Policies related to own workforce (S1‑1)

Due to the early stage of work on the transition plan, we are currently not identifying impacts on employees resulting from transformation activities. Analysis of such impacts will be carried out in the later stages of the transition plan preparation. As the Group, we did not identify material negative impacts on our employee resources – due to the nature of our business, the risk of occurrence of things such as child labour, forced labour or serious industrial accidents is really low.

The primary and overarching document we use to achieve our strategic objectives in the employee is the ”Human Resources Management Corporate Framework’’, which outlines the process of managing the ’employee life cycle’ within the organization. This life cycle includes recruitment, hiring, adaptation, training, development, goal setting, performance appraisal, remuneration, succession, and, where appropriate, termination of employment.

In addition, the management of impacts on own workforce is governed by various policies, with key ones applying across the Group. Disclosures in the Own Workforce section (ESRS S1) refer to all employee resources of the Group, with a particular focus on employees under employment contracts. Nonetheless, it is worth emphasising that the Group’s policies, in particular those related to human rights, ethical conduct, respect, inclusiveness and diversity, also extend to other categories of non-employees who are part of own workforce. This includes the self-employed, employees employed by employment agencies and those working under civil law contracts. In this way, as the Group, we ensure that all team members, regardless of their form of employment, are treated with equal care and respect. These policies promote decent working conditions, equal treatment and the creation of a working environment based on ethical values.

Policies that are confidential and intended for internal use are available to employees via the intranet. Policies that are public in nature are made available through the Bank and the Group Companies’ websites, which ensures transparency and access to information. Each policy has an assigned owner within each of the Group Companies, who is responsible for its implementation and the implementation of the obligations according to its regulation.

The implementation of each policy is described in detail in sections related to the respective areas. Responsibility for implementing the policies usually lies with the Management Board, unless otherwise stated in the content.

The respect and protection of human rights in the Group are governed by, among other things, the ”Responsible Banking and Sustainability Policy”. The policy emphasises the relevance of our commitments to stakeholders and explain processes of applying social, environmental and corporate governance standards in accordance with the ”Responsible Banking Model”. The policy sets out, among other things, the principles, commitments, objectives and strategy in relation to employees and other stakeholders, as well as to social issues, diversity, respect for human rights and the prevention of illegal activities (including child labour, forced labour and human trafficking).

As part of our activities, we apply mechanisms aimed at preventing human rights violations (including the equal treatment policy, training on ethics and compliance issues – more in the section ‘Preventive and educational activities’). In addition, the Group has whistleblowing mechanisms in place – for details, see the section entitled ‘Reporting violations’.

Delivering on our 2024-2026 strategy „We Help You Achieve More”, we have developed an integrated Total Experience (TX) approach as part of our Total Experience (TX) direction. Adopting the employee experience (EX) management model, at Santander Bank Polska S.A. we have created an Employee Experience Competence Centre – empowered directly under the Management Board Member in charge of the Business Partnerships Division.

The Bank has a ”Health, Safety and Wellbeing Policy”, which sets out the guidelines and standards to be followed to protect health and life and ensure the highest levels of safety and wellbeing for employees. It also includes the promotion of healthy lifestyles and the creation of long-term value for employees and local communities. Working time and work-life balance issues are also regulated in the ”Labour regulations”. The Group companies do not have health and safety policies in place, but employees are covered by the company’s internal health and safety management system.

Each Group Company provides safe and hygienic workplaces – all our employees (100%) are covered by the occupational health and safety system. There are Social Labour Inspectors and a Health and Safety Committee within our structures. The working environment at the Bank is monitored by the Health, Safety and Wellbeing Office, which conducts regular audits and reviews of occupational risk assessments for individual positions. Among other things, we take into account factors affecting physical safety, work ergonomics issues, as well as psycho-social risks and hazards associated with, for example, remote working. When updating the risk assessment, the experts take into account information on previous accidents as well as current legislation. We consult with employees and professional organisations. In special situations, we set up a crisis management team.

The process of assessing occupational risk for individual positions in the Group consists of five elements.:

• Gathering information,
• Identifying risks,
• Estimating the probability of the hazard occurrence and its consequences,
• Determining risk acceptability according to the PN-N-18002-2011 standard,
• Monitoring and possible corrective action.

Within the Group, we verify and improve the correct operation of the health and safety management system. Specialists from the health and safety management units continuously enhance their qualifications at training courses, conferences and industry meetings.

All our employees receive health and safety training. Their scope and frequency are determined by legislation, changing external circumstances and needs reported by employees. Information on situations that pose a threat to the life or health of employees at the Bank is reported to the supervisor and to the staff of the Health, Safety and Wellbeing Office directly, by email, via an electronic form or phone. The effectiveness of conducted health and safety training is systematically verified through, among other things, health and safety audits, interviews with employees, analysis of accident incidents and post-training surveys.

In addition, we have implemented Business Continuity Plans throughout the Group, which consist of procedures and information to ensure business continuity in the event of an emergency. These allow the most important processes to be restored in the shortest possible time while ensuring an acceptable scope of operation for the Group.

We also care about the health and safety of employees with disabilities. At the Bank, we have been implementing the ‘Differently Abled’ project for several years, which aims to create a diverse working environment. We are preparing the organisation to employ people with disabilities (complying with workplace standards and regulations, allowing employees with disabilities to request full remote work if the nature of the work permits, and granting an additional two days off). An employee with a disability may also benefit from a one-time financial allowance.

The Group has a ”Training and Development Policy”, which promotes the management of learning and knowledge transfer, as well as innovation and development of skills needed by employees now and in the future. The policy provides for the preparation of training plans tailored to the strategic needs of the Group and ensures that all employees have access to training activities that enable them to perform their duties effectively and develop their competencies.