Ethical relations - Santander

Ethical relations

The transparency we want to see in the country begins with the way we conduct our business.

99.2% of our 48,000 employees had completed a course in Prevention and Combating Corruption by the end of 2018.

We have the “Canal Aberto” (Open Channel), which receives reports about allegedly unlawful acts and violations of Santander's policies in a confidential manner.

What we do

We have policies, regulations, an Ethics and Compliance Committee and other initiatives that guide the work of our executives and employees. We fight corruption and encourage ethics in the relationships between employees and also in external relationships.

The Code of Ethical Conduct sets out guidelines and practices that help protect our reputation and guarantee the integrity of our actions, promoting an environment free of discrimination, which values diversity, respect, transparency, responsibility and integrity, curbing any other practice that violates ethics, human rights and legislation. We reinforce this position with internal communication practices and training, and we also have channels so that people can report eventual problems freely and in a confidential way.

Main initiatives

Labor relations

We respect the labor legislation and the internal documents that guide the actions of our employees and trainees, among them the Code of Ethical Conduct. Reinforced through the internal communication and training provided by Academia Santander, the code helped to spread the Santander culture and allowed more openness to enquiries and clarification of doubt. Based on practical examples of expected behaviors and those that are not accepted, the document, in accessible language, provides the five fundamental principles of Santander's conduct: integrity, transparency, responsibility, diversity and respect.

Respect for free trade union association and the right to collective negotiation

Santander recognizes the employees' right to freedom of association, in accordance with current legislation and collective bargaining. We are signatories of the Collective Convention of the bank clerks’ category and we participate actively in the discussion, as a permanent member of the Employer Negotiation Committee. Our Collective Bargaining Agreement establishes the conditions for the free trade union association of employees. We believe that, in this way, it is possible to maintain an agenda of open dialogue with the representatives of our employees.

Combating harassment and discrimination

We have a program – “Santander against moral harassment in labor relations” – which informs and guides our employees about this issue through initiatives such as:
  • Awareness and orientation lectures for managers of São Paulo (the city where our headquarters is located) and the wider state.
  • Insertion of the issue in the institutional program of management training.
  • Disclosure of a digital guidebook through the company intranet about the subject and publication of the agreement signed by the Bank and the Public Labor Ministry.
  • Distribution of paper booklets and an online course for all employees.
  • Specific training for employees and managers.

Combating corruption

Based on internal and external rules, including the Anti-Corruption Law (12.846/13), we adopted a series of policies to regulate the issue:
 
  • Anti-Corruption Policy, which is periodically reviewed and establishes monitoring procedures for the prevention of corruption internally and in external relationships. 
  • Procedure for conduct related to anti-corruption.
  • Code of Ethical Conduct. 
  • Prevention of Money Laundering. 
  • Supplier Code of Conduct, which has points based on the principles of the United Nations Global Pact.
  • Presents, Promotional Gifts and Entertainment. 
  • Donation Policy.
  • Stakeholder Engagement Policy.
  • Code of Conduct in Securities Markets. 
  • Criminal Risk Prevention Policy - Corporate Defense.
  • Antitrust Policy - Introduction of the Competition Law, in compliance with the Brazilian Competition Defense Legislation.
  • Conduct Risk in the Marketing of Products and Services.

To ensure alignment around these regulations, we have processes to guide and support employees who have doubts regarding conduct. The issue is also covered extensively through lectures, meetings, in-person and distance training. Compulsory for all employees and trainees, the online course on “Preventing and Combating Corruption” was attended, between 2015 and 2018, by 99.2% of the employees.

The issue is reinforced by internal communication. In 2018, 100% of employees received communications giving information on the Bank's anti-corruption policies and procedures.

In addition to the work on awareness, the areas related to the public sector, contracting suppliers and granting sponsorships to the public and private sectors have the analysis process performed by several areas, including Compliance, which seeks to identify possible risks related to corruption in these operations.

Canal Aberto (Open Channel) Santander

The Canal Aberto Santander receives complaints of situations with indications of unlawfulness of any nature, regarding the activities carried out by Santander or associated companies, breaches of its Code of Ethical Conduct and/or internal rules received from employees, trainees, coworkers, customers, users of products and services, partners or suppliers. In all cases, the confidentiality and the secrecy of the information received is ensured by the areas involved in the handling of the incidents. All records received by the Canal Aberto are evaluated and forwarded to those responsible for the verification and decision on the adoption of necessary measures, including those related to human rights, diversity, corruption, accounting and auditing. Get in touch: canalaberto@santander.com.br, telephone 0800 723 4472 (option 4).