Disclosures in relation to specific circumstances (BP‑2)
- ESRS:
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Disclosures in relation to specific circumstancesBP-2Disclosures in relation to specific circumstances
Time Horizons
The time horizons for impacts, risks, and opportunities that reflect the expected effects on stakeholders and the environment, or the anticipated financial effects, are identified in accordance with ESRS 1 as follows:
- Short-term time horizon: a period of one year, corresponding to the reporting period of the financial statements.
- Medium-term time horizon: a period from one to five years. This time horizon focuses on achieving strategic operational and financial objectives, considering material sustainability-related risks and opportunities.
- Long-term time horizon: a period beyond five years. This horizon encompasses our long-term commitments and aspirations related to sustainability, including goals associated with energy transition, innovation, and social and environmental impacts.
Metrics based on estimates or characterised by high levels of uncertainty
The majority of metrics used in our reporting are based on actual data obtained from direct sources. In cases where full actual data is not available, estimates are applied to ensure the continuity and completeness of the reported information. These estimates are based on best industry methods and practices to reflect actual data as accurately as possible.

The following indicators are determined using estimation methods due to the lack of complete actual data:
- Electricity consumption: Estimates are applied for certain locations, such as Santander zones, offsite locations, and selected ATMs, where individual energy consumption data is unavailable.
- Thermal energy: Thermal energy consumption is estimated for locations without direct measurements, using available cost data and average unit prices.
- Electricity and thermal energy consumption in the final quarter of the reporting period: Estimates are used due to the lack of invoices confirming actual consumption, resulting from the timing of invoice issuance and delivery by energy providers. These estimates are based on consumption during the same period in the previous reporting year.
- Greenhouse gases emissions (”GHG”) linked to client activities: Most Scope 3 emissions are calculated using the Partnership for Carbon Accounting Financials (PCAF) methodology and are based on estimates, as access to actual data from clients is limited.
- Employee commuting (Scope 3): Emissions data related to employee commuting is estimated based on survey results, which account for the modes of transport employees use for commuting. Management Board Report on Santander Bank Polska Group Performance in 2024 (including Report on Santander Bank Polska S.A. Performance) 190
- Business travel (Scope 3): Emission metrics for business travel include both actual data (when available) and estimates, particularly for rail and bus travel, where average distances are applied.
- Number of beneficiaries of social initiatives: For social initiatives supported by multiple organizations (partners), the estimated number of beneficiaries attributable to the Group is proportional to our financial contribution to the initiative’s total budget. In the lack of tools to calculate the exact number of beneficiaries of an initiatives, a 30% cap is applied due to potential double counting of beneficiaries.
Detailed information on the methodology for determining the above indicators and the estimation methods applied is presented in the relevant sub-sections. To improve the accuracy of metrics based on indirect data, we undertake ongoing efforts to enhance data quality. We engage in dialogue with clients and other stakeholders to obtain more comprehensive actual data and to gradually reduce reliance on estimates. At the same time, we refine estimation methods by applying available methodologies. We systematically verify data from external entities, cross-check it with invoices and accounting records, and analyze deviations from historical data. This allows us to identify and correct inaccuracies on an ongoing basis.
For the assessment of negative and positive impacts, risks and opportunities, as well as the applied measurement of indicators related to the financing of specific client groups, more detailed information can be expected in the future. This takes into account, among other factors, that clients will provide data in their sustainability reports, and that EFRAG guidelines and new sectoral standards will be published. As a Group, we are making use of transitional provisions, including in the area of the value chain. The double materiality assessment process and the Statement include forward-looking information. Therefore, assumptions, judgments, forecasts, and projections have been applied regarding, among other things, climate risks, transition risks, and opportunities. As a result, forward-looking information reflects the Group’s current expectations and may be subject to uncertainty. It may also change, particularly due to economic developments, regulatory changes, market dynamics, or climate change.
Alignment with the EU Taxonomy
As part of the sustainability statement, in section ”Disclosures under Regulation no. 2020/852”), we disclose information prepared in accordance with Regulation (EU) 2020/852 of the European Parliament and of the Council (hereinafter: ”EU Taxonomy”).
Incorporation by reference
In this statement, we refer to matters described in other sections of the Management Board Report or in other documents of the Group. This includes topics such as:
- Detailed information about the experience of Management Board Members, which can be found in Chapter XII ”Statement on corporate governance in 2024”,
- Information on business segments in terms of customer profiles and product lines, which can be found in Chapter VIII ”Business development in 2024”.
- Detailed information on actions taken in the area of own workforce can be found in Chapter V ”Relations with employees” and Chapter IV ”Development strategy”. Detailed information on actions taken in the area of consumers and end users can be found in Chapter VI ”Relations with customers” and Chapter VIII ”Business development in 2024”. Detailed information on actions taken in the area of affected communities can be found in Chapter IV ”Development strategy”.
Application of phased-in disclosure requirements
The table below presents disclosures resulting from the phased-in disclosure requirements. By applying the provisions of the ESRS in this regard, the Group does not disclose the information listed in the table below in this statement.
* Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC, and Directive 2013/34/EU as regards corporate sustainability reporting.
**Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU of the European Parliament and of the Council with regard to sustainability reporting standards.