Processes to remediate negative impacts and channels for own workforce to raise concerns (S1‑3)

In our Group, we prioritise the wellbeing of our employees and strive to create a working environment that is transparent, safe and open to dialogue. Aware of the potential challenges in a dynamic financial environment, we implemented comprehensive procedures to identify, report and effectively address concerns about working conditions.

Our Group has a ”Whistleblowing Policy” and an ”Internal Reporting Procedure (whistleblower protection)”, which are overseen at the Bank by the Compliance Department. In accordance with these documents, we operate a comprehensive system that enables employees to report irregularities such as violations of the law, internal procedures or ethical standards.

When a violation in the area of employee relations is confirmed, we take action to eliminate negative behaviour. Responsibility for compliance with the regulations rests with all employees, supported by appropriate communication and educational activities (an example is the mandatory e-learning course 'Show respect – Be Fair’). The Bank Management Board is responsible for the adequacy and effectiveness of procedures for employees to report violations.

The bank maintains a register of whistleblowing reports, which includes all reports received through whistleblowing channels. This allows for the analysis of received reports, taking actions in response to them and formulating development recommendations at the organisation-wide level.

Information on breach reporting channels is widely available on the intranet. In addition, we promote awareness of the whistleblowing channels (through elearning courses and articles on the intranet).

As the Group, we provide employees with the opportunity to report violations both anonymously and openly, using channels such as:

The system ensures the anonymity of breaches reporting, the protection of the reporter’s identity and the possibility to provide detailed information on violations, such as descriptions of events, evidence or other documents. The system has mechanisms in place to ensure the protection of employees making notifications:

• confidentiality – the applicant’s data are protected at every stage,
• no retaliation – no retaliation against persons making reports,
• anonymity – the possibility to submit reports without revealing one’s identity.

The whistleblowing channels indicated above are intended in particular for persons employed by the Bank under an employment contract or a civil law contract, including top management and members of the Bank’s management and supervisory bodies, Group Companies have their own reporting channels.

Employees can also use a relationship helpline for consultation on difficult incidents in employee relations area. The Group also has trade unions to which employees can report problems and, as the Group, we engage in dialogue with them and respond to reported issues.

The management of the whistleblowing channel at the Bank is coordinated by the Compliance Unit, and in Group’s companies it is handled by dedicated units. In order to ensure that the whistleblowing processes operate as intended by our regulations, we evaluate the functioning of the whistleblowing channels by periodic internal audits. In addition, they are subject to regular external audits. At Santander Bank Polska, the Ethics and Relationships Office analyses employee whistleblowing in the area of employee relations and, on the basis of this, makes recommendations on the preventive measures needed. For example, the Office regularly creates and makes available to managers the educational material 'Diagnosis of the working environment’, in which it shares the conclusions of its investigations and provides guidance on how to manage difficult employee situations.