Anti-corruption

The Santander Bank Polska Group has a ”Zero tolerance for corruption” approach. Anti-corruption is one of the elements of the General Code of Conduct.

Our anti-corruption policy is set out in the ”Anti-Corruption Programme”, the application of which is consistent with the Santander Group’s Corporate Governance and Compliance Principles, the General Code of Conduct and the applicable regulations and local laws.

The programme includes provisions on anti-corruption and guidelines on:

• presentation of gifts and invitations to public officials,
• acceptance of gifts and invitations by employees,
• relations with third parties,
• application of additional control mechanisms,
• channels for reporting infringements.

In 2021, we updated  our Anti-Corruption Programme, adding detailed information on the whistleblowing channels available in Santander Bank Polska S.A.

One case of suspected corruption was reported in 2021. An employee accepted a discount card from a customer for purchases with a revolving limit. The card was returned to the customer along with a letter in which the bank expressed its disapproval for putting the employee in an awkward situation. The customer apologised for its behaviour.

We conduct our business taking into account the interests of all stakeholders, as long as these interests are not in conflict with those of the bank. We set out clear procedures for managing conflicts of interest in the ”General Code of Conduct” and the ”Conflict of Interest Policy” updated in 2021.

We comply with all the requirements of the updated good practices on the management of conflicts of interest and related party transactions.

• The bank applies the principle of equal treatment of the bank’s customers and suppliers. No shareholder receives preferential treatment in transactions with related parties.
• The Supervisory Board has the option to consult an external entity when valuing and analysing the economic effects of related party transactions. If the conclusion of such a transaction requires the approval of the General Meeting of Shareholders, the Supervisory Board shall each time assess the need for such an opinion.
• Members of the Management Board and Supervisory Board shall avoid professional activities that may lead to conflicts of interest. They may not take part in the resolution of matters where a conflict of interest has arisen or may arise and are obliged to inform the bank of any such situations.

The issues of possible conflicts of interest of members of the Management Board and Supervisory Board are also examined as part of the suitability assessment prior to their appointment to serve on these bodies and as part of the regular suitability assessments.

In 2021, no situations of this kind were identified in relation to Members of the Management Board and Supervisory Board.