We are aware of and comply with all laws and regulations, in addition to all ethical standards that are applicable to the markets in which we operate. We also act fairly, ethically and responsibly in order to benefit our customers, shareholders and other stakeholders.
General Code of Conduct (GCC)
This document encompasses the ethical principles and standards applicable to each of the Bank’s employees. It also acts as a means of preventing any risks to which we are exposed.
During 2022, we coordinated the following actions:
The GCC outlines the guidelines for employees, directors and Board Members to help prevent any conflict of interest. It is of the utmost importance that all decisions be taken in the best interest of Santander, without putting vested interests, those of family members, or those relating to the acquisition or leasing of goods and assets, among others, first.
We also have a Conflicts of Interest policy that contains the guidelines to prevent and manage any conflicts of interest that may arise as a result of their activities. This policy also:
It also outlines the policies for communicating with and informing shareholders, markets and the general public.
In the event of a conflict of interest, the mechanism outlined in the Governance Model will be applied to escalate the issue, firstly, to the authority responsible, and, if no solution is found, then it will be escalated to the respective CEO. As a last resort, and in accordance with the responsibilities delegated by the Board, it will be sent to the respective Chairs or the appropriate governance body at the Group or Mexico level for a formal ruling. If necessary, it will be escalated to the Shareholders’ Assembly.
All members of our Board of Directors who have any conflicts of interest must disclose them and abstain from any deliberation or vote concerning the latter.
Furthermore, in accordance with the Credit Institutions Law, our Corporate Practices Committee must issue a ruling regarding, among other elements, any operations and agreements with related parties, which must then subsequently be approved by the Board of Directors.
Ethics Line is a reporting system, operated by EthicsGlobal, an external specialist in complaint and report management. It has several channels that offer our employees, suppliers and ex-employees the opportunity to make their voices heard anonymously regarding any irregularities that could cause a risk to or affect the operations of the Bank in order to redress any negative impacts1. Furthermore, they can request support regarding the application of the organization’s practices and policies to ensure responsible business conduct.
1. Negative impact refers to the effect that the organization has or may have on the economy, the environment or individuals, including those effects regarding human rights, and which, in turn, may be indicative of its contribution (be it negative or positive) to sustainable development.The areas responsible for the Ethics Line are Human Resources, Compliance, and Operational Incidents, which are obliged to report the content of relevant cases to the respective steering committees and follow up on each case.
Complaints relating to an employee’s responsibilities may be discussed in the Sanctions and Incidence Analysis Forum to help promote a reliable and impartial working environment. This also safeguards, at all times, confidentiality and anonymity, in addition to ensuring no acts of reprisal or conflicts of interest are involved when handling said complaints.
Our reporting channels include:
In our day-to-day activities, we fully and comprehensively reject any corrupt practices through a zero-tolerance approach. Santander Mexico’s Corruption Prevention Policy, which is coordinated by the Compliance Committee, stipulates the guidelines for preventing corruption within the Group, including the misuse of public funds, bribery, payment of contributions and influence peddling.
We have a System for the Prevention of Money Laundering and Terrorist Financing (PMLTF) to control how we manage fund origins. This system is governed by the General Policy and Procedures Manual and is reviewed on an on-going basis to ensure compliance with applicable laws and standards.
