organizational culture, including building responsible employee attitudes.
[205-2] Communication and training about anti-corruption policies and procedures for employees and managers
[205-3] Confirmed incidents of corruption and actions taken

Other guidelines:

[ESG Governance]

The Santander Bank Polska Group has adopted the ”zero tolerance for corruption” approach.

Our ethical standards in this area are set out in the following documents and policies:

General Code of Conduct,
Code of Conduct on Securities Markets,
General Conflict of Interest Policy,
Anti-money laundering and anti-terrorist financing policy,
Personal data protection policy,
Sustainability policy,

Anti-corruption program,
Corporate defense model (a model to prevent the risk of criminal liability for employee misconduct),
Compliance policy,
Reputational risk management model – defines the principles of risk management and control, key elements, policies and processes, as well as roles and responsibilities and internal supervision.

Anti-corruption provisions of the General Code of Conduct

The Code addresses various aspects of ethical conduct in our organization. The document provides guidance on conflicts of interest (in internal relations, in banking transactions and investments, and in relations with suppliers and customers), principles of cooperation with third parties, rules of contact with regulators, anti-money laundering and terrorist financing and corrupt practices.

The Code is complemented by the ″Anti-Corruption Programme″, which describes in detail the control mechanisms in place, including a register of gifts and invitations for public officers, rules of offering gifts and invitations to employees or members of the bank’s management, a channel for reporting violations, training and responsibilities of the Corporate Compliance.

0

confirmed cases of corruption in the Santander Bank Polska Group and the bank in 2019.
4

reports of irregularities in the Santander Bank Polska Group and the bank in 2019 through available channels.

Anti-corruption communication and training

Our employees have the opportunity to deepen their knowledge in the field of anti-corruption by means of a generally available e-learning training on this subject. During the training we emphasize that there is zero tolerance for corrupt behaviour in our organization. We also teach:

how to behave in specific situations, e.g. when dealing with government officials, agents or brokers;
what constitutes a corrupt activity – not only transferring money, but also giving, offering or accepting benefits of any kind, such as: providing goods and services below market prices, handing over gifts, funding trips, hotel stays, meals and tickets or hiring friends.

The training includes practical exercises and ends with a test. Every 2 years each employee of Santander Bank Polska S.A. Group is obliged to take part in the training.

Anti-corruption communication and training in 2019

	Percentage of employees who have become acquainted with anti-corruption policies and procedures	Percentage of employees who have undergone anti-corruption training
Santander Bank Polska Group	100%	93%
Santander Bank Polska	100%	91%
Members of the bank’s management board	100%	100%
Members of the bank’s senior management	100%	88.5%
Members of the bank’s middle management	100%	92.2%
Other employees of the bank	100%	94.2%