Annual Integrated Report
86
National and international action guidelines
To ensure the highest security standards, we adhere to industry-
leading protocols. Our operations are currently aligned with the
following:
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⚫ the Brazilian Central Bank's cyber security resolution
⚫ the NIST-CSF cyber security framework, which is regarded as
the most up-to-date and pragmatic on the market
ISO-27001, which outlines best practices for information
security management
⚫ the global corporate cyber security policies issued by the
Santander Group's headquarter
Based on these references, we have established best practices
in a global security program, which is monitored by independent
units within the organization.
On a local level, the operations of these units are subject to our
Corporate Governance practices. Its composition includes the
Operational Risks and Audit departments, which serve as the
second and third lines of defense, respectively.
As a regulated and publicly traded company, our security
processes are also reviewed by independent auditors and the
Brazilian Central Bank itself.
Internal structure
Our primary defense structure is Cyber Security & Anti-Fraud,
which centralizes technology risk management. This hub
comprises the Cyber Security, Fraud Prevention, and GRC
(Governance, Risk and Compliance) units.
We are also supported by the Security Operations Center, which
is based at the Santander Group's headquarters in Madrid. This
division is responsible for formulating monitoring actions for all
Santander units.
Additionally, we have a local cyber security operation entirely
dedicated to security practices and disciplines. Its activities
encompass technical architecture, data center infrastructure
security, system development, and incident response.
Awareness and training
Every year, we organize training sessions and awareness
strategies so that cyber risk management and information
security are ingrained in the daily routines of our employees,
interns, and customers.
In 2022 alone, our online communications, featuring valuable
insights for customers on how to protect themselves against
digital scams and attacks, garnered over 73 million impressions
across more than 15 channels.
We constantly invest in security and technology solutions,
refining training and awareness initiatives for employees,
customers, and society at large.
See below some of the initiatives undertaken last year.
• Launch of Cyber Defenders, a biannual awareness pathway
for executives, aimed at decentralizing cyber security
knowledge within the organization.
.
Pathway guidance for teams whose activities have a high
degree of criticality, such as Swift payment operators, IT
developers, etc.
•
Security campaigns on social media for customers and
society, featuring influencers
• Launch of Cyber Heroes for customers, a quick, free, and
accessible course offering tips against fraud and scams
• Release of the Security Champions Program, a Cyber Security
training initiative for the entire FIRST team, with a focus on
secure development
• Periodic phishing tests for employees, with the goal of
equipping them with the skills to recognize cyber attacks
•
Revamping of our security website, featuring exclusive
content on safeguarding oneself against scams.
Security-focused initiatives
We devised fresh initiatives throughout 2022 to reinforce the
security of our protocols. The following are a few of them:
→ Facial Biometrics: we deployed this technology, which
enables robust authentication, to provide our customers with
the convenience of conducting risk transactions via electronic
channels.
→ Information leakage prevention: we strengthened our efforts
in this field through the implementation of an information
classification process, as well as the establishment of rules for
information protection and compliance with local and global
regulations
→ Supplier Cyber Security Risk Management: we assessed
the maturity of preventive controls (detection and response)
implemented by companies providing the Bank with critical
services. In addition, specific assessments focusing on the
handling of emerging threats, such as ransomware, and the
monitoring of improvement plans have been conducted.
General Data Protection Law ("LGPD")
The General Data Protection Law ("LGPD"), which has been in
effect since 2020, sets forth regulations for the processing of
personal data, including by private companies. We acknowledge
the importance of this matter and accord it high priority.
Our LGPD compliance program is spearheaded by a specialized
division dedicated to data protection and privacy, encompassing
all data processing activities involving the personal information
of our customers, former customers, and employees. This
team is responsible for all governance processes pertaining to
the subject matter and invests in technologies and processes
that increase transparency to data subjects and enhance data
security against cyber threats. Additionally, this department
works to optimize internal processes that promote compliance
with privacy concepts across all our operations.
In addition to structuring mechanisms that ensure compliance
with the rights of data subjects as provided for in the LGPD,
we have strengthened our culture regarding this matter by
establishing a robust governance framework that encompasses
all levels of the organization, including affiliated companies.
Annual Integrated Report
Table of Contents
[2-6; 2-23] Material topic: Culture, Conduct, and Responsible
SUPPLIER
RELATIONSHIP
Introduction | Value Creation | Economic Performance | Environmental | Social | Governance | Appendices
Supplier management and control
1 Pre-Engagement
Our engagement with suppliers involves a rigorous assessment
process at all stages, including competition, approval, and
contract duration. To this end, we adhere to the guiding
principles of the United Nations Global Compact as a foundation
for our approach.
One of the internal instruments used to ensure that these
commitments are met is the Supplier Code of Conduct, which
governs all principles that must be respected in our business
relationships.
We also follow the PRSAC, the Outsourcing and Third-Party
Agreements Corporate Framework, the Supplier Approval
Policy, as well as anti-corruption and money laundering
prevention regulations.
―
We categorize the range of services that a supplier can provide
us based on their inherent risk level critical, high, medium,
low, and risk-free and strive to ascertain this risk prior to the
procurement/renewal procedure, utilizing a risk assessment
calculator.
-
In this process, we evaluate the service's characteristics, data
access and/or processing, level of data confidentiality, and
system accessibility, among other factors.
Within our organizational structure, the service manager
is primarily responsible for ensuring compliance with all
requirements specified in the key supplier management and
control processes, as depicted in the adjacent figure:
*Learn more about the Supplier Code of Conduct and the PRSAC on our website
[308-1, 414-1]
Procurement requirements
The procurement process for all our suppliers contains
contractual provisions that stipulate:
⚫ good social and environmental practices
⚫ defense of human rights (such as preventing child and forced
labor)
⚫ guidelines against moral and sexual harassment and combating
corruption
⚫ legal, fiscal, tax, and reputational suitability
For the approval of suppliers deemed relevant, we undertake
more thorough assessments of their inherent risks, which
encompass factors such as business continuity, cyber security,
physical security, facilities, and data protection.
At the end of 2022, we had active contracts with 1,802 suppliers,
of which 6% were regarded as more relevant, based on their
activities and predefined risk criteria.
Our suppliers engage in a range of activities, including call center,
debt collection, telemarketing, business process outsourcing
("BPO") for real estate and financial credit, secure transportation
of valuables, and document archiving.
5 Risk Assessment
2 Negotiation
6 Monitoring
Company
Approval
31
4 Formalization
-7 | Termination/
Renewal
In 2022, we expanded our engagement with suppliers
regarding ESG issues. We launched a series of initiatives aimed
at promoting engagement, awareness, and communication,
including webinars on climate change. These efforts are
designed to assist our partners in their transition to a low-
carbon economy, while considering the risks and opportunities
arising from the social, environmental, and climate impacts of
their businesses.
Furthermore, as part of a pilot project, we assessed 89
significant suppliers and administered an ESG criteria
questionnaire. Out of the total, 46% achieved the desired
minimum level of compliance, while the remaining suppliers
were provided with recommendations for developing an
action plan for implementation in 2023.
Monitoring
We conduct regular monitoring of our suppliers, during
which we evaluate a variety of factors, such as the labor, tax,
fiscal, and reputational situation, significant events related
to operational risks, involvement with forced labor, and
penalties imposed by the public authorities.
Our Supplier Forum is responsible for deliberating on each case
and overseeing the implementation of any action plans related
to identified opportunities for improvement. Additionally,
this body is tasked with ensuring the implementation of
the Corporate Outsourcing Framework and Third-Party
Agreements, as well as policies and regulations of regulatory
agencies.
Diversity and inclusion
Since 2020, newly drafted contracts and amendments have
incorporated a specific clause designed to reinforce the
respect and promotion of diversity and inclusion, as well as
the commitment to train all service providers.
We have also produced an e-book on this subject, consolidating
fundamental concepts and behaviors that are minimally
required by Santander and its affiliates.
Climate management
Since 2017, when we joined the CDP Supply Chain, we have
invited our suppliers to provide information pertaining to their
climate management. In 2022, 34% of them reported emissions
data, as well as the risks and opportunities associated with
this subject matter for their respective businesses.
Santander
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