General Standard Disclosures GRI G4

Transcription

1 General Stard Disclosures GRI G4 STRATEGY AND ANALYSIS G4-1 Provide a statement from the most senior decision-maker of the organization (such as CEO, chair, or equivalent senior position) about the relevance of sustainability to the organization the organization s strategy for addressing sustainability. Page/Omission P. 8-9 G4-2 Provide a description of key impacts, risks, opportunities. P COMPANY PROFILE G4-3 Report the name of the organization. P. 106 G4-4 Report the primary brs, products, services. P. 10 Annual Report (p ) G4-5 Report the location of the organization s headquarters. P. 106 G4-6 Report the number of countries where the organization operates, names of countries where either the organization has significant operations or that are specifically relevant to the sustainability topics covered in the report. P. 6-7 Annual Report (p ) Note 3c of the Manangement Report (p.56) G4-7 Report the nature of ownership legal form. P G4-8 G4-9 G4-10 Report the markets served (including geographic breakdown, sectors served, types of customers beneficiaries). Report the scale of the organization, including: - Total number of employees - Total number of operations - Net sales (for private sector organizations) or net revenues (for public sector organizations) - Total capitalization broken down in terms of debt equity (for private sector organizations) - Quantity of products or services provided a. Report the total number of employees by employment contract gender. b. Report the total number of permanent employees by employment type gender. c. Report the total workforce by employees supervised workers by gender. d. Report the total workforce by region gender. e. Report whether a substantial portion of the organization s work is performed by workers who are legally recognized as self-employed, or by individuals other than employees or supervised workers, including employees supervised employees of contractors. f. Report any significant variations in employment numbers (such as seasonal variations in employment in the tourism or agricultural industries). P. 6-7 Annual Report (p ) P. 4, 6-7, 53 P G4-11 Report the percentage of total employees covered by collective bargaining agreements. P. 29 G4-12 Describe the organization s supply chain. P G4-13 Report any significant changes during the reporting period regarding the organization s size, structure, ownership, or its supply chain. Commitments to initiatives G4-14 G4-15 G4-16 Report whether how the precautionary approach or principle is addressed by the organization. List ly developed economic, social charters, principles, or other initiatives to which the organization subscribes or which it endorses. List memberships of associations (such as industry associations) national or international advocacy organizations in which the organization: - Holds a position on the governance body. - Participates in projects or committees. - Provides substantive funding beyond routine membership dues. - Views membership as strategic. material aspects boundaries a. List all entities included in the organization s consolidated financial statements or equivalent documents. G4-17 b. Report whether any entity included in the organization s consolidated financial statements or equivalent documents is not covered by the report. P P. 49 P. 13 Santer participates in industry associations representing financial activity in the countries where it operates, as the AEB in the case of Spain P. 88 Appendix I of the Management Report (p ) Review 89

2 G4-18 a. Explain the process for defining the report content the Aspect Boundaries. b. Explain how the organization has implemented the Reporting Principles for Defining Report Content. Page/Omission P. 88 G4-19 List all the material identified in the process for defining report content. P G4-20 For each material Aspect, report the Aspect Boundary within the organization. G4-21 For each material Aspect, report the Aspect Boundary outside the organization. G4-22 Report the effect of any restatements of information provided in previous reports, the reasons for such restatements. Specific stard disclosures GRI G4 (p ) Specific stard disclosures GRI G4 (p ) P G4-23 Report significant changes from previous reporting periods in the Scope Aspect Boundaries. P. 88 STAKEHOLDER ENGAGEMENT G4-24 Provide a list of stakeholder groups engaged by the organization. P G4-25 Report the basis for identification selection of stakeholders with whom to engage. P G4-26 Report the organization s approach to stakeholder engagement, including frequency of engagement by type by stakeholder group, an indication of whether any of the engagement was undertaken specifically as part of the report preparation process. P G4-27 Report key topics concerns that have been raised through stakeholder engagement, how the organization has responded to those key topics concerns, including through its reporting. Report the stakeholder groups that raised each of the key topics concerns. P REPORT PROFILE G4-28 Reporting period (such as fiscal or calendar year) for information provided. P. 88 G4-29 Date of most recent previous report (if any). P. 88 G4-30 Reporting cycle (such as annual, biennial). P. 88 G4-31 Provide the contact point for questions regarding the report or its contents. P. 106 Gri content index G4-32 Assurance G4-33 GOVERNANCE G4-34 G4-35 G4-36 a. Report the in accordance option the organization has chosen. b. Report the GRI Content Index for the chosen option. c. Report the reference to the External Assurance Report, if the report has been ly assured. a. Report the organization s policy current practice with regard to seeking assurance for the report. b. If not included in the assurance report accompanying the sustainability report, report the scope basis of any assurance provided. c. Report the relationship between the organization the assurance providers. d. Report whether the highest governance body or senior executives are involved in seeking assurance for the organization s sustainability report. Report the governance structure of the organization, including committees of the highest governance body. Identify any committees responsible for decision-making on economic, social impacts. Report the process for delegating authority for economic, social topics from the highest governance body to senior executives other employees. Report whether the organization has appointed an executive-level position or positions with responsibility for economic, social topics, whether post holders report directly to the highest governance body. P. 88 P P. 88 P P. 12, Management Report (p. 291) P. 12 P. 12 Review 90

3 G4-37 Report processes for consultation between stakeholders the highest governance body on economic, social topics. If consultation is delegated, describe to whom any feedback processes to the highest governance body. G4-38 Report the composition of the highest governance body its committees. G4-39 G4-40 G4-41 Report whether the Chair of the highest governance body is also an executive officer (, if so, his or her function within the organization s the reasons for this arrangement). Report the nomination selection processes for the highest governance body its committees, the criteria used for nominating selecting highest governance body members. Report processes for the highest governance body to ensure conflicts of interest are avoided managed. Report whether conflicts of interest are disclosed to stakeholders. Highest governance body s role in setting purpose, values, strategy G4-42 Report the highest governance body s senior executives roles in the development, approval, updating of the organization s purpose, value or mission statements, strategies, policies, goals related to economic, social impacts. Highest governance body s competencies performance evaluation G4-43 G4-44 Report the measures taken to develop enhance the highest governance body s collective knowledge of economic, social topics. a. Report the processes for evaluation of the highest governance body s performance with respect to governance of economic, social topics. Report whether such evaluation is independent or not, its frequency. Report whether such evaluation is a selfassessment. b. Report actions taken in response to evaluation of the highest governance body s performance with respect to governance of economic, social topics, including, as a minimum, changes in membership organizational practice. Highest governance body s role in risk G4-45 G4-46 G4-47 a. Report the highest governance body s role in the identification of economic, social impacts, risks, opportunities. Include the highest governance body s role in the implementation of due diligence processes. b. Report whether stakeholder consultation is used to support the highest governance body s identification of economic, social impacts, risks, opportunities. Report the highest governance body s role in reviewing the effectiveness of the organization s risk processes for economic, social topics. Report the frequency of the highest governance body s review of economic, social impacts, risks, opportunities. Highest governance body s role in sustainability reporting G4-48 Report the highest committee or position that formally reviews approves the organization s sustainability report ensures that all material are covered. Highest governance body s role in evaluating economic, social performance G4-49 Report the process for communicating critical concerns to the highest governance body. G4-50 Report the nature total number of critical concerns that were communicated to the highest governance body the mechanism(s) used to address resolve them. Page/Omission P P Management Report (p ) Management Report (p ) Management Report (p ) Management Report (p ) P. 12 Article 3 of the Regulations of the Board of Directors of Banco Santer, S.A Management Report (p. 360) Management Report (p. 308) P. 12 Management Report (p. 160) Management Report (p. 160) P. 12 Management Report (p. 160) P. 12 Management Report (p. 359) Report of the Committees (p. 59) Review 91

4 Remuneration incentives a. Report the remuneration policies for the highest governance body senior executives for the below types of remuneration. G4-51 b. Report how performance criteria in the remuneration policy relate to the highest governance body s senior executives economic, social objectives. G4-52 G4-53 G4-54 G4-55 Report the process for determining remuneration. Report whether remuneration consultants are involved in determining remuneration whether they are independent of. Report any other relationships which the remuneration consultants have with the organization. Report how stakeholders views are sought taken into account regarding remuneration, including the results of votes on remuneration policies proposals, if applicable. Report the ratio of the annual total compensation for the organization s highest-paid individual in each country of significant operations to the median annual total compensation for all employees (excluding the highest-paid individual) in the same country. a. Report the ratio of percentage increase in annual total compensation for the organization s highest-paid individual in each country of significant operations to the median percentage increase in annual total compensation for all employees (excluding the highest-paid individual) in the same country. ETHICS AND INTEGRITY Describe the organization s values, principles, stards norms of behavior such as codes of G4-56 conduct codes of ethics. G4-57 G4-58 Report the internal mechanisms for seeking advice on ethical lawful behavior, matters related to organizational integrity, such as helplines or advice lines. Report the internal mechanisms for reporting concerns about unethical or unlawful behavior, matters related to organizational integrity, such as escalation through line, whistleblowing mechanisms or hotlines. Page/Omission Report of the Committees (p ) Report of the Committees (p ) Report of the Committees (p ) In order to obtain an homogeneous comparison on top 10 countries where the operates, Santer is adapting its reporting systems for obtaining G4 indicators relating to compensation remuneration In order to obtain an homogeneous comparison on top 10 countries where the operates, Santer is adapting its reporting systems for obtaining G4 indicators relating to compensation remuneration P. 35 P. 35 P. 35 Review 92

5 Specific stard disclosures GRI G4 Category: economic Economic performance million Economic value generated 1 45,818 41,716 Economic value distributed 22,753 20,363 Dividends paid in cash 3 1, Other administrative expenses (except taxes) 7,008 6,751 Staff costs 10,242 10,069 Income tax other taxes2 2 4,180 2,479 CSR investment Economic value retained (Economic value generated less value distributed) 23,065 21,353 Solvency s opportunities associated with climate change. G4-EC1 Direct economic value generated distributed Total shareholder remuneration 3 7, Gross income plus net gains on disposal of assets. 2. Only includes income tax expense accrued taxes recognised during the year. Additional disclosures on taxes paid are included in the Community investment chapter. 3. In addition to the 1,136 million in shareholder remuneration through the scrip dividend programme (Santer Dividendo Elección), the Bank offers shareholders the option of receiving an amount equal to the final dividend for 2014 in cash or new shares. The Bank s directors estimate that 84% of shareholders will request that the final dividend be settled in shares, whereby it is estimated that approximately 1,772 million shares will be distributed to shareholders. 4. Figures for 2013 are presented for comparative purposes only. Figures for 2013 have been changed from those presented in the 2013 report, primarily to account for the effects of applying IFRIC 21. G4-EC2 Financial implications other risks opportunities for the organization's activities due to climate change - P , CDP Report 2014 ( 2.1 question). 2 G4-EC3 Coverage of the organization's defined benefit plan obligations The liability for provisions for pensions similar obligations at 2014 yearend amounted to EUR 9,412million. Endowments contributions to the pension funds in the 2014 financial year have amounted to EUR 780 million. The detail may be consulted in Note 25 of the Management Report (pp of the auditors report annual consolidated accounts) G4-EC4 Financial assistance received from government The Bank has not received subsidies or public aids during The only remarkable subsidies are those received for training, which in Spain amounted to EUR 3 million in Management Report (P. 228) Market presence Job creation G4-EC5 G4-EC6 Ratios of stard entry level wage by gender compared to local minimum wage at significant locations of operation Proportion of senior hired from the local community at significant locations of operation In order to obtain an homogeneous comparison on top 10 countries where the operates, Santer is adapting its reporting systems for obtaining G4 indicators relating to compensation remuneration The Corporate Human Resources Model aims to attract retain the best professionals in the countries in which it operates P. 28 except for UK USA 93

6 Indirect economic impacts Access to financial services by vulnerable groups of society Procurement practices G4-EC7 G4-EC8 Job creation External G4-EC9 Environmental s Development impact of infrastructure investments services supported Significant indirect economic impacts, including the extent of impacts Proportion of spending on local suppliers at significant locations of operation P. 5, P. 5, P. 85 Controlling reducing the impact Energy Controlling reducing the impact Non material Water Controlling reducing the impact Non material Biodiversity Non material Not applicable Not applicable Not applicable G4-EN1 s used by weight or volume P G4-EN2 G4-EN3 G4-EN4 Percentage of materials used that are recycled input materials Energy consumption within the organization Energy consumption outside of the organization The percentage of the lyfriendly paper consumption with respect to the total consumption is 68% This percentage includes both recycled certified paper 3 P Not available. This information will be disclosed in next few years. G4-EN5 Energy intensity P G4-EN6 G4-EN7 Reduction of energy consumption Reductions in energy requirements of products services An specific analysis of cause effect relation for the implemented measures of the obtained saving is not available. Non material G4-EN8 Total water withdrawal by source P G4-EN9 G4-EN10 G4-EN11 G4-EN12 Water sources significantly affected by withdrawal of water Percentage total volume of water recycled reused Operational sites owned, leased, managed in, or adjacent to, protected areas areas of high biodiversity value outside protected areas Description of significant impacts of activities, products, services on biodiversity in protected areas areas of high biodiversity value outside protected areas Non material Non material Non material G4-EN13 Habitats protected or restored G4-EN14 Total number of IUCN Red List species national conservation list species with habitats in areas affected by operations, by level of extinction risk 94

7 Emissions Controlling reducing the impact No material Effluents waste Non material Not applicable Not applicable Products services Controlling social risls in lending transactions Compliance control Transport Controlling reducing the impact Overall Non material Not applicable G4-EN15 G4-EN16 G4-EN17 G4-EN18 G4-EN19 G4-EN20 G4-EN21 G4-EN22 G4-EN23 G4-EN24 G4-EN25 G4-EN26 G4-EN27 G4-EN28 G4-EN29 G4-EN30 G4-EN31 Direct greenhouse gas (GHG) emissions (Scope 1)) Energy indirect greenhouse gas (GHG) emissions (Scope 2) Other indirect greenhouse gas (GHG) emissions (Scope 3) Greenhouse gas (GHG) emissions intensity Reduction of greenhouse gas (GHG) emissions Emissions of ozone-depleting substances (ODS) X, SOX, other significant air emissions Total water discharge by quality destination Total weight of waste by type disposal method Total number volume of significant spills Weight of transported, imported, exported, or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III, VIII, percentage of transported waste shipped internationally Identity, size, protected status, biodiversity value of water bodies related habitats signifcantly affected by the organization's discharges of water runoff Extent of impact mitigation of impacts of products services Percentage of products sold their packaging materials that are reclaimed by category Monetary value of significant fines total number of non-monetary sanctions for non-compliance with laws regulations Significant impacts of transporting products other goods materials for the organization s operations, transporting members of the workforce Total protection expenditures investments by type P P P P An specific analysis of cause effect relation for the implemented measures of the obtained saving is not available. Non material Non material Non material Non material Non material Non material Non material P Non material No significant sanctions nor penalties due to breaches of regultations have been imposed. P Non material 95

8 Supplier assessment control G4-EN32 G4-EN33 Environmental grievance mechanisms control Social dimension G4-EN34 LABOR PRACTICES AND DECENT WORK Employment Managing talent Job Creation Labor/ relations Policies on work-life balance diversity Occupational health safety control G4-LA1 G4-LA2 G4-LA3 G4-LA4 G4-LA5 G4-LA6 G4-LA7 G4-LA8 Percentage of new suppliers that were screened using criteria Significant actual potential negative impacts in the supply chain actions taken Number of grievances about impacts filed, addressed, resolved through formal grievance mechanisms Total number rates of new employee hires employee turnover by age group, gender region Benefits provided to full-time employees that are not provided to temporary or part-time employees, by significant locations of operation Return to work retention rates after parental leave, by gender Minimum notice periods regarding operational changes, including whether these are specified in collective agreements Percentage of total workforce represented in formal joint -worker health safety committees that help monitor advise on occupational health saftey programs Type of injury rates of injury, occupational diseases, lost days, absenteeism, total number of work-related fatalities, by region by gender Workers with high incidence or high risk of diseases related to their occupation Health safety topics covered in formal agreements with trade unions P. 85 P. 85 Environmental typology is not identified within grieveances registries in the Bank. P P Temporary employees represent a %3.8 of total workforce, therefore this content has been considered as non material. This information is not available Santer has not established any minimum period to give prior notice relating to organisational changes different to those required by law in each country In BancoSanter S.A the percentaje of workforce represented in the Health Safety Committe is %100. Banco Santer S.A P There have not been identified work positions with high risks of diseases. Issues related to employees health occupational risk prevention, such as health monitoring programms are included within formal agreements with trade unions. Banco Santer S.A 96

9 Training education G4-LA9 Average hours of training per year per employee by gender, by employee category P. 31 Managing talent Diversity equal opportunity Policies on work-life balance diversity G4-LA10 G4-LA11 G4-LA12 Equal remuneration for women men Policies on work-life balance diversity G4-LA13 Supplier assessment for labor practice control G4-LA14 G4-LA15 Labor practices grievance mechanisms control HUMAN RIGHTS Investment Non material Non-discrimination control Not applicable G4-LA16 G4-HR1 G4-HR2 G4-HR3 Programs for skills lifelong learning that support the continued employability of employees assist them in managing career endings Percentage of employees receiving regular performance career development reviews, by gender by employee category Composition of governance bodies breakdown of employees per employee category according to gender, age group, minority group membership, other indicators of diversity Ratio of basic salary remuneration of women to men by employee category, by significant locations of operation Percentage of new suppliers that were screened using labor practices criteria Significant actual potential negative impacts for labor practices in the supply chain actions taken Number of grievances about labor practices filed, addressed, resolved through formal grievance mechanisms Total number percentage of significant investment agreements contracts that include human rights clauses or that underwent human rights screening Total hours of employee training on human rights policies or procedures concerning aspects of human rights that are relevant to operations, including the percentage of employees trained Total number of incidents of discrimination corrective actions taken Banco Santer in Spain offers in specific occasions programms for skills lifelong learning that support the employability of their employees once they have finished their careers or have been affected by collective redundancies. Banco Santer S.A P P. 15, In order to obtain an homogeneous comparison on top 10 countries where the operates, Santer is adapting its reporting systems for obtaining G4 indicators relating to compensation remuneration P. 85 P. 85 Note 25 d e of the Management Report (p ) 4 Non material Non material P

10 Child labor control Child labor control Forced or compulsory labor control Security practices control Indigenous rights control Assessment G4-HR4 G4-HR5 G4-HR6 G4-HR7 G4-HR8 Non material No aplica G4-HR9 Supplier human rights assessment control control G4-HR10 G4-HR11 Grievance mechanisms for impacts on human rights control G4-HR12 Operations suppliers identified in which the right to exercise freedom of association collective bargaining may be violated or at significant risk, measures taken to support these rights Operations suppliers identified as having significant risk for incidents of child labor, measures taken to contribute to the effective abolition of child labor Operations suppliers identified as having significant risk for incidents of forced or compulsory labor, measures to contribute to the elimination of all forms of forced or compulsory labor Percentage of security personnel trained in the organization s human rights policies or procedures that are relevant to operations Total number of incidents of violations involving rights of indigenous peoples actions taken Total number percentage of operations that have been subject to human rights reviews or impact assessments Percentage of new suppliers that were screened using human rights criteria Significant actual potential negative human rights impacts in the supply chain actions taken Number of grievances about human rights impacts filed, addressed, resolved through formal grievance mechanisms P. 85 P. 85 P. 85 Santer requires to its Safety Services suppliers during the hiring process compliance with Human Rights Regulations. The existing potential risk in this matter is mitigated throughout analysis carried out within the framework of Equator Principles. During 2014 any assessment of this type has been carried out, because no risks of this type have been identified in Santer operations. 2 2 P. 83 P. 83 P

11 SOCIETY Local communities P Access to financial services by vulnerable groups of society Factoring in social aspects into the s strategy G4-SO1 Percentage of operations with implemented local community engagement, impact assessments, development programs Santer has no formal programme to analyse the impacts on communities in its entry /or leaving the country. However, specific analyses are carried out, according to recomendations based on the identified risks. As a way to maximise positive impacts on society mitigate the negative ones, for the last eighteen years the Santer Universities programme is being developed in key countries where the is present Additionally, in recent years products services with a social or focus have been launched, adapted to the different locations where the Bank operates. G4-SO2 Operations with significant actual potential negative impacts on local communities No operation centers in this situation have been identified Fight against corruption Regulatory compliance Public policy Regulatory compliance Anti-competitive behavior Regulatory compliance Compliance Regulatory compliance G4-SO3 G4-SO4 G4-SO5 G4-SO6 G4-SO7 G4-SO8 Supplier assessment for impacts on society control G4-SO9 G4-SO10 Total number percentage of operations asessed for risks related to corruption the significant risks identified Communication training on anticorruption policies procedures Confirmed incidents of corruption actions taken Total value of political contributions by country recipient/beneficiary Total number of legal actions for anti-competitive behavior, anti-trust, monopoly practices their outcomes Monetary value of significant fines total number of non-monetary sanctions for non-compliance with laws regulations Percentage of new suppliers that were screened using criteria for impacts on society Significant actual potential negative impacts on society in the supply chain actions taken P P. 17 P The vinculation, membership or collaboration with political parties or with other kind of entities, institutions or associations with public purposes, as well as contributions or services to them should be done in a way that can assure the personal character that avoids any involvement of the, as indicated in Santer General Code of Conduct. Information on litigation other contingencies can be found in Notes 1.d 25.e of the auditors report annual consolidated accounts (pp ) Information on litigation other contingencies can be found in Notes 1.d 25.e of the auditors report annual consolidated accounts (pp ) P. 83 P

12 Grievance mechanisms for impacts on society Number of grievances about control G4-SO11 impacts on society filed, addressed, resolved through formal P grievance mechanisms Product responsibility Customer health safety G4-PR1 Percentage of significant product service categories for which health safety impacts are P. 48 assessed for improvement control Total number of incidents of non-compliance with regulations Information on litigation voluntary codes concerning other contingencies can G4-PR2 be found in Notes 1.d 25.e of the health safety impacts of products services during their the auditors report annual life cycle, by type of outcomes consolidated accounts (pp ) 4 Product service labeling Type of product service information required by the organization's procedures for product G4-PR3 service information labeling, P percentage of significant product service categories subject to control such information requirements Total number of incidents of Information on litigation non-compliance with regulations other contingencies can G4-PR4 voluntary codes concerning be found in Notes 1.d 25.e of 4 product service information the auditors report annual labeling, by type of outcomes consolidated accounts (pp ) Customer satisfaction Marketing communications G4-PR5 Results of surveys measuring customer satisfaction P. 40 G4-PR6 Sale of banned or disputed products P. 49 In Spain, the Bank forms part of the Spanish Advertising Association (AEA). It is also a member of the Association for the Self-regulation of Commercial Communication, which in turn is a member of the European Advertising Stards Alliance. Therefore, the Total number of incidents of Bank assumes the ethical obligation non-compliance with regulations of responsibly exercising the freedom control voluntary codes concerning of commercial communication G4-PR7 marketing communications, contributes to strengthening 4 Customer privacy including advertising, promotion, sponsorship, by type of outcomes advertising self-regulation as a way of ensuring that consumers competitors rights are respected. Information on litigation other contingencies can be found in Notes 1.d 25.e of the auditors report annual consolidated accounts (pp ) control P.41 Total number of substantiated Information on litigation G4-PR8 complaints regarding breaches other contingencies can of customer privacy be found in Notes 1.d 25.e of 4 Transparency in Products losses of customer data the auditors report annual Services consolidated accounts (pp ) 100

13 Compliance control Transparency in Products Services G4-PR9 Coverage frequency of audits to assess implementation of social policies risk assessment procedures Information on litigation other contingencies can be found in Notes 1.d 25.e of the auditors report annual consolidated accounts (pp ) 4 Product portfolio FS1 Policies with specific social components applied to business lines P Controlling social risks in leading transactions FS2 FS3 Procedures for assessing screening social risks in business lines Processes for monitoring clients implementation of compliance with social requirements included in agreements or transactions P Monitoring on infraestructures financied projects is planned depending on the identified regulatory compliance risk. Disclosing sustainability performance FS4 FS5 Process(es) for improving staff competency to implement the social policies procedures as applied to business lines Interactions with clients/ investees/business partners regarding social risks opportunities P. 50 During 2014, there were meetings with 30 investors on Socially Responsible Investment Transparency in products services FS6 Percentage of the portfolio for business lines by specific region, size (e.g. Micro/sme/large) by sector P. 4, Acccess to financial services by vulnerable groups of society FS7 Monetary value of products services designed to deliver A specific social benefit for each business line broken down by purpose P s opportunities associated with climate change FS8 Monetary value of products services designed to deliver a specific benefit for each business line broken down by purpose P Audits control FS9 Coverage frequency of audits to assess implementation of social policies risk assessment procedures In December 2014 the Intern Audit Area of the have done a review so as to assess compliance level on Environmental Social Policies, which includes Equator Principles review as well as other additional procedures for specific sectors. After the review some reccomendations arise, that are currently ongoing. 101

14 Active asset FS10 Percentage number of companies held in the institution s Portfolio with which the reporting organization has interacted on or social issues P Factoring in social aspects into the s strategy FS11 FS12 Percentage of assets subject to positive negative Environmental or social screening Voting policy(ies) applied to or social issues for shares over which the reporting organization holds the right to vote shares or advises on voting P. 46 The Santer has no voting policies relating to social /or matters for entities over which it has voting power or for which acts as an advisor. The Santer Employees Pension Fund does have a policy of formal vote in relation to social aspects, for shareholder meetings of the entities over which it has voting rights Santer Asset Management Access to financial services by vulnerable groups of society Financial education FS13 FS14 Access points in lowpopulated or economically disadvantaged areas by type Initiatives to improve access to financial services for disadvantaged people P. 43 P. 43 y 46 Transparency in products services Financial Education FS15 FS16 Policies for the fair design sale of financial products services Initiatives to enhance financial literacy by type of beneficiary P P. 70 Reviewed content according to described scope. Review Content revised as per described scope. Assurance Report is included in p of the Sustainability Report. Non reviewed content. 1. Only information regarding owned employees is disclosed. 2. Only qualitative information is disclosed. 3. The scope limitations of this indicator are described on p Provisions of clients complaints are disclosed. 5. Information on total complaints for any reason is disclosed. 6. Not reported in percentage. 7. Information about each type of products services is not detailed. 8. Information about monetary value of all products is not provided. 102