2013 Annual Report

EMPREGO 178 Annual Report 2013 PRODUCT AND SERVICE LABELING Materiality and Responsibility Product and service labeling, under the responsibility of Retail Vice-President's Office, is a relevant topic to Santander Brazil due to the influence it has on the quality of business relations, the correct use of the Bank's product portfolio and on financial results. Furthermore, this subject is associated with a variety of rules and regulations. - Impacts The clear labeling of products and services enables clients to make proper use of the Bank's product portfolio, which reduces the chance for the client to become overindebted and for the Organization to incur financial losses. Moreover, this reduces risk in relation to image, reputation and legal proceedings. Policies and Commitments The Bank operates in accordance with the following policies for the management of risks in product marketing: Code of Ethics; Policy for the Marketing of Products and Services; Methodology for the Analysis of Investor Profiles - Suitability; Derivatives Suitability Policy; Investor Profile Assessment. The benchmarks for these policies are: Consumer Defense Code (external); Banking Self-Regulation Code (FEBRABAN), Anbima Codes and other standards established by the Regulatory Entities (the Brazilian Central Bank, CVM, SUSEP). G4-PR3 Assessment Mechanisms In order to further clarify the labeling of products and services, the Bank performs activities on financial education, which help clients gain a better understanding of the portfolio. With this in mind, the Bank invests in activities to train the Retail business team in financial guidance. The effectiveness of this training is monitored via quarterly reports on the performance in the training programs. Activities in relation to the risk management and product marketing are monitored in accordance with the Corporate Policy for reputational risk management, derived from product and service marketing. Reports are submitted every four months to the Local Marketing Committee and the Corporate Reputational Risk Management Office. Indicators Consolidation Type of product and service information required by the organization's procedures for product and service information and labeling, and the rate of significant products and service categories subject to such information requirements G4-PR3 The service is in compliance with the standards in force and whenever necessary the Bank makes adjustments to internal procedures in order to keep them updated. Information on products in relation to the individual client segments is made available to clients by means of their respective agreements. Banking service fees are published in the Services Table, available for consultation at the branches and on the Santander website. Information in relation to the Corporate segment is included in the respective agreement documents, when the original copies are submitted to the client. Information on products offered via the Stock Market (securities) is made available by means of leaflets disclosed within the scope of the products on offer. Total number of incidents of non-compliance with regulations and voluntary codes concerning product and service information and labeling, by type of outcomes G4-PR4 21 public civil lawsuits were filed against Santander in connection with products in 2013, eleven of which resulted in an injunction being granted and an expected assessment for non-compliance; eight where no fine is expected; one with an injunction and an expected fine, but suspended due to the filing of an interlocutory appeal; and one lawsuit with a signed agreement. None of the 21 lawsuits involves the execution/obligation of the payment of an immediate fine. There are no cases of violation of voluntary codes. Results of client satisfaction surveys G4-PR5 The Bank monitors the client satisfaction by means of surveys answered by regular channel users (branches, ATMs, call centers, Internet and credit cards). The surveys have been conducted three times a year since 2009. The sample is comprised of around 9,000 interviews represented by all types of client profile, income levels and geographic location. The outcomes for May and August 2013 show the challenge for the Bank to reach the desired satisfaction level continues, but illustrates positive progress. Based on the diagnosis, efforts will now be focused on four main topics: Availability, Service, Speed and Efficiency and the High-Income Sector. 179

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