• GRI:
  • Management of material topics (identified as material in the materiality matrix) for the topic: Values and ethics3-3
    Management of material topics (identified as material in the materiality matrix) for the topic: Values and ethics
  • Conflict of interest2-15
    Conflict of interest
  • Mechanisms for seeking advice and raising concerns2-26
    Mechanisms for seeking advice and raising concerns
  • ESG:
  • Our approach to corporate governanceG – Governance
    Our approach to corporate governance
  • GPW:
  • Code of ethicsG-P2
    Code of 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:

  • Code of Conduct for Securities Markets”,

  • ”Anti-Money Laundering Policy”,

  • ”Anti-Corruption Programme”,

  • ”Conflict of Interest Policy”,

  • ”Respect and Dignity” (Whistleblowing) policy”.

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:

  • non-competition,
  • conflicts of interest,
  • relations with suppliers,
  • relations with customers,
  • receiving benefits,
  • anti-corruption,
  • confidentiality of information,
  • protection of personal data,
  • marketing and sale of financial services,
  • counteracting money laundering and terrorist financing,
  • conduct on securities markets,
  • responsibilities regarding accounting and financial information,
  • relations with public officials,
  • intellectual property rights.

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.

The full text of the Code is publicly available and can be found on our website under the Investor Relations tab in the Corporate Documents section.

Reporting of irregularities

  • GRI:
  • Communication of critical concerns2-16
    Communication of critical concerns
  • Mechanisms for seeking advice and raising concerns2-26
    Mechanisms for seeking advice and raising concerns
  • Number of irregularities and/or issues to be clarified reported to the "Ethics Box" and the HelplineCustom indicator
    Number of irregularities and/or issues to be clarified reported to the "Ethics Box" and the Helpline
  • ESG:
  • Our approach to corporate governanceG – Governance
    Our approach to corporate governance
  • PRB:
  • 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 impacts5 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 impacts
  • GPW:
  • Whistleblowing mechanismG-P4
    Whistleblowing mechanism

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.

 

The policy governs the protection of whistleblowers against punitive action, discrimination or other unfair treatment.

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:

  • ethical helpline for reporting violations of legal regulations, ethical rules, corruption, fraud, money laundering, failure to follow internal procedures, unauthorised disclosure of confidential information or excessive risk taking;

  • relational helpline to report  instances of, inter alia, discrimination, bullying, harassment and other violations of labour relations, corporate values and behaviours;

  • dedicated mailbox;

  • KLAKSON intranet application.

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.

Employee education on ethical issues

  • GRI:
  • List of key activities and initiatives implemented in the bank during the year to enhance employees' knowledge of the bank's ethics and corporate cultureCustom indicator
    List of key activities and initiatives implemented in the bank during the year to enhance employees' knowledge of the bank's ethics and corporate culture
  • PRB:
  • 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 impacts5 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 impacts

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:

  • applicable ethical standards,
  • avoiding situations giving rise to conflicts of interest;
  • whistleblowing channels available in the bank;
  • rules of conduct in specific situations, such as when dealing with government officials, agents or intermediaries;
  • actions and situations that employees should avoid as potentially corruptive – not only related to offering money, but also to giving, offering or accepting of any type of benefit, such as goods and services made available below market price, gifts, sponsored trips, hotel stays, meals and tickets or offering employment to acquainted persons.

The training includes practical exercises and ends with a test. Every employee of the Santander Bank Polska Group is obliged to take part in the training every two years. In order to pass the training, employees must prove that they have familiarised themselves with the General Code of Conduct, the ”Anti-Corruption Programme” and the ”Corporate Defence Policy” and successfully complete the test at a minimum level of 80%.

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.

Results of ethical policies implementation

  • GRI:
  • Communication and training on anti-corruption policies and procedures (indicator reported partially)205-2
    Communication and training on anti-corruption policies and procedures (indicator reported partially)
Percentage of employees who attended e-learning courses on ethics and compliance 97.43%
Percentage of employees who have familiarised themselves with anti-corruption policies and procedures:
Group 100%
Bank 100%
Members of the bank’s Management Board 100%
Representatives of the bank’s senior management 100%
Representatives of the bank’s middle management 100%
Other employees of the bank 100%
Percentage of employees who have received anti-corruption training in 2021:
Group 97.21%
Bank 97.40%
Members of the bank’s Management Board 100%
Representatives of the bank’s senior management 91.30%
Representatives of the bank’s middle management 96.76%
Other employees of the bank 97.49%