Processes for engaging with consumers and end-users about impacts (S4‑2; S4‑3)

The cooperation with customers in our Group is regulated by the ”Customer Experience Management (CX) Policy”, which sets out the rules for diagnosing customer needs, improving their experience, as well as monitoring and reporting progress. The Management Board is responsible for the implementation and execution of this policy, but the operational responsibility for individual initiatives is decentralised.

To manage customer impact, we want to understand their needs and the quality of the experience we provide. The diagnosis of customer needs is carried out through various forms of information collection, which we use to improve the quality of our services. Sources of information include:

All these activities are aimed at ongoing monitoring and adapting the Group’s products and services to the needs of our customers. Customers are involved in the various stages of product and service design – exploration, design, testing, and monitoring. We ask for customer opinions as part of ongoing research (e.g. in relational or benchmarking research) and research related to specific initiatives. We make the results of the research available to employees, including in the form of the „Voice of the Customer” dashboard, reports, databases and repositories, webinars and newsletters, along with actions recommended actions. In addition, the Bank implemented the research and design standard „Compass” explaining how and at which points along the design path research should be conducted.

We strive to ensure that all our products and services benefit consumers and end-users, but we recognise that not all activities or processes are without the risk of negative impacts. Therefore, within the Group, we pay particular attention to providing our customers with easy access to effective mechanisms for reporting concerns and complaints, as well as transparent remedial procedures.

In July 2024, the Bank implemented the „Policy for handling complaints, inquiries and cause analysis”, which covers the receipt of complaints, distribution of tasks between units, evaluation of complaints, communication with customers, monitoring request, inspections and analysis of the reasons for complaints. The compliance unit is responsible for interpreting the policy, and the Management Board for its approval.

All Group companies offer contact channels enabling consumers to raise concerns and obtain answers quickly and in accordance with the standards of customer service. Detailed information on complaint procedures and available channels for reporting concerns is available on the websites of each Group company. The channels for accepting and investigating complaints are described in the terms and conditions of individual products (and for loans, in the loan agreements). These are for instance:

In 2024, the Bank continued its efforts to shorten the response time to complaints and improve the quality of communication. Thanks to automation, simple cases are resolved faster, which streamlines the service process. Responses to complaints are prepared in an accessible, understandable way, free from banking jargon – in accordance with accepted simple language standard. If the complaint is not accepted, the Bank informs customers about the appeal process – internally to the Customer Ombudsman, or to external institutions. At the Bank, all customer reports are registered and monitored in the Bank’s internal complaint system. The system enables a thorough analysis of notifications, response time and effectiveness of the actions taken. This allows us to identify areas for improvement. To ensure the effectiveness of the process, we analyse complaint trends and incidents that cause an increase in the number of complaints. This information is reported quarterly to the Management Board and the Supervisory Board and discussed once a year at the meetings of the Management Board and the Audit and Compliance Committee.

We work to provide remedies when we identify a negative impact on customers. The Customer Ombudsman’s Office has a key role in this regard, dealing with more complex cases, including the third and subsequent complaint on the same issue. The Office also responds to reports from regulators and institutions, such as the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego), the three or more complaints Financial Ombudsman (Rzecznik Finansowy) or the Banking Arbitrator (Arbiter Bankowy) hen a customer’s complaint is accepted as justified, we reimburse the amount charged.

We provide that our complaint process is in line with the Group’s customer service standards – we try to ensure that customers trust the channels for reporting breaches and guarantee that there is no retaliation.

The average complaint response time for our Group is calculated as a weighted average of the number of days it takes to process a complaint, weighted by the total number of complaints received from consumers and end users during the reporting period. The complaints concerned various areas of activity – depending on the Group company-in the Bank, the most frequent issues were related to: fees and commissions (including account maintenance fees and card fees), fraudulent transactions and ATM transactions. At Santander Consumer Bank, complaints most often concerned provisions of loan agreements, while other Group’s companies were mainly concerned with issues related to insurance and fee calculation processes.