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Annual Integrated Report

122 Content ESG Culture Details Annual Integrated Report Table of Contents Introduction Value Creation | Economic Performance | Environmental Social Governance Appendices 3-3 Management of mate- rial topics The dissemination of sustainability within the Bank is an integral component of our ESG Culture plan, which encompasses three primary areas of focus that yield tangible positive impacts: education, communication, and engagement. We mitigate the impacts through online courses and employee participation in social and environmental initiatives. Our commitment to developing our professionals is outlined in our PRSAC, encouraging them to incorporate social, environmental, and climate practices. In 2022, the ESG Culture dissemination goals were achieved. Santander Academy integrated ESG as one of its core areas of strategic knowledge. The ESG Culture has become a recurring initiative, with regular reporting to senior leadership. 205-1 Operations asses- sed for risks related to corruption Total number and percentage of operations assessed for corruption- related risks: 1,091 Significant corruption-related risks identified: 22 (This figure includes unfavorable opinions, following a thorough analysis by the Compliance team, pertaining to Anti-Corruption Clauses and Suppliers, in cases that demonstrate a correlation with corruption). 205-2 Communication and training about anti-corruption policies and procedures Santander's anti-corruption procedures and policies were communicated to 100% of employees in 2022 via bulletins, mandatory online courses and policies, and the code of ethical conduct. Likewise, all governance members received the requisite information and training. Furthermore, all business partners are informed about procedures and policies related to this topic. Our policy and code of conduct are also accessible to all audiences via our Investor Relations portal. Where to find the indicator Reasons for omission Pages 9, 22, 23, 46, 49 to 53, 60 to 69 Pages 77 and 78 Page 79 Information not applicable. Given that the topic refers to disseminating the ESG culture among our audien- ces, there are no tangible or potential negative impacts. (items b., d.i., ii.) Information not applicable. Gi- ven that 100% of employees and high-level governance members are apprised and trained on procedures and policies related to anti-corrup- tion measures, and business partners are also informed on the subject, we do not publish data by functional category and region (items a, b, c, d). Incomplete information. Given that we have disclosed the percentage of employees who have received trai- ning in anti-corruption and non-dis- crimination, we will not publish the data categorized by functional category and region. (item e). Santander 123
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