Responsible sales and marketing

Inclusive banking is understood broadly in our bank. We take into account all customers’ needs, possibilities and limitations in the product offering and the way we provide services. We have built a corporate culture free of exclusions. Tolerance, attentive listening and individual approach are promoted among employees and are expected from our staff in relations with clients. Our advisers are bound by precise sales procedures. We also make sure to support them with training in dealing with special needs of customers served.

We have introduced Good Practices in the Service of Vulnerable Customers at Santander Bank Polska S.A. The procedure helps to develop products and services, as well as sales and service processes, taking into account the vulnerability and specific requirements of customers, in order to counteract misselling and promote responsible selling more effectively. We created a web page about the new regulation and other rules in force in the bank regarding vulnerable groups of customers.

We review all sales procedures before they are implemented in order, among other things, to prevent the risk of misselling. A key role is played here by the Compliance Area, which also supervises and monitors the process of identifying misselling incidents. Compliance reporting paths allow for the escalation of misselling incidents to the Local Marketing and Product Monitoring Committee, the General Compliance Committee, the bank’s Management Board, the Audit and Compliance Committee and the Supervisory Board. An identified misselling incident may result in financial sanctions for the responsible employee.

The above principles also apply to partner outlets.

We systematically implement initiatives related to building responsible banking.

• All employees are subject to mandatory e-learning training in the General Code of Conduct and ethics, conduct risk mitigation and commercialisation of products and services, as well as good practices concerning vulnerable customers. Training is repeated periodically and adapted to changing realities and sales practices.
• We regularly publish articles on ethical topics and responsible selling on the intranet.
• The topics of liability and prevention of misselling are regular items on the agenda of the Risk Week and RiskPro

The bank is a signatory and initiator of the Declaration of Responsible Selling. The purpose of the declaration is to improve and disseminate ethical standards in relations with customers, educate businesses and consumers, increase trust in the financial industry and counteract unfair practices.

In 2020, we underwent an independent audit confirming our compliance with the commitments enshrined in the Declaration. We scored a level two on a three-point rating scale.

More information on the Responsible Selling Declaration is available at: www.santander.pl/aktualnosci/aktualnosci-lista/santander-bank-polska-w-gronie-inicjatorow-deklaracji-odpowiedzialnej-sprzedazy and at www.odpowiedzialnasprzedaz.pl 

We ensure that our products and services comply with regulations and that our marketing communication is ethical. These topics are regulated at the bank by:

In 2020:

Amount of significant fines and total number of non-financial sanctions for non-compliance with laws and regulations (in respect of services and products, offer and/or customer relations): PLN 23,634,055

In 2020, the President of the Office of Competition and Consumer Protection, in the proceedings concerning the bank’s use of abusive contractual clauses in the appendixes to mortgage loan agreements denominated in CHF and EUR, issued decision no. 12/2020 and declared the clauses describing the bank’s rules for determining exchange rates as abusive, prohibited their use and imposed a financial penalty of PLN 23,634,055 on the bank. The decision is not final as the bank appealed against the decision to the Competition and Consumer Protection Court.