Selection of material aspects for the bank

In 2022, the bank’s carbon footprint in Scopes 1 and 2 was 31,613.6 tCO₂e (location-based) / 19,499.8 tCO2e (market -based). The carbon footprint in Scope 3, resulting from business travel, was 870.1 tCO₂e.

The bank is working to reduce its direct carbon footprint, e.g. since 2020 onwards it has been neutral in terms of its own CO2 emissions. The energy purchased directly comes exclusively from renewable sources. In the current calculation methodology for Scope 3, the bank has so far not taken into account the impact of its portfolio with a significant effect on the climate. Santander Bank Polska S.A. is implementing the global Net Zero strategy of the Banco Santander Group.

CO2 emissions have a negative impact on the environment, so the impact has been identified as actual and negative.

Actual negative impact

In 2022, the bank’s total electricity consumption was 21,670.20 MWh, with 9,551.29 MWh of energy coming from non-renewable resources (the energy purchased by the Bank comes from RES, while the energy for which the Bank is re-invoiced, based on agreements between the bank’s suppliers and energy distributors, comes in part from non-renewable sources). Previous reports do not include data on energy consumption outside the organisation (GRI 302-2). The bank is taking steps to reduce the negative impact by minimising energy consumption and increasing the use of renewable energy sources.

Energy consumption negatively impacts the environment, so the impact has been assessed as actual and negative. All measures aimed at increasing the share of renewable energy, among others, have been included in the assessment of the scale of impact.

Actual negative impact

In 2022, the topic of remuneration was crucial due to the macroeconomic situation in Poland. Rising inflation was identified as one of the most significant risks in the World Economic Forum’s ‘Global Risks 2023’ report. The analysis of the bank’s impact in this regard involved in the first place examination of the indicators and data on remuneration levels taking into account the different job grades, and a comparison with the minimum wage and the rate of inflation. The pay rate of the bank’s lowest-level employees (customer service manager, relationship manager) by gender in relation to the minimum wage in 2022 was 146% for women and 144% for men.

The bank conducts a pay review every year. In September 2023, the Management Board of Santander Bank Polska S.A. approved the remuneration adjustment plan.

In the absence of a numerical data summary of the remuneration adjustment process at the time of the analysis, the impact in this respect could not be identified as actual. The lack of data also prevented a precise assessment of the scale and scope of the impact. Therefore, the adjustment of the remuneration of employees in the bank’s branches to the current inflation rate should be interpreted as a potentially positive impact of the bank.

Potential positive impact

On 30 March 2023, the European Parliament adopted new regulations on pay transparency. Under the new EU directive, companies will have to report on the gender pay gap for work of equal value and take action if the pay gap exceeds 5%. The new directive also includes provisions on compensation for victims of pay discrimination and on penalties, including fines, for employers who violate the new regulations. The Pay Transparency Directive will enter into force after publication in the Official Journal of the EU. In addition, in November 2022, the European Parliament adopted the Woman On-Boards Directive. According to the legislation, by June 2026 at least 40% of non-executive directors or 33% of all executive and non-executive directorships must be held by members of the underrepresented gender. The impact analysis in this topic area largely follows the above regulations.

The bank’s pay gap indicator last year was 2%. This means that, on average, women earned 2% less than men in the same positions. The pay gap indicator improved by 0.4% compared to the previous year. A pay review was conducted at the bank in the second quarter of 2022 to continue to address the gender pay gap. The bank aims to close the pay gap by 2025. In 2022, the Santander Bank Polska Group was awarded the 'Equal Pay Certificate’.

The bank’s ESG 2022 Report presents data demonstrating that there is a decrease in the share of women at different levels of employment compared to 2021, with values now ranging from a 68.2% share of women among all permanent employees at the bank to an 11.1% share of women in top management.

Due to the relevance of this issue in light of current social changes, the differences that exist in remuneration and the share of women at all levels of employment and the lack of an in-depth analysis of the results (description of adopted methodologies and detailed explanation), the impact should be assessed as actual and negative.

Actual negative impact

Actions taken by the bank to reduce the gender pay gap can in turn create opportunities to increase stakeholder trust and help position the bank as a responsible, inclusive employer.

With a network comprising branches, off-site locations, banking zones and partner outlets, the bank interacts with local communities in Polish cities of all sizes. Thanks to the scale of its operations and the identification of local needs, all these business units can have a positive impact on local communities. Given that Santander Bank Polska S.A. has been carrying out activities aimed at meeting the needs of target social groups for several years, the impact it exerts (through initiatives) should be identified as actual. One area of such impact is the activity of the Santander Foundation. The initiatives implemented by the Foundation include grant programmes, a scholarship programme, cooperation with other organisations to implement social projects as well as the coordination of corporate volunteering.

Implementation of the Santander Universidades programme

Education is at the heart of the bank’s social commitment and the most important programme in this area is Santander Universidades, implemented globally by the entire Santander  Group. Through cooperation between business and academia, the bank contributes to improving the professional competences of members of society and adapting them to the needs of the labour market.

The bank is pursuing these objectives through its global education platform, Santander Open Academy.

The bank cooperates with 66 Polish universities, where it has 13 own outlets.

Actual positive impact

The bank runs educational campaigns on safe online banking, including:

• cooperation with the Polish Bank Association as part of the project 'Security in cyberspace’ (implemented since 2017) with nearly 1 million beneficiaries, including direct participants: 185,000 schoolchildren, more than 95,000 students and approximately 8,000 seniors.
• The project implemented by the Santander Foundation „Independent and Safe Senior on the Web”, which includes a series of workshops on the safe use of the Internet and electronic banking services. Classes are conducted throughout Poland by volunteers of the Foundation and by police officers. No statistics are available on the scale of the project.

Actual positive impact

The ability to ensure effective protection of customer privacy comes with potential additional costs for IT services, which may be reflected in the bank’s cash flow.

The bank aligns its communication, marketing and sales practices with applicable laws and is committed to continuously monitoring them by informing the bank of significant changes in laws and guidelines from regulators (e.g. in the form of messages in the mobile app and online banking), monitoring the implementation of regulatory projects, applying procedures for the acceptance of new products and significant product changes, reviewing contractual templates, communications and advertising, procedures and training and regular monitoring of processes and products. No figures are available on the above activities. In 2022, the bank recorded no instances of material non-compliance with regulations and voluntary codes on the labelling and communication for products and services, including advertising, promotion and sponsorship. There were, however, fourteen significant cases of employee fraud, which resulted in the bank terminating the employment contracts with justification (Article 52 of the Labour Code) and one case of imposing a fine for non-compliance with generally applicable laws, the details of which are disclosed in the ESG 2022 Report. In 2022, no cases related to misselling were documented at the bank. Due to the nature of the incidents, the impact should be identified as potential and negative.​

Potential negative impact

In 2022, the bank was among the top four banks in Poland in terms of managing the quality of the mass customer experience. It also achieved the third highest NPS in the group of affluent customers and small and medium-sized companies. In addition, the improved performance can also be seen in relation to corporate customers, where the NPS increased by 10 points. The Net Promoter Score (NPS) is a measure of the extent to which customer needs are understood and satisfied. In 2022, the bank adopted the Customer Experience Management Policy, which sets out key customer-centric standards. In 2022, in the 7th edition of the ‘Institution of the Year ranking’, the Bank received three awards: in the ‘Best Branch Service’, ‘Best Remote Channel Service’ and ‘Best Bank for Companies’ categories.

Actual positive impact

One of the elements of the bank’s responsibility and customer care is to strive to make banking services fully accessible. The Barrier-Free Service programme ensures an equal standard of service and a positive experience for customers with individual needs regardless of where they are served – in a branch, by telephone, online or through an ATM. The bank’s website includes a tab with the possibility to search for a barrier-free branch and ATM, i.e. one that has been adapted for customers with special needs.

Santander Bank Polska S.A. has a Consumer Protection Policy which, among other things, introduces a definition of a vulnerable customer. This is a customer who, due to his or her life situation, is particularly vulnerable to financial or personal losses, and this may be related, for example, to age, disability, job loss, illness or financial hardship. Appropriate provisions are included in internal procedures and employees who have direct contact with customers, especially vulnerable customers, receive appropriate training.

The bank is a founding member of the Business Accessibility Forum. This initiative serves to popularise solutions to increase the accessibility of services and to develop a common position among members on the implementation of the EU Directive on the accessibility of products and services into Polish law. In 2022, the bank received the title of ‘Bank of the Year’ in the ‘Inclusive Banking’ category from The Banker magazine.

Actual positive impact

Hypothetical incidents of corruption, bribery or other unethical behaviour, due to the scale of the impact, would have a negative impact on the environment and result in a breach of regulations.

During the period between 2019 and 2023, not a single case of corruption has been confirmed at the bank, and no legal proceedings regarding corrupt practices have been initiated against the bank or its employees. The bank operates according to a zero-tolerance approach to corruption. Anti-corruption matters are governed by the General Code of Conduct and the Anti-Corruption Programme (until November 2023)/ Anti-Bribery and Corruption Policy (as of December 2023), which address, inter alia: the giving of gifts and invitations, relations with third parties, the use of additional control mechanisms and channels for reporting violations of the rules.

The bank discloses indicators on employees covered by anti-corruption training. A total of 97% of employees have received anti-corruption training in 2022 (employees on long-term sick leave are not included).​

Potential negative impact

This area is covered by the bank’s policy; however, there have been isolated instances of suspected corruption in the past, hence the risks identified.

ESG issues directly or indirectly affect liquidity. As a financial intermediary, the bank contributes to significant positive and negative, environmental and social externalities through its lending practices. Environmental, social and governance factors can have a significant impact on the entities, assets and projects financed by the bank l in many industries.

Failure to integrate ESG risks with business risks can adversely affect the bank’s liquidity and, consequently, its customers. This also applies to the impact analysis of the bank’s portfolio. ESG risk management should consider the impact on the environmental, social and governance areas.

Potential negative impact

Greenwashing is a real risk from the point of view of investors, both professional and individual. This aspect is the main focus of financial authorities (in Poland, the Polish Financial Supervision Authority), which combat unfair greenwashing practices related primarily to financial investments, securities and green investments, etc. Consumer protection authorities (in Poland the President of the Office of Competition and Consumer Protection) are concerned about public claims made by entrepreneurs to attract customers.

In order to minimise the potential risk of infringement, a bank should first of all analyse its marketing campaigns, any public claims made in relation to its activities, the names and statements placed on the products sold, as well as its internal documentation to check whether any environmental declarations appear there. Any such claims and public statements should be true and verifiable. Internal procedures to prevent greenwashing (anti-greenwashing policy) and appropriate documentation for individual products and services that does not contain risky claims also serve this purpose. Care should also be taken to raise employee awareness through training. Instructions and procedures for dealing with possible proceedings (including inspections) initiated by the President of the Office of Competition and Consumer Protection may be necessary so that managers and employees know how to behave in such cases.

Santander Bank Polska S.A. has introduced internal guidelines 'Communication and advertising in the area of sustainability at Santander Bank Polska S.A.’. The document describes how information can be communicated, who is responsible for giving an opinion on particular documents and which units shall give their opinions.

Potential negative impact