| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Actual | Positive | Santander Bank Polska S.A. processes significant amounts of customers’ personal data and other confidential and sensitive information, which are vulnerable to accidental breaches and targeted by cybercriminals. The impact affects several stakeholder groups (retail customers, business customers, media and the public, industry organizations, Santander Bank Polska Group). The Bank maintains a functioning security system for services, transactions and data, which is responsible for the security of this data. Legitimate complaints about data loss and privacy violations occur on a relatively small scale compared to the scale of the bank’s operations. The bank conducts educational campaigns on safe online banking. | 5.0 |
| Potential | Negative | The progressive digitalization of the banking sector means that Santander Bank Polska S.A. and other financial institutions are exposed to the risk of incidents such as loss or theft of confidential data (including customer data), interruption of key services, attacks on customer assets, fraudulent transactions. In the past, there have been incidents of customer privacy breaches and data loss on a relatively small scale in relation to the size of the Bank’s operations – a scale that could potentially increase significantly as more of the bank’s day-to-day processes are digitized. Potential negative impacts in this area could lead to non-compliance with regulations such as Regulation 2016/679 (GDPR). | 5.0 |
Selection of material aspects for the bank
- GRI:
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Process to determine material topics3-1Process to determine material topics
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List of material topics3-2List of material topics
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Processes to remediate negative impacts2-25Processes to remediate negative impacts
In 2022, we conducted an assessment of the materiality of ESG aspects using a pilot methodology developed by the Santander Group.
The assessment process consisted of three stages. At first, we compiled a list of material ESG aspects identified from the bank’s internal documents, industry-relevant issues, trends, topics identified a year earlier and aspects considered important by competitors. In the second stage, we asked external experts, employees, customers and NGOs to evaluate the diagnosed aspects. Each aspect was evaluated from the perspective of dual materiality i.e. in terms of its impact on our bank and in terms of our bank’s impact on that aspect. The third stage involved assigning appropriate weights to the ratings given and developing the ESG Materiality Matrix of Santander Bank Polska S.A.
ESG Materiality Matrix
Results of the assessment proces
Compared to 2021, the list of ESG aspects that have the highest materiality to our bank’s strategy has been expanded from eight to nine topics. Some aspects were reformulated under the influence of sustainability trends and the ESG priorities defined by the Santander Group. The differences are presented in the table below.
| HIGHLY MATERIAL ESG ASPECTS IN 2021 | HIGHLY MATERIAL ESG ASPECTS IN 2022 | COMMENTS |
|---|---|---|
| Security of services, transactions and customer data | Security of services, transactions and customer data | An aspect considered highly material in both 2021 and 2022 |
| Values and ethics | Values and ethics | An aspect considered highly material in both 2021 and 2022 |
| Comprehensive risk management, including ESG risks | Operational and business resilience
Integrating ESG into the organization’s risk management system |
The aspect „Comprehensive risk management, including ESG risks” has been divided into two separate topics. „Operational and business resilience” is an aspect considered highly material in the CSRD. It is also an aspect included in Santander Group’s summary of the highly material ESG aspects. The issue of „Integrating ESG into the risk management system” has been included as a separate aspect due to the high importance of the topic. |
| Positive customer experience (NPS) | Positive customer experience (NPS) | An aspect considered highly material in both 2021 and 2022 |
| Climate policy | Portfolio alignment with Net Zero 2050 goals
Green finance |
Following the development of the EU’s climate policy, the Climate Policy aspect has been divided into two aspects („Aligning the Portfolio to Net Zero 2050” and „Green Finance”), in line with the approach taken by the Banco Santander Group. |
| – | Meeting regulatory ESG requirements | Due to the increasing regulatory obligations imposed on financial institutions in the ESG area, it was decided to add a new aspect in 2022. This aspect was considered the most important. |
| Green finance (ESG finance) | Inclusive and sustainable banking | The Green Finance aspect was covered by the following two aspects: Integrating ESG into Risk Management System and Inclusive and Sustainable Banking. Both aspects were included in the list of the highly material ESG aspects. |
| Financial performance | – | Financial Performance is the result of all implemented activities and should be considered more as an overall performance measure rather than an ESG aspect. Therefore, it was decided to move away from Financial Performance as a separate ESG aspect. |
| Digitization and innovation | – | The Digitization and Innovation aspect was considered to be a slightly less material ESG aspect. |
For the purpose of this report, we have analysed the impact of Santander Bank Polska S.A. on the environment, taking into account external impacts as well as internal processes and the impact on employees. We identified the areas in which our organization has actual and potential impact, as well as positive and negative impact. We also determined whether the impact is major, moderate or minor. Below are the areas defined as „major” along with background data.
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Actual | Positive | Santander Bank Polska S.A. has a Business Ethics Council, a General Code of Conduct, the Respect and Dignity policy and whistleblower channels for reporting misconduct. The Council’s tasks include analysing situations and events that are indicative of unethical behaviour and recommending the best solutions. In 2021, one case of suspected corruption was reported; in 2019-2020 and 2022, there were no confirmed cases of corruption at the bank | 4.8 |
| Potential | Negative | Santander Bank Polska S.A. is the third largest bank in Poland. Any hypothetical incidents of corruption, bribery or other unethical behaviour, due to the impact scale, would have a negative effect on the environment and lead to non-compliance with relevant regulations. Corruption poses a serious threat to economic growth and good governance, disrupts the functioning of market mechanisms, reduces the degree of public trust in financial institutions, and promotes human rights violations, so the impact has been assessed as significant. | 4.8 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Potential | Negative | By managing ESG topics, Santander Bank Polska S.A. contributes to the process of managing systemic risks arising from, among other things, climate change or social inequality in Poland. The bank is a prominent financial institution in the Polish market, so any inefficiencies and omissions in the bank’s risk management processes could potentially impair the performance of the financial system and reinforce market disruptions due to the interconnectedness of the system, which would affect many stakeholder groups: customers, employees, the environment. Due to the growing importance of ESG considerations, the probability of such negative effects was assessed as high. | 4,5 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Actual | Positive | The bank complies with good practices, international standards and applicable regulations. It goes beyond minimum legal requirements by following good practices and aspiring to reporting according to the GRI standard and TCFD guidelines. | 4.1 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Potential | Negative | The magnitude of the impact has been assessed as high due to the relevance of the topic in the new CSRD, as well as in the context of the importance of financial institutions in relation to achieving the goals of the Paris Agreement (impact may lead to non-compliance). | 3.9 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Potential | Negative | Santander Bank Polska S.A. could contribute to negative environmental impacts by financing environmentally unsustainable activities which would have a significant negative impact on climate. Failure to align the investment portfolio with Net Zero targets would prevent compliance with the Paris Agreement, which is expected of Santander Bank Polska S.A. in light of the Banco Santander Group’s strategy. | 4.5 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Potential | Negative | Failure to align financial product offer with Net Zero goals would prevent compliance with the Paris Agreement, which is expected of Santander Bank Polska S.A. in light of the Banco Santander Group’s strategy. | 4.0 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Actual | Positive | The impact consists in providing financial services to customers, simplifying and digitizing products and processes, promoting omnichannel service and simplifying the credit process for businesses. | 4.1 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Actual | Positive | Santander Bank Polska S.A., by providing access to financial services to people with individual needs, has a positive impact on building trust in financial institutions and financial inclusion of people (Barrier-Free Service program, tailoring services to the needs of customers with disabilities). The impact affects several stakeholder groups – primarily customers, but also social partners, the media and the public. | 4.1 |
| Potential | Negative | A potential lack of action in this area could deprive people with individual needs of access to banking and undermine social capital and trust in financial institutions. The impact affects several stakeholder groups – primarily customers, but also social partners, the media and the public. | 4.1 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Potential | Negative | The impact was assessed as moderate. A potential lack of action could negatively impact diversity and equal opportunities in the workplace, including equal pay for men and women. In extreme cases, negative impact in this area could lead to non-compliance with equal treatment laws. | 3.8 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Potential | Negative | When assessing human rights impact, the importance of the human rights topic should be considered first and foremost, rather than the possibly low probability of the occurrence of real effects. | 3.2 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Actual | Positive | Santander Bank Polska S.A. is the third largest bank in Poland so the magnitude and extent of the impact was assessed as high. Corporate governance of Santander Bank Polska S.A. defines the principles of the bank’s authorities, internal systems and processes. Strict adherence to these principles allows building good relations with shareholders, customers and other stakeholders, and increases the effectiveness of internal supervision, key internal systems and functions, and statutory authorities. | 3.2 |
| Potential | Negative | Santander Bank Polska S.A. is the third largest bank in Poland. The potential weaknesses in the functioning of corporate governance could have a significantly negative impact on the environment and would lead to non-compliance with applicable voluntary guidelines such as Good Practices for Companies Listed on the WSE or Corporate Governance Principles for Supervised Institutions. | 3.2 |
| Actual or potential impact? | Positive or negative impact? | Background and comments | Santander’s impact on the environment according to the Materiality Matrix (Santander methodology) (on the 0 to 5 scale) |
|---|---|---|---|
| Potential | Negative | The magnitude of the impact was assessed as high, as the negative effects would lead to non-compliance with regulations. The impact of negligence in the area of financial crime prevention could also be irreversible. | 3.2 |
| Highly material ESG aspects in 2022 | Where we write about this in our report: |
|---|---|
| Security of services, transactions and customer data | |
| Values and ethics | |
| Operational and business resilience | |
| Integrating ESG into the organisation’s risk management system | |
| Positive customer experience (NPS) | |
| Green Finance | |
| Aligning the portfolio to Net Zero 2050 | |
| Meeting the regulatory ESG requirements | |
| Inclusive and sustainable banking |