Annual Integrated Report

118 Content 201-2 Financial impli- cations and other risks and opportunities due to climate change Culture, Conduct, and Responsible Banking 3-3 Management of mate- rial topics Details Annual Integrated Report Table of Contents Introduction Value Creation | Economic Performance | Environmental Social Governance Appendices Where to find the indicator Pages 30, 31, and 82 Reasons for omission Information unavailable. The finan- cial implications of risk or opportuni- ty, as well as the costs of measures taken, are currently being assessed. (items a.iii and v) The dissemination of our purpose and ethical conduct generates tangible positive impacts for a bank that is responsible towards our clients and society. We manage these impacts through online courses, employee participation in social and environmental initiatives, monitoring of the whistleblowing channel, among other measures. To ensure continuous improvement, our policies undergo annual reviews. Pages 9, 22, 23, 33, 46 to 55, 60 to 69, 76 to 82, 87 Information not applicable. Given that the subject matter pertains to the dissemination of culture, con- duct, and responsible banking, there are no actual or potential negative impacts. (items b., d.i.,ii.) 205-1 Operations asses- sed for risks related to corruption a. Total number and percentage of operations assessed for corruption-related risks: 1,091 b. 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-corrup- tion policies and proce- dures 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. Pages 77 and 78 Page 79 Confidential information. Despi- te providing the total number of operations assessed by category, we refrain from disclosing the percenta- ge of operations assessed for corrup- tion-related risks, as this constitutes confidential information. 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 119

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