Anti-corruption
The Santander Bank Polska Group has a zero-tolerance approach to corruption.
- GRI:
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103-1 Explanation of the material topics and their boundariesExplanation of the material topics and their boundaries
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103-2 Approach to management of topics identified as material and their boundariesApproach to management of topics identified as material and their boundaries
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103-3 Evaluation of the management approach to topics identified as materialEvaluation of the management approach to topics identified as material
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205-2 Communication and training about anti-corruption policies and procedures for employees and managersCommunication and training about anti-corruption policies and procedures for employees and managers
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205-3 Confirmed incidents of corruption and actions takenConfirmed incidents of corruption and actions taken
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Custom indicator A list of key activities and initiatives implemented in the bank over the year to increase employees' knowledge of the bank's ethics and corporate cultureA list of key activities and initiatives implemented in the bank over the year to increase employees' knowledge of the bank's ethics and corporate culture
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ESG: G – Government Our approach to corporate governanceOur approach to corporate governance
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PRB 5 Governance & Target Setting We will implement our commitment to these Principles through effective governance and a culture of responsible banking, demonstrating ambition and accountability by setting public targets relating to our most significant impactsWe will implement our commitment to these Principles through effective governance and a culture of responsible banking, demonstrating ambition and accountability by setting public targets relating to our most significant impacts
We oppose all forms of corruption. Our ethical standards in this area are set out in the following documents:
- General Code of Conduct
- Code of Conduct for Securities Markets
- Conflict of Interest Policy
- Anti-Money Laundering and Counter-Terrorist Financing Policy
- Data Protection Policy
- Sustainability Policy
- Anti-corruption Programme
- Corporate Defense Policy
- Compliance Policy
- Reputational Risk Management Model – sets out the principles of managing and controlling the risk, the key aspects, principles and processes, as well as roles and responsibilities and internal supervision
Anti-corruption in the Code of Conduct
The Code addresses various aspects of ethical conduct in our organisation. It contains guidelines on conflicts of interest (in internal relations, in the execution of banking transactions and investments, and in relations with suppliers and customers), on cooperation with other entities, on contacts with regulators, on anti-money laundering and anti-terrorist financing, and on corrupt practices. The provisions of the Code are supplemented by additional regulations concerning particular areas of activity, including the „Anti-Money Laundering Policy” and the „Anti-Corruption Programme”.
„The Anti-Corruption Programme” clarifies our control mechanisms, including the register of gifts and invitations to public officials, the rules for offering gifts and invitations to employees or members of the bank’s management, the channel for reporting violations, training and the responsibility of the corporate compliance.
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0
confirmed cases of corruption in the bank and the Santander Bank Polska Group in 2020
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1
report on suspected corrupt behaviour (filed through available whistleblowing channels) in the bank and the Santander Bank Polska Group in 2020
Anti-corruption communication and training
Our employees periodically take part in e-learning training on anti-corruption. In the training we emphasise that there is zero tolerance for corrupt behaviour in our organisation. We teach:
- how to behave in different situations
e.g. in dealing with government officials, agents or intermediaries - what acts of corruption are
not only the transfer of money, but also the giving, offering or accepting benefits of any kind, such as the provision of goods and services below market prices, the offering of gifts, the provision of trips, hotel stays, meals and tickets, or the employment of friends
The training includes practical exercises and ends with a test. Every Group employee is obliged to take part in such training every two years. The training programme has been a fixed part of the schedule of mandatory employee training for many years. Ethical and reputational issues are also taken into account during the annual information and training Risk Pro campaign (Risk Culture Week), which promotes the risk management culture in the organisation.
| Percentage of employees who have familiarised themselves with anti-corruption policies and procedures | Percentage of employees who received anti-corruption training | |
|---|---|---|
| Group | 100% | 97% |
| Bank | 100% | 97,5% |
| Percentage of the bank’s Management Board members | 100% | 100% |
| Percentage of the bank’s senior management | 100% | 87% |
| Percentage of the bank’s middle management | 100% | 95,8% |
| Percentage of other bank employees | 100% | 97,8% |
