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Responsible selling

Responsible selling is a key area of responsibility for banks. Our organization undertakes numerous efforts in order to enhance the culture of responsible selling and prevent misselling. We also take part in the most important industry initiatives in this area.

Preventing misselling

GRI:
  • [103-1] for the reporting Aspect: Responsible selling and prevention of misselling for the reporting Aspect: Responsible selling and prevention of misselling

    Go to GRI list
  • [103-2] for the reporting Aspect: Responsible selling and prevention of misselling for the reporting Aspect: Responsible selling and prevention of misselling

    Go to GRI list
  • [103-3] for the reporting Aspect: Responsible selling and prevention of misselling for the reporting Aspect: Responsible selling and prevention of misselling

    Go to GRI list

Misselling is a practice violating collective consumer interests which consists in proposing consumers the purchase of financial services which do not meet their needs as identified based on the information available to the seller on the characteristics of the consumers or proposing the purchase of such services in a way which is not adequate for their nature*.

In Santander Bank Polska we understand misselling as irresponsible and unethical selling of financial products. In this kind of a sales transaction, the buyer purchases a product other than planned or is not aware of the financial consequences associated with the purchase. There are many different definitions of misselling, but all contain the element of unethical conduct in respect of the customer.

* https://alebank.pl/misselling-po-17-kwietnia-kongres-prawa-bankowego-i-informacji/

Potential causes and effects of misselling:

Causes (seller’s conduct, sales procedures, marketing activities, product design)
Misselling (useless product, a product which is not consistent with the description or a product which the customer cannot afford)
Effects (difficult financial situation of the customer)

Our organization strongly objects to all unfair selling practices. Therefore, we have launched a clear and transparent principle for all employees of our bank ”Zero tolerance for misselling”. The introduction of the principle was accompanied by the implementation of relevant procedures, policies, practices, internal regulations, a control system and an appropriate incentive policy that takes into account the impact of unethical sales on the employees’ compensation. Detailed information on the subject can be found in the last year’s report.

The employees of the Corporate and Investment Banking Division, in addition to the General Code of Conduct and the Anti-Corruption Program are subject to a number of additional internal procedures. Moreover, an independent bank’s unit conducts a series of checks to examine the quality of sales processes e.g. listening to the recorded dealers’ phone conversations and verifying conformance of the executed product sales transactions with agreements signed by customers and the results of the adequacy test. The products offered by the Corporate and Investment Banking Division are subject to the commercialization process which includes the examination of target markets for the products with a view to misselling.

Employee education in responsible selling

The main objective of educational and training activities conducted by our bank is to raise the competences of employees, give them the confidence necessary to do their jobs well and develop their skills. Our training policy helps us manage the reputational and misselling risks. At the very beginning of their professional career in the bank, our advisors take part in the Adaptation Program, the goal of which is to prepare them for selling the bank’s products properly. The good insight and the ability to operate in the specific banking environment requires excellent knowledge of the procedures, processes and products in order to avoid misselling and demonstrate the attitude consistent with the bank’s values. More information about the Adaptation Program can be found here [http://en.raport.santander.pl/klienci/odpowiedzialna-sprzedaz-i-przeciwdzialanie-missellingowi/]

The employees of our organization can always refer to a special section on the intranet with information about misselling.

Principles of responsible selling for the bank’s partners

We also make sure that the principle of ”Zero tolerance for misselling” is respected in our partner outlets. The Agency Agreements signed with each Partner contain special provisions on misselling. Paragraph 28, for example,  refers to the compensation policies and practices consistent with the guidelines of the European Banking Authority. All partners of our organization are obliged to respect the rules in relationships with their employees.