The General Code of Conduct (GCC) is our catalog of ethical principles and standards of conduct that govern how all employees within the Bank behave, making it the lynchpin for our operations. It must be adopted by each of our employees in order to prevent any type of risk.
As part of our strategy to guarantee responsible and ethical operations, we organized a series of training sessions regarding GCC compliance and anti-corruption measures for all the Bank employees.
Furthermore, on November 19, 2021, we held a GCC training session for our Board Directors, in addition to offering them a series of courses on Diligent regarding compliance issues.
During 2021, we rolled out a number of campaigns to drive awareness of our GCC among all Bank employees:
The GCC is our highest standard for promoting transparent and honest operations among our employees, directors and Board Members. This document stipulates that all decisions and actions taken must only be in the best interest of Santander, without putting first vested interests or those of family members or other people involved in these operations, in areas related to the acquisition or leasing of goods and assets, transactions, and product and service contracts.
In the event of any complaints filed regarding infringements of the GCC, Compliance is the area at Santander that is responsible for receiving, identifying, analyzing, and registering this evidence and sending it to the Compliance Committee.
In order to promote ethical behavior in all Santander’s operations, we have implemented a multi-channel complaints channel that offers our employees the opportunity to make their voices heard anonymously in case of any irregularities that affect the proper functioning of the Bank. In addition, they have the possibility of seeking advice on ethical and lawful behavior, and organizational integrity.
This system is operated by an external supplier called EthicsGlobal, a specialist in complaint and report management. It allows us to increase the levels of trust among our employees, suppliers and ex-employees. All reports are handled autonomously and confidentially.
We safeguard all our employees through our Ethics Line Report Response Policy, in which we specifically outline the following: “Any act of reprisal or negative reaction to anyone who has filed a report is strictly prohibited.”
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In 2021, we continued bolstering our Ethics Line by including the Ethics Question option. This is available to any employee who has doubts about a situation they witnessed and who wants to know if this is a reportable offense, offering them access to the EthicsGlobal hotline to receive guidance about the protocols in place. This avoids a situation in which our employees do not file a report because of a lack of knowledge on how the system works or because they do not file the report correctly.
We also activated the Anonymous to the Company option, which means that employees can waive their right to anonymity with EthicsGlobal employees but not with the Bank. This ensures reports are not underestimated because of a lack of information.
We have reiterated our strong commitment to fighting any form of corruption and illegal practices, such as the misuse of public funds, bribery, payment of contributions and influence peddling, in the public or private sector. We have designed a number of guidelines that are included in our Corruption Prevention Policy that fully and comprehensively reject any corrupt practices through a zero-tolerance approach.
Our Corruption Prevention Policy, which is coordinated by Compliance and other committees, is the channel through which we can responsibly bolster our practices and operations and regulate anti-corruption measures.
During 2021, we offered training and provided information about our policies and procedures in our fight against corruption to:
As a banking institution, one of our priorities lies in preventing money laundering and terrorist financing. We have a System for the Prevention of Money Laundering and Terrorist Financing (PMLTF), which enables us to comply with a series of policies, guidelines, regulations, flows and controls in order to handle the management of fund origins.
This system is governed by the General Policy and Procedures Manual and is reviewed on an on-going basis to ensure compliance with domestic regulations. Furthermore, there is a risk and control certification program, which is implemented every six months.
We also have a Risk Assessment Methodology, the goal of which is to guarantee compliance with regulatory requirements at all levels of the Bank, in addition to adhering to industry best practices regarding PMLTF through a risk assessment process.