Corporate governance

Activities in the area of climate risk management and making appropriate steps to take advantage of opportunities are the responsibility of the Management Board as well as the Supervisory Board. These bodies support the risk management strategies by accepting key policies, participating in supporting committees, reviewing and accepting risks and reports.

The Management Board is responsible for setting our mission and long-term action plans, including the climate strategy and its main objectives. In making its decisions, the Management Board takes into account the assessments, information and analyses of the unit responsible for risk management, on the basis of which it adopts the ”Risk Appetite Statement”. The level of acceptable risk (”risk appetite”) is then approved by the Supervisory Board. Based on the defined limits, observation1 limits are set and risk management policies are constructed. In addition, the member of the Management Board responsible for risk management provides the Supervisory Board with relevant risk information in order to create a complete risk profile of the bank and to make appropriate decisions in this respect.

The Supervisory Board’s remit is, among other things, to review the bank’s overall management strategy and risk management strategy, also with a view to the long-term interests of the bank. In making its decisions, the Management Board also takes into account the assessments, information and analyses of the unit responsible for risk management.

In addition, the bank has a Responsible Banking and Organisational Culture Committee, which supports the bank’s Management Board in fulfilling its supervisory responsibilities with regard to the responsible business strategy and sustainable development at the company and Santander Bank Polska Group levels. The CEO is also the Committee Chairman and his responsibilities include defining the strategy and annual objectives in the field of responsible banking and corporate culture and ensuring the implementation of the provisions of Santander Bank Polska S.A.’s socio-environmental policies. This Committee is supported by the ESG Forum, which is tasked with planning ESG activities, coordinating their implementation in the bank, and reporting periodically to the Responsible Banking and Corporate Culture Committee and the bank’s Management Board. Members of the ESG Forum include senior managers representing all divisions.

In the Risk Management Division, the function of Environmental & Social Risk Manager (ESRM) was established two years ago. The manager is responsible for carrying out individual risk assessments, in particular for entities operating in sectors such as oil and gas, power generation and transmission, mining and metals, soft commodities, and making ESRM recommendations (positive, conditionally positive or negative) for clients or transactions in the Corporate and Investment Banking (SCIB) segment. Credit partners are required to verify that the socio-environmental risk analysis has been carried out and that the obligatory ESRM recommendation has been included in the credit application.

In addition, an Environmental and Social Risk Analysis procedure was implemented in June 2021 for customers in the Business and Corporate Banking (BCB) segment. As part of this process, an automated algorithm has been applied to a large extent, allowing for the preselection of environmental and social risks, as a result of which customers receive statuses regarding the level of these risks, so-called ”environmental flags”. ”Environmental flags” are assigned to all clients as part of a portfolio pre-selection, carried out on the basis of individual company characteristics (including an assessment of their PAC). There are four types of flags: one is temporary (”For Verification”) and three are final (”Positive Verification”, ”Elevated Risk”, ”Prohibited Activity”).