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Responsible selling and prevention of misselling

GRI:
  • [103-1, 103-2 i 103-3] for the Aspect: Responsible selling and prevention of misselling for the Aspect: Responsible selling and prevention of misselling

    Go to GRI list

MissellingIrresponsible and unethical selling of financial productsIrresponsible and unethical selling of financial products is the irresponsible and unethical selling of financial products. In Santander Bank Polska we have implemented a strictly observed practice of Zero tolerance for missellingIrresponsible and unethical selling of financial productsIrresponsible and unethical selling of financial products, which encompasses internal regulations, a control system and an appropriate incentive policy that takes into account the impact of unethical sales on the employees’ compensation.

Zero tolerance for misselling

Culture of responsibility

All employees of the bank are obliged to know and obey the ethical standards laid down in the General Code of Conduct and the Anti-Corruption Programme. The Code is also binding on the bank representatives, who are not employed directly by the bank (employees of partner outlets). The culture is supported by an extensive programme of e-learning courses which explain the most important concepts related to business ethics, compliance, transparency, anti-corruption and identification of conflicts of interest.

Internal regulations

The following documents regulating responsible selling are in place:

  • Regulation of the Chairman of the Deposit Working Group regarding quality control of the process of selling investment products which defines the practice of missellingIrresponsible and unethical selling of financial productsIrresponsible and unethical selling of financial products.
  • Implementing regulation to the Bonus Rules – the terms of awarding bonus to employees of the bank’s branch network which defines the possibilities and the terms of depriving employees of the bonus because of missellingIrresponsible and unethical selling of financial productsIrresponsible and unethical selling of financial products practices.

Santander Bank Polska monitors compliance with these regulations on an ongoing basis through:

  • Three levels of investment product control:
    • Mystery shopping.
    • Telephone checks initiated by the bank.
    • Review of deviations from the standards and trends.
  • Seven levels of insurance product control.

Our customers can submit complaints regarding missellingIrresponsible and unethical selling of financial productsIrresponsible and unethical selling of financial products via all available communication channels:

  • our branches

  • the online banking platform

  • on the website

  • over the phone (for instance during telephone calls initiated by the bank)

Good practices of Santander Bank Polska
  • At each stage of the offer presentation, we make sure it is clear and accurate. Each of our customers always receives transparent, comprehensive and specific information about the bank’s services.
  • We have simplified the language of communication – we always inform the customers clearly about the terms of the offer, the fees, commissions, interest rates and the benefits related to the products.
  • We pay special attention to making people aware of the risk associated with financial instruments, particularly with investment products and long-term loans.
  • We do not sell unit-linked insurance products (so-called ‘polisolokata') to senior customers.
  • Selected template agreements that we sign with our customers are reviewed by external institutions and the outcomes of such reviews are taken into consideration by the bank

The Intranet has a special section containing information concerning missellingIrresponsible and unethical selling of financial productsIrresponsible and unethical selling of financial products.

Prevention of misselling in our partner outlets

Employee training in partner outlets begins with an Adaptation Programme, which lasts for 8 days. The first day of the training is devoted to insurance issues and ends with an exam. On the following days, the participants learn how to handle products offered by partner outlets, how to register product servicing processes in the relevant banking systems, how to conduct sales conversations with customers, how to verify the authenticity of documents and how to react properly in difficult situations occurring during the teller’s work. In the course of the programme, trainers focus on building awareness of bearing personal responsibility for non-compliance with banking procedures and on the standard of service, where they emphasise the importance of carrying out a thorough analysis of customer needs when suggesting a specific product. The Adaptation Programme ends with a practical exam, held on the last day of the training. In addition, employees are required to complete mandatory e-learning courses within one month of completion of the Adaptation Programme. Moreover, all other (existing) Partners and employees of partner outlets, irrespective of the form of their employment, are required to complete any new training modules within one month of the date of their release.

The Adaptation Programme was completed by:

  • 139

    people
    in 2017

  • 108

    people
    in 2018

Additionally, 33 people who were exempt from participating in the Adaptation Programme due to documented professional banking experience, took the practical exam.

Issues related to missellingIrresponsible and unethical selling of financial productsIrresponsible and unethical selling of financial products are regulated by the provisions of an Agency Agreement, which is signed with every Partner. The provisions of Article 18 of the agreement, for example, refer to compensation policies and practices (European Banking Authority guidelines), which the Partner is required to apply to its employees.

GRI:

In 2017, no fines were imposed on Santander Bank Polska for non-compliance with laws and regulations concerning the services provided.

Ethical marketing

Advertising messages are an important and effective communication tool with our existing and prospective customers. They should build a positive image of the bank in the eyes of customers and, most importantly, provide complete, reliable and accurate information and conform with the law and ethical standards.

The following external documents regulate the bank’s advertising and communication activities:

  • Rules of advertising banking services (appended to KNF’s resolution of 2 October, 2008)
  • Good practices concerning the advertising of consumer loans (adopted by the Polish Bank Association on 22 December 2015).

All our marketing activities are carried out pursuant to the provisions of the Manual of Compliance in Advertising and Marketing Communication Activities of Santander Bank Polska, which is a collection of guidelines pertaining to all types of advertisements, including the increasingly popular advertisements in electronic media.

Good practices of Santander Bank Polska

Review of all marketing messages published by the bank
All marketing materials require a prior approval of the Compliance Area and the Legal Area. The Compliance Area already at the stage of new product commercialisation checks whether the product is consistent with the Simple, Personal, Fair philosophy.

Employee education
Employees responsible for the broadly understood marketing activities take part in projects aimed at simplifying regulations for customers, including workshops with language experts.

GRI:

In 2017, no instances of non-compliance were identified in respect of marketing communication addressed to customers as well as product labelling and information (no proceedings were instituted by the Competition and Consumer Protection Office against the bank).