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.
Policies and regulations that provide a framework to counteracting misselling:
General Code of Conduct
Consumer protection policy in Santander Bank Polska S.A
Policy on commercialisation and monitoring of products and services in Santander Bank Polska S.A
Policy of accepting and offering incentives in Santander Bank Polska S.A.
Conflict of interest policy
Procedure for quality control in the sales of investment products -misselling
New regulations added in 2020.
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.
Procedures and practices
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.
Promoting ethical attitudes among employees
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
Initiatives implemented in 2020
The Compliance Area organised a Compliance Congress to communicate the main principles for designing customer-centric products and services, taking into account consumer protection principles.
In connection with the exponential growth of electronic transactions and the popularisation of electronic banking services, we conducted a number of campaigns targeted at customers. The education and information campaigns concerned safe online behaviour and responsible use of e-banking services.
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
ESG: S - Society Our approach to Social Responsibility
Our approach to Social Responsibility
PRB 4 Stakeholders We will proactively and responsibly consult, engage and partner with relevant stakeholders to achieve society’s goals.
We will proactively and responsibly consult, engage and partner with relevant stakeholders to achieve society’s goals.
Declaration of Responsible Selling
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.
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:
Santander Bank Polska S.A. Advertising and Marketing Communications Manual
Procedure for the preparation and verification of communication and advertising materials in Santander Bank Polska S.A
Communication and advertising guidelines for products intended for private and corporate customers
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
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
419-1 Value of significant fines and non-monetary sanctions for non-compliance with laws and/or regulations
Value of significant fines and non-monetary sanctions for non-compliance with laws and/or regulations
Compliance with responsible sales and marketing regulations
Total number of non-financial sanctions for non-compliance with laws and regulations (on services and products, product offer and/or customer relations)
Total number of cases of non-compliance with regulations and voluntary codes governing marketing communications.
Total number of cases of non-compliance with regulations and voluntary codes concerning labelling and information on products and services.
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.
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