Ethics

All employees of our bank, regardless of their functions, are required to apply the ethical principles and rules of conduct set out in the General Code of Conduct. It represents a set of key principles and values reflecting the Santander Group’s corporate culture which aim to build trust and lasting loyalty among employees, customers, shareholders and local communities. The Code is reviewed annually. No changes were made to the CoC provisions following their review in 2021.

Other regulations on ethical issues applicable to our bank include:

At Santander Bank Polska S.A. we also apply good industry practices collected in the Code of Banking Ethics, developed by the Polish Bank Association.

The ethical standards applicable to all employees of Santander Bank Polska S.A. are laid down in the General Code of Conduct. The Code sets directions for ethical business conduct and provides an ethical guideline for conduct in specific situations. It defines detailed ethical principles applicable to all employees, includes provisions concerning behaviour in specific situations and advises about the consequences of breaching its provisions.

These principles concern, among other things:

The Code also sets out the responsibilities of the various units for implementing ethical principles, including those of the Compliance unit management, 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 2021, we worked to update the ”Respect and Dignity” (Whistleblowing) policy and align it with the provisions of the EU Whistleblower Protection Directive and the proposed Whistleblower Protection Act. We also drafted new regulations based on the proposed laws.

Any employee of the Santander Group who becomes aware of a violation of the Code of Conduct, other codes, policies, procedures and other internal business regulations, or suspects that an offence, corruption or money laundering has been committed or that other laws, including the Group’s Human Rights Policy have been violated, is obliged to report it immediately.

The ”Respect and Dignity”(Whistleblowing) policy details the procedure and ways of reporting ethical breaches and other irregularities by employees through dedicated channels and sets out the procedure for handing such reports.

Employees who report violations of the law are guaranteed through investigation of the reported matter and full confidentiality. Whistleblowers will not be subject to reprisals of any kind or face any consequences for reporting violations.

Employees can use a variety of reporting channels, including:

Each of these channels offers a possibility to report matters of concern anonymously.

In 2021, our whistleblowing channels received a total of 205 reports from employees. Each of the reported cases was analysed and clarified. The allegations contained in the reports were confirmed in 34 cases and disciplinary sanctions were applied in 23 cases.

We make sure that our employees have the opportunity to deepen their knowledge of ethics, anti-corruption and the Corporate Defence Policy through regularly revised and publicly available e-learning training on these topics. The dedicated training courses refresh such topics as:

In 2021, we implemented a number of initiatives to increase ethical awareness and employee knowledge of our organisation’s corporate culture. These included:

• continuation of the communication campaign promoting ethical attitudes and presenting ways to report violations and irregularities, as part of which we prepared educational videos, articles, webinars, surveys and animations promoting whistleblowing channels;
• developing educational materials for managers based on conclusions from reported cases;
• continuation or regular meetings of the Director of the Office of Ethics and Relations with members of the Management Board – sharing conclusions and recommendations prepared on the basis of cases reported by employees.