General Code of Conduct (GCC)

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:

• • Internal GCC communication campaigns.
• • Publication of articles on the intranet news portal.
• • Short and accessible messages for all employees using the
  #CultivateCompliance hashtag.
• • Focus on using the Ethics Line as the official channel to file a complaint regarding GCC non-compliance.

Conflicts of Interest

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 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.

Money Laundering Prevention

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.