Annual Integrated Report
78
How Santander Open Channel works
Open Channel received 1,741 reports in 2022, a decrease of 31%
from the previous year. The following is a breakdown of the
data:
[2-26; 205-1]
•
Annual Integrated Report
Table of Contents Introduction Value Creation | Economic Performance | Environmental Social Governance Appendices
The following situations fall within the scope:
Non-compliance with internal regulations or applicable
laws;
•
Behavioral deviations (threats, conflict of interest,
humiliation, discrimination, misuse of Bank property, and
negligence, among others);
.
• Inadequate management;
[3-3; 205-2]
Mandatory training¹
Our conviction is that an organization can only foster bonds
of trust when it upholds principles that are widely known and
Online course
2022
2021
2020
Change
(2022 x 2021)
Content
1
The complaints are submitted through
either the designated email address,
[email protected],
⚫ Information security;
or
the electronic form accessible on the
intranet for employees.
2
3
The Compliance department evaluates
the received records before redirecting
them to the appropriate parties for
investigation and a decision regarding
the adoption of necessary measures
Information pertaining to the channel
is compiled into reports, as mandated
by regulatory authorities. The content
is then reported to the Audit Committee
and approved by the Board of Directors.
To ensure that all employees are aware of our policies and
codes, we have instituted mandatory online courses.
• Internal fraud, including but not limited to those involving
financial statements, internal controls, internal audit or
influence on external audits, password sharing, document
tampering, misappropriation of Bank or customer assets,
signature forgery, sale of Bank products without customer
authorization, target tampering, theft, robbery, and electronic
point, among others;
• Moral and/or sexual harassment;
• Physical integrity risks;
•
Corruption and/or bribery and practice of detrimental acts,
as defined in the anti-corruption law;
Anti-competitive practices that may violate any Brazilian
laws, including but not limited to Federal Laws No. 9,279/1996,
No. 12,529/2011, and No. 8,137/1990;
• Improper use of confidential or strategic information;
[205-1; 3-3]
Preventing and combating
corruptiont
96.5%
99.1%
99.1%
-2.6p.p.
New Code of Ethical
Conduct
98.8%
97.8%
99.0%
1.0p.p.
Money laundering
prevention
98.6%
98.9%
99.1%
-0.3p.p.
Antitrust - Introduction to
Competition Law
99.4%
99.6%
99.2%
-0.2p.p.
Fraud Preventiont
99.3%
99.5%
96.7%
-0.2p.p.
Reports Received
1,741
2022
Total
Reports
1,741
Validity
72%
Anonymous
16%
Response
Time
29 days
Conflict of Interest
99.2%
99.4%
96.7%
-0.2p.p.
Well-founded
76%¹
Unfounded
21%¹
2021 2,526
83%
8%
29 days
In progress
5%²
Inconclusive
3%¹
Corporate Defenset
98.7%
98.2%
99.1%
0.5p.p.
'Calculation based on the total number of reports received and
completed through 12/31/2022. 2Calculation based on the total
number of reports registered in our system through 12/31/2022.
4%
19%
The Compliance department has established a preliminary timeline of
five business days for the report's investigation. However, depending on
the complexity, determination, and implementation of measures, the time
required for addressing the allegations may be extended.
In 2022, the average completion time was 29 days, with no allegations of
wrongdoing involving senior leadership.
We adhere to a classification system consisting of 13 categories of
allegations, with the main ones featured in the table below, detailing the
progression from 2021 to 2022:
Warning
36%
Conduct risk in the sale
99.3%
99.6%
99.1%
-0.3p.p.
of products and services
Ethics, fighting corruption and
bribery. The course describes our
practices, laws in effect and covers
the Anti-Corruption Policy.t
Ethical principles that must govern
the actions of all Santander and
affiliated companies' employees, in all
relationships.
Money laundering and concealment,
origins of illicit funds, examples of
atypical situations, whistleblowing
channels and current legislation. The
course also covers the Know Your
Customer Policy.
Guidance on communication,
relationships, prohibitions, obligations,
and competition rules between
companies in the industry.
Guidelines on fraud prevention,
explaining how it is classified and what
procedures should be adopted upon
its detection, in addition to compliance
with regulatory requirements of the
Santander Group.
Conflict of interest, examples of
atypical situations and expected
behaviors. The course also covers the
General Interest Policy
Guidance on how the Bank acts to
prevent crime and inhibit inappropriate
conduct. The course details control
and oversight measures, the Corporate
Defense model, the Criminal Risk
Prevention Manual, the Criminal
Risk Prevention Policy and the Open
Channel.
Ethical conduct risks and standards
associated with the product creation,
sale, and after-sale stages.
Report Category
Change
2022
Market Abuse
Disciplinary
Actions¹
Fraud
2021 2022 x 2021
0.2% 0.0%
0.2%
19.8% 35.7%
-15.9%
Securities Market Code of
Conduct ("SMCC")²
99.5%
99.0%
99.1%
0.5p.p.
Guidance on securities transaction rules
Money Laundering
14.6%
14.3%
0.3%
Information Security
13.6%
17.3%
-3.7%
Conflicts of Interest
10.5%
4.1%
6.4%
22%
Marketing
14.7%
16.3%
-1.6%
Behavioral Deviation
16.1% 10.4%
5.7%
19%
'Considering the following companies: Banco Santander (Brasil) S.A, Aymoré Crédito, Financiamento e Investimento S.A., BEN Benefícios e Serviços S.A., Esfera Fidelidade
S.A., FIRST Tecnologia e Inovação LTDA., Santander Brasil Gestão de Recursos LTDA., Santander Corretora de Seguros, Investimentos e Serviços S.A., Santander Holding
Imobiliária, S.A., Universia Brasil, S.A., Webmotors S.A., Superdigital Instituição de Pagamento S.A., Santander Distribuidora de Títulos e Valores Mobiliários S.A., Return
Capital S.A., SANB PROMOTORA DE VENDAS E COBRANÇA S.A., SX TOOLS SOLUÇÕES E SERVIÇOS COMP. LTDA., and Santander Corretora de Câmbio e Valores Mobiliários
S.A. Among the employees who have not yet taken the course are the new hires, who are eligible, but may still be on schedule for completion. The figures reflect both
completed and ongoing training. The total number of eligible employees differs from others because its calculation considers specific criteria from the Securities Code
of Conduct.
Harassment
6.4%
1.2%
5.2%
Termination
Without Cause
Simple, Personal and Fair
2.9%
0.4%
2.5%
Suspension
Guidance
Discrimination
1.2%
0.3%
0.9% 1
Termination
With Cause
Santander
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