2013 Annual Report

EMPREGO 166 Annual Report 2013 GRIEVANCE AND COMPLAINT MECHANISMS Materiality and Responsibility Labor and human rights-related grievances and complaints involving employees, clients and suppliers are the responsibility of the Compliance, SAC (Client Support Service) and Ombudsman departments, in addition to the Supplier Management department, which deal with complaints submitted by each of these audiences respectively. This issue is important to the Bank as it involves major legal and social implications. The reporting channels monitor cases of abuse in relation to labor and human rights-related issues involving employees, third parties and suppliers. In the case of the mechanism geared to employees, the channel builds trust and engagement due to transparent processes, dialogue and mediation between the parties; it provides solutions for problems by means of the close monitoring of managers and guidance in relation to conduct; in addition to strengthening the principles of good management by managers and administrators. Positive and negative impacts - Grievance and complaint mechanisms for labor practices and human rights issues help create an internal environment geared to employee satisfaction and enhanced personnel engagement levels. Furthermore, this system helps maintain healthy supplier and client relations. Conversely, the absence of structured channels and processes leads to the spread of undesired behavior such as segregation and discrimination and all the implications thereof (poor productivity, sick leave and functional lack of interest). Control and assessment mechanisms The Bank assesses the cases dealt with on a regular basis, identifies the main occurrences; acts directly in the impacted areas and with the managers involved with the aim of implementing plans of action to reduce and eliminate such occurrences and reporting the problems to the senior management. The engagement survey filled out by employees also addresses this issue. Any employee or intern who becomes aware of any act which is supposedly illicit or which fails to comply with the guidelines of the Code of Ethics or the internal policies in force should report the fact to the Compliance Office via the Santander Reporting Channel, launched in 2011. In addition to the Compliance department, the Human Resources, Special Occurrences Office (the SOE) and Legal department also deal with reporting. Santander's clients, investors and suppliers can report via their own channels. Suppliers, for example, should access the Bank's website and go to the Fale Conosco section on the Fornecedores page. Clients and investors should report incidents to the SAC (Client Support Service) and the Ombudsman department using the means available, including the telephone, e-mail or letter (please see the list of channels on page 138 of the Annual Report). These allegations are dealt with and monitored by the areas responsible for the issue involved until its conclusion. The information is processed in total confidentiality and reports may be registered anonymously. Training - Employee and manager awareness is conducted by means of meetings, integration training, lectures and the web-based course on Codes of Ethics and other associated topics such as moral harassment and human rights. Identification - The records of all the complaints received are filed in the system; reporting which requires investigation are forwarded to the Human Resources or Special Occurrences Office (SOE). 167

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