2013 Annual Report
ANTI-CORRUPTION
Policies and Commitments
The Bank has the following policies in our efforts against
corruption: Action against Corruption and Bribery; Money
Laundering Prevention, Conflict of Interest in the Commercial
Network; Relationship with Suppliers; Presents, Gifts &
Entertainment; Transactions with Related Parties; Institutional
Sponsoring and Commercial Network Sponsoring, including
the Code of Ethics, the Code of Conduct in the Stock
Markets and the Santander Reporting Channel. These
policies and channels are based on internal and external
standards, including the Anti-Corruption Act 12.846/13.
In 2013 the Bank adhered to the Empresa Pró-Ética Register,
maintained by the Federal Government Comptroller-General,
i.e., the Controladoria Geral da União (CGU), and the Pacto
Empresarial para Integridade e Contra a Corrupção by the
Instituto Ethos.
Assessment Mechanisms
In order to monitor management actions while increasing
their effectiveness, the Bank strives for business results under
ethical principles and good corporate governance. The areas
involved in this process perform a survey of any such actions,
their impacts on business and the improvement of process
prioritization criteria. The outcomes are communicated to the
relevant teams and in case of any circumstances that warrant
process improvement they are discussed with the relevant
department heads.
The Bank ensures that our internal policies, business principles
and values are followed by our employees via communications
and training programs.
By the end of 2013 we were not aware of any corruption-
related facts involving Santander.
Communication and training on anti-corruption policies and procedures G4-SO4
The corruption topic is dealt with in lectures, meetings, classroom training sessions and in web-based courses,
including code of ethics, money laundering prevention, information security and prevention of fraud. In 2013,
34,386 people (69% of employees) underwent these training sessions. In addition, all employees were made
aware of the Anticorruption Policy and the update of the new Code of Ethics, which was validated by both
the Executive Committee and the Board of Directors.
Number of employees trained in anti-corruption policies and procedures, by employee category G4-S04
Operations
Administrative
TRAINING BREAKDOWN BY POSITION LEVEL
# Employees
trained
# Employees
per category
%
13,655
18,114
75.4
16,881
24,954
67.6
3,541
5,735
61.7
246
616
39.9
Executive Officers
Grand Total
63
202
31.2
34,386
49,621
69.3
Specialists
Managerial
Created in a joint effort by the Controladoria Geral
da União (CGU) and the Instituto Ethos, the Empresa
Pró-Ética Register is an initiative that disseminates policies
implemented by organizations in order to create a corporate
environment that is both honest and transparent. In order
to be included in the Register the firm executes a public
commitment in which it agrees to adopt actions to
promote ethics and prevent corruption.
In turn, the Pacto Empresarial pela Integridade e Contra
Corrupção (a business pact against corruption) in an
initiative by the Instituto Ethos that stimulates businesses
to embrace "the commitment of creating awareness
among their employees and stakeholders about the
Brazilian anticorruption laws in order to ensure full
compliance. The signatory firms are committed to prohibit
any type of bribery, while working for the legality and
transparency in their contributions to political campaigns
and using transparent information and cooperating with
investigations as needed". (www3.ethos.org.br)
Indicators Consolidation
Total number and percentage of operations assessed
for risks related to corruption and the significant
risks identified G4-SO3
In 2013, the 58 cases of sponsoring activities involving
cash to the Governmental Sector were assessed by the
Compliance area. Another 100 processes involving
sponsoring to the Private Sector were also submitted
to the office and all underwent the standard analysis.
The assessments did not detect any significant risks
in connection with corruption, either in public or
private sponsoring.
Number and rate of suppliers which received anti-corruption policies and procedures embraced
by the Organization, per type of partner and region G4-SO4
This topic is made integral part of the approval process for suppliers that aspire to do business with the Bank.
Any companies that undergo a bidding process are required to accept a Request for Quotation (RFQ) that
includes the UN Global Compact Principles. Then the potential supplier undergoes approval during which
technical, administrative, legal and social/environmental processes are considered.
Confirmed incidents of corruption and actions taken G4-SO5
In 2013 there were no legal action entered in connection with corruption involving Santander; also, there
were no complaints involving corruption cases in the Santander Reporting Channel. The Bank is not aware
of any corruption cases involving our suppliers.
144 AMBA ReperRepot Attachment
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