Code of Conduct

Goal 8 - Decent work and economic growth

The objective of all the companies of the Santander Bank Polska Group is to consolidate ethical standards among employees and to further develop a culture of responsible and ethical actions in the spirit of the Simple, Personal, Fair values.

  • GRI:
  • 102-16 Values, principles, standards and norms of behaviour
    Values, principles, standards and norms of behaviour
  • 102-25 Conflict of Interest
    Conflict of Interest
  • 103-1 Explanation of the material topics and their boundaries for the topic: Values and Ethics
    Explanation of the material topics and their boundaries for the topic: Values and Ethics
  • 103-2 Management approach to topics identified as material for the topic: Values and Ethics
    Management approach to topics identified as material for the topic: Values and Ethics
  • 103-3 Evaluation of the management approach to topics identified as material for the topic: Values and Ethics
    Evaluation of the management approach to topics identified as material for the topic: Values and Ethics
  • ESG: S – Society Our approach to Social Responsibility
    Our approach to Social Responsibility
  • ESG: G – Governance Our approach to corporate governance
    Our approach to corporate governance

The Santander Group and the Santander Bank Polska Group have an efficient ethical infrastructure, the cornerstone of which is the ”General Code of Conduct” (the Code), which contains ethical standards applicable to all employees and provisions for specific situations. The Code sets out general conduct guidelines applicable to various aspects of the bank’s activities and provides guidelines for the Santander Group’s relations with employees, customers, shareholders and local communities. In addition, it clarifies the organisation and responsibilities of the various units. The units responsible for implementing the principles of the Code include the management of the Compliance unit, the Santander Group Regulatory Compliance Committee, Internal Audit, the Audit and Compliance Committee, the Supervisory Board, the Human Resources Management Unit and the Business Ethics Board.

In 2020, we added new provisions to the Code:

  • a point on relations with competitors – which obliges all Santander Group employees to act in a fair and effective manner when executing transactions as part of their job duties in Santander Bank Polska Group, in all cases striving for unrestricted, healthy competition for the benefit of the market, our customers and all parties connected by business and/or professional relations, also in the social dimension,
  • a point stipulating the obligation to inform the Human Resources Unit and the Compliance Unit of any person subject to the Code who has been accused or convicted in criminal proceedings and of any proceedings in which they participate as a party, witness or in any other capacity, concerning Santander Bank Polska S.A. or involving Santander Bank Polska S.A. carried out by the authorities responsible for supervising the activities of Group companies, even if such proceedings are not related to their professional duties.

Our values

All actions taken by Santander Group employees and management must be consistent with the organisation’s ethical principles, relevant corporate policies and standards of professional ethics, and be based on our values.

The corporate culture of the Santander Bank Polska Group is founded on 8 values:


  • Show respect

  • Keep promises

  • Be part of change

  • Work with passion

  • Cooperate actively

  • Support others

  • Speak openly

  • Listen attentively

How do we put these principles into practice?

We provide equal opportunities, we focus on diversity, we do not allow discrimination

  • We provide equal opportunities for employment and career advancement.
  • We have zero tolerance for any discrimination based on gender, age, sexual orientation, nationality, religion, ethnic origin, marital or social status.

We respect other people


  • We foster a friendly working environment based on mutual respect.
  • We respect the dignity of others and uphold the principles of equality, commitment and collaboration.

We maintain a balance between personal and professional life

  • We support employees in achieving the maximum balance between their professional responsibilities and their personal and family life.
  • We give employees a chance to develop as individuals.

We prevent occupational risks

  • We ensure safe working conditions.
  • Our employees are obliged to observe health and safety rules.

We protect the environment and are socially responsible

  • We comply with applicable environmental and social responsibility regulations.
  • In our operations we apply the principles set out in Santander Group policies: the Sustainable Development Policy, the policies on change
    climate and environmental management, human rights policies and policies for risk-sensitive sectors.

We respect collective rights

  • We comply with the law on trade union formation and bargaining.
  • We respect the actions taken by organisations representing employees.
  • We rely on open communication and exchange of views with trade unions.

Conflict of Interest Policy

The Conflict of Interest Policy supplements the Code with guidance to prevent and manage conflicts of interest that may arise. The document also provides examples of the basic categories of conflicts of interest and the activities, services, decisions or transactions that generate or may generate a particular type of conflict of interest, and places obligations on officers and employees to identify, prevent, escalate and manage conflicts of interest.

In 2020, we updated the policy with provisions on the primacy of the interests of the Group and its customers over the personal interests of employees and their family members and related persons, and on the prohibition of approving operations by the employees who executed them or by their related persons.

How do we put the policy into practice?

  • Governing bodies, managers and all employees are obliged to act in good faith in accordance with the internal regulations in force, within the remits of their positions.
  • We adopt an honest and transparent attitude in line with our values.
  • We avoid conflicts of interest. If they arise, we develop the best measures to counteract them in order to minimise the negative effects.
  • We act in each case at our own discretion, maintaining our loyalty to the bank, its shareholders and customers, regardless of our own interests or those of related persons.
  • We refrain from participating in or influencing decisions involving employees or independent parties where there is a potential conflict of interest.
  • We report internally on all situations that may arise or have arisen as a result of conflicts of interest.

Corporate Defense Policy

In 2020, we reviewed and updated the Corporate Defense regulations. The merger of four documents (Model, Policy, Manual and Guidelines) resulted in one new document, the Corporate Defense Policy. The policy introduces a zero-tolerance approach to criminal activities, describes corporate crimes that must be detected and prevented and provides guidance on how to deal with such cases. The policy also contains examples of prohibited activities for which employees may be held criminally liable.

Respect and Dignity policy

Building a culture of openness in our organisation is supported by our Respect and Dignity policy. In 2020 we began work on revising the policy to align it with the Whistleblower Protection Directive and are planning to continue the work in 2021.