Scope 1 Emissions
2022 Communication on Progress
Banco Sabadell, S.A
Published date
June 29, 2022
No. of questions
64
Supplemental files
PLAN PREVENCION_v7_2019_actual_firmado.pdfCEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentThe Non-Financial Disclosures Report Report1 for Banco de Sabadell, S.A., which includes information on a consolidated and individual basis of Banco Sabadell Group. This report has been developed complying with the general provisions published in Law 11/2018, of 28 December, and information relating to taxonomically eligible exposures in compliance with the Taxonomy Regulation (EURegulation 2020/852), which came into effect in January 2022. In addition, the non binding guidelines published by the European Commission on its Guidelines on Non Financial Reporting (2017/C 21 5/01) are considered, as well as its supplementary document on climate change related information (2019/C 209/01) and the Global Reporting Initiative (GRI) reference framework. This report has been prepared in accordance with the core option of the GRI Standards. (https://www.grupbancsabadell.com/corp/files/1454451076044/einf_bs_2021_eng.pdf?bsb=RmlsZV9DLTE0NTQ0NTEwNzYwNDQtMTM3NDA5ODA3OTg5NQ) In addition, the bank comes from publishing in its sustainability site the Sabadell Sustainable Commitment, as an annual issue statement, where the action framework for Banco Sabadell’s Commitment to Sustainability is underpinned by four strategic pillars, for which a set of commitments is defined. Each one is described by objectives and activated by two kinds of levers:transformation levers and promotion levers. The four strategic pillars are: Progress as a Sustainable Insitution, Support customers in the transition to a sustainable economy, Offer investment opportunities that contribute to sustainability and Work together for a sustainable and cohesive society. The governance system and the organisation of the Bank’s different decision making levels are in a continuous process of improvement and adaptation to the needs that are being created in the new sustainability environment.2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentAll policies, codes and rules issued by the Bank, related to sustainability topics, are publicly available on https://www.grupbancsabadell.com/corp/en/sustainability/policies-codes-and-rules.html3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentAll policies, codes and rules issued by the Bank, related to sustainability topics, are publicly available on https://www.grupbancsabadell.com/corp/en/sustainability/policies-codes-and-rules.html Particularly, This Code of Conduct has been approved by the Board of Directors of Banco de Sabadell, S.A. in order to include the catalogue of principles, obligations and duties that must govern the actions of all the members of the Group. All the internal obligations with a deontological content have been integrated into the Group’s Code of Conduct which thereby groups them together in a single regulatory corpus under the direct supervision of the Corporate Ethics Committee and the Board of Directors of Banco de Sabadell, S.A.4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentThe Board of Directos is the highest responsible for Human Rights, Labour Rights/Decent Work, Environment topics, after report issued by Board Committees regarding the issue. Regarding Anti-corruption issues, CEC (Corporative Ethics Committee) has been named by Board of Directors, as supervisory and monitoring authority for Anti-Corruption program. In 2021, the Board of Directors resolved to create the Strategy and Sustainability Committee within the Board of Directors comprising of five Directors: two Other External Directors and three Independent Directors. The Chairman of the Board is the Chair of the Committee. In the area of sustainability, the Committee has the following areas of responsibility: (a) Reviewing the Institu tion's sustainability and environmental policies; (b) Reporting to the Board of Directors potential regular changes and updates to the sustainability strategy; (c) Reviewing the definition and changes to policies on diversity and inclusion, human rights, equal opportunities and work/life balance and regularly assessing their degree of compliance; (d) Reviewing the Bank’s social action strategy and its sponsorship and patronage plans; (e) Reviewing and updating the Institution’s Non Financial Disclosures Report prior to the Audit and Control Committee’s review and update and its subsequent approval by the Board of Directors; (f) Collecting information relating to reports, letters or communications from external supervisory bodies in this Committee’s area of responsibility.5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Prevention
6. Does the company have a process or processes to assess risk?
Optional commentIn 2021, a first assessment and quantification of the impact of the transition climate and physical risks of our loan portfolio has been developed in line with the scenarios of the Network for Greening the Financial System (NFGS) and the exercises launched by bank of England and the European Central Bank. Based on them, all activity of the loan portfolio has been classified according to its sensitivity to transition risk, taking into account the expected impacts in each scenario and at the level of income, costs and low-carbon capex. On the part of the physical risks, Grupo Banco Sabadell has made a first estimate of the impacts derived from these events on its loan portfolio.6.1. During the assessment of risk, which business relationships are reviewed?
Optional commentThe aim at this stage is to specify and validate the list of priority stakeholders, whose demands and requirements must be incorporated in the materiality analysis, in accordance with best practice in the sector and the recommendations of the aforementioned bodies. To this end, the priority' considered stakeholders were Regulators and supervisory authorities, Economic Agents, Investors and rating agencies, Customers, Employees, Society (through several ways that come from press articles and interviews to participation in social networks or an active and direct relationship with think-tanks, foundations and NGOs) and Suppliers.7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
Optional commentThrough the publication of its Human Rights Policy and the related due diligence procedure, both approved in 2021 and applicable to all Group companies, Banco Sabadell Group establishes its basic principles of action, as well as the mechanisms required to identify, prevent, mitigate and/or remedy any potential negative impacts on human rights that its activities and procedures may entail, in particular, with regard to granting finance to companies, or issues involved in its human resources management model or its supplier contracting processes; the need for training in all of these areas is also established. Moreover, in relation to the supplier approval process, the Group carries out its overall supplier due diligence as part of its selection process and before contractual terms are agreed. Supplier due diligence checks include financial due diligence, policy due diligence, subcontractors’ management and financial crime. A supplier’s corporate social responsibility is assessed as part of the policy due diligence process. The Equator Principles, which it signed up to in 2011 and which form a framework for the a ssessment and management of social and environmental risks, encompassing respect for human rights, and the performance of due diligence to prevent, mitigate and manage adverse impacts; and the Principles for Responsible Banking, among which, the principles of commercial alignment, the principle of impacts and those related to customers and users, as well as the principle of transparency and accountability are particularly relevant to human rights.7.1. During the due diligence process, which business relationships are reviewed?
Optional commentA Code of Conduct has been approved by the Board of Directors of Banco de Sabadell, S.A. in order to include the catalogue of principles, obligations and duties that must govern the actions of all the members of the Group. In addition, and particularly, A Code of Conduct for suppliers has also been approved, that must be accepted by all suppliers and rule the whole compliance criteria on human rights, labour, anti-corruption and environment.Concerns and grievance mechanisms
8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Optional commentIn this regard, Banco Sabadell Group has a Whistleblower Channel for the purpose of detecting and managing possible irregularities that could put this commitment at risk or that could involve a criminal offence. For this purpose, there is a dedicated email address at canaldenunciasGBS@bancsabadell.com through which any employee of the Group or person linked to it (subcontracted personnel, collaborators, suppliers, etc.) must communicate any information or indication of breach of the Code of Conduct or regarding the possibility of a crime being committed that they become aware of. The competent body responsible for resolving and responding to reports or communications received through this channel is the Corporate Ethics Committee of Banco Sabadell Group, which includes the Chief Risk Officer (CRO) among its members.8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?
Optional commentThrough the publication of its Human Rights Policy and the related due diligence procedure, both approved in 2021 and applicable to all Group companies, Banco Sabadell Group establishes its basic principles of action, as well as the mechanisms required to identify, prevent, mitigate and/or remedy any potential negative impacts on human rights that its activities and procedures may entail, in particular, with regard to granting finance to companies, or issues involved in its human resources management model or its supplier contracting processes. In addition, all suppliers agreements includes that "the supplier undertakes to comply with and put into practice, both in the development of the services that are the object of this contract and in the daily exercise of all its professional activity, the content of the "Policies, codes and standards" of the Banco Sabadell Group", that includes among others, the Code of Conduct for suppliers, the Human Rights policy, the Anti-Corruption policy, the Equality Plan and the Sustainability Policy.Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentConsideration of sustainability as a core factor in remuneration within the Group, as a new feature of the Director Remuneration Policy. The components of remuneration contribute to fostering action in environmental, social and good governance (ESG) matters in order to make the business strategy sustainable and socially responsible.Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentOn 26 May 2022, one male independent director resigned from his position, effective upon the attainment of the regulatory authorisations approving the appointment of a new female independent director of Banco Sabadell who was appointed on the same date. Once the female independent director joins effectively the Board, the percentage of women will rise up to 33%.13. Do you produce sustainability reporting according to:
Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Optional commentNon-Financial Disclosures Report 2021, https://www.grupbancsabadell.com/corp/files/1454451076044/einf_bs_2021_eng.pdf (Pages: 126-129. Independent Assurance Report on the Consolidated Non-Financial Disclosures Report for Banco de Sabadell, S.A. and subsidiaries for 2021)Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
Optional commenthttps://www.grupbancsabadell.com/corp/en/sustainability/policies-codes-and-rules.html2.1. For each human rights policy, is it:
Optional commentRegarding our digital security and privacy issue, there is no publicly available policy but, for commercial purposes, it is available in our dedicated website with suppliers. Regarding the Equality Plan policy, it is available: https://www.grupbancsabadell.com/corp/es/sostenibilidad/politicas-codigos-y-normas.html https://www.bancsabadell.com/cs/Satellite/SabAtl/Politica-de-Seguridad/6000020159989/es/#:~:text=Pol%C3%ADtica%20de%20Seguridad%20Banco%20Sabadell%20ha%20incorporado%20la,efectos%20el%20Usuario%20deber%C3%A1%20cumplir%20las%20condiciones%20siguientes%3APrevention
3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?
Optional commentRegarding the Rights of women and/or girls policies, a set of measures have been agreed from the conclusions of the diagnosis and the deviations detected in matter of gender equality. It sets goals to achieve to make equality effective, measures and actions positive aspects necessary to achieve the stated objectives, a implementation schedule, the persons or groups responsible of its realization and indicators and/or monitoring criteria of the actions. There will be monitoring and evaluation of compliance with the Plan, through of the responsible persons designated by each party that collect information on their degree of achievement, their results and its impact on companies. Regarding our Digital security policy, for risks purposes, adequate and effective mechanisms and processes must be adopted to safeguard the confidentiality, integrity and availability of the Information Systems, including the critical, logical and physical resources of the entities, whether at rest, in transit or in use. Each of the Group Entities must proactively manage this risk in order to anticipate, detect and respond as far as possible to potentially problematic risk situations in an appropriate and timely manner.4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?
Optional commentRegarding the Rights of women and/or girls policies, a set of measures have been agreed from the conclusions of the diagnosis and the deviations detected in matter of gender equality. It sets goals to achieve to make equality effective, measures and actions positive aspects necessary to achieve the stated objectives, a implementation schedule, the persons or groups responsible of its realization and indicators and/or monitoring criteria of the actions. There will be monitoring and evaluation of compliance with the Plan, through of the responsible persons designated by each party that collect information on their degree of achievement, their results and its impact on companies. Regarding our Digital security policy, for risks purposes, adequate and effective mechanisms and processes must be adopted to safeguard the confidentiality, integrity and availability of the Information Systems, including the critical, logical and physical resources of the entities, whether at rest, in transit or in use. Each of the Group Entities must proactively manage this risk in order to anticipate, detect and respond as far as possible to potentially problematic risk situations in an appropriate and timely manner.5. Who receives training for the following human rights issues?
Optional commentThere is specific and mandatory training for employees, on both issues. These training courses are being updated periodically6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Optional commentRegarding Digital security, during the reporting period, Banco de Sabadell have an IT Security Plan, with related objectives and indicators and a control framework evaluated by a third party (external). For only Digital privacy, the option to be selected would be "Set annual targets/ goals, track progress over time (internal programs only)"Response
7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?
Optional commentIn 2021, as in the previous year, no report of any breach of human rights was received through whistleblowing channel.8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
Through the publication of its Human Rights Policy and the related due diligence procedure, both approved in 2021 and applicable to all Group companies, Banco Sabadell Group establishes its basic principles of action, as well as the mechanisms required to identify, prevent, mitigate and/or remedy any potential negative impacts on human rights that its activities and procedures may entail, in particular, with regard to granting finance to companies, or issues involved in its human resources management model or its supplier contracting processes; the need for training in all of these areas is also established. Banco Sabadell Group has a whistleblowing channel used to report both breaches of the Code of Conduct and any other corporate crime or potentially criminal act committed by the person(s) concerned, in other words by any employee, partner, supplier or third party in the course of their relationship with the Group. In 2021, as in the previous year, no report of any breach of human rights was received through the whistleblowing channel.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentHuman Right Policy of Banco Sabadell Group: https://www.grupbancsabadell.com/corp/files/1454335664844/politica_ddhh_extracto_grupo_ing.pdf Human Right Due Dilligence Procedure: https://www.grupbancsabadell.com/corp/files/1454450703007/2022_extract_hhrr_due_diligence_procedure.pdf In addition, as attached file, our Occupational Risk Prevention Plan is also uploaded1.1. For each labour rights policy, is it:
Optional commentThrough the publication of its Human Rights Policy and the related due diligence procedure, both approved in 2021 and applicable to all Group companies, Banco Sabadell Group establishes its basic principles of action, as well as the mechanisms required to identify, prevent, mitigate and/or remedy any potential negative impacts on human rights that its activities and procedures may entail, in particular, with regard to granting finance to companies, or issues involved in its human resources management model or its supplier contracting processes; the need for training in all of these areas is also established. Regarding occupational safety and health, the Group applies a policy of hazard prevention and continuous improvement of the health and safety conditions of employees. In accordance with prevailing legislation, the Bank has an occupational hazard prevention plan that includes all of the preventative activities carried out by the company, which are published an nually in a report that is available on the employee intranet and on the corporate website.Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?
Optional commentThrough the publication of its Human Rights Policy and the related due diligence procedure, both approved in 2021 and applicable to all Group companies, Banco Sabadell Group establishes its basic principles of action, as well as the mechanisms required to identify, prevent, mitigate and/or remedy any potential negative impacts on human rights that its activities and procedures may entail, in particular, with regard to granting finance to companies, or issues involved in its human resources management model or its supplier contracting processes; the need for training in all of these areas is also established. Regarding occupational safety and health, the Group applies a policy of hazard prevention and continuous improvement of the health and safety conditions of employees. In accordance with prevailing legislation, the Bank has an occupational hazard prevention plan that includes all of the preventative activities carried out by the company, which are published an nually in a report that is available on the employee intranet and on the corporate website.3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?
Optional commentThe Group fosters and maintains an environment in which the entire workforce is treated with dignity and respect, fairly, with no discrimination based on gender, ethnicity, age, social background, religion, nationality, sexual orientation, political leanin g or disability of any kind, promoting equal opportunities and inclusion in the workplace and in work settings, and prohibiting any form of forced or child labour. In the same vein, the Institution does not hire any minors under the legal working age and in no case under the age of 15. The new version of the Code of Conduct of Banco Sabadell Group, approved in 2021 by the Board of Directors, meets the free exercise of collective rights by the Group’s employees and, in particular, of the internationally recognised rights to form and join unions, associations and collective bargaining, as well as the activities carried out by the organisations that represent them within the framework of the functions and competences legally attributed to them are respected and guaranteed4. Who receives training for the following labour rights issues?
Optional commentIn terms of training, the Group promotes awareness and a culture of upholding human rights by providing employees with the necessary information to raise awareness about the importance of observing the procedures developed to ensure maximum r espect for human rights, and specific training activities are carried out, aimed at the early detection and reporting of any conduct that may be in violation of these international principles. The objective is to reduce any potential breach of human rights. To this end, staff are offered a series of training activities that are related to and have an impact on the main human rights directly or indirectly involved for their team or the activity they carry out. These training activities include courses on pr evention of occupational risks, prevention of money laundering and financing of terrorism, data protection or human trafficking. In particular, in the last quarter of 2021, the Bank launched a new course, which is mandatory for all employees, with the aim of raising awareness of the basic aspects of the Group’s Code of Conduct, and facilitating an inherent understanding and belief in the key principles on which our corporate culture is based, encompassing specific issues related to human rights.5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Optional commentWith regard to its employees, the Group fosters and maintains an environment in which the entire workforce is treated with dignity and respect, fairly, with no discrimination based on gender, ethnicity, age, social background, religion, nationality, sexual orientation, political leanin g or disability of any kind, promoting equal opportunities and inclusion in the workplace and in work settings, and prohibiting any form of forced or child labour. In the same vein, the Institution does not hire any minors under the legal working age and in no case under the age of 15.Performance
6. What is the percentage of employees covered under collective bargaining agreements?
7. What is the percentage of employees in a trade union or other workers' organization?
8. In the course of the reporting period, what was the percentage of women in:
9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Optional commentThe pay gap calculation compares total remuneration received by men against total remuneration received by women. To this end, it is calculated as the percentage arrived at by taking the difference between average and median remuneration received by men and average and median remuneration received by women and then dividing this by the average and median remuneration received by men. If the percentage is positive, this means that the average or median remuneration received by men is higher than that received by women. Conversely, if the percentage is negative, it means that women receive more average or median remuneration than men.10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
11. In the course of the reporting period, what was the company’s incident rate?
Response and Reporting
12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?
13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
Banco Sabadell aplies the banking collective agreement that was signed with the trade unions in March 2020 and guarantees all the labour rights contained therein. In addition, the Equality Plan, which recognizes equal opportunities between women and men, has recently been signed. In the company, current legislation is strictly applied to ensure compliance with all labor rights.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentDue to the activity sector of the Banco Sabadell Group, we do not need to have developed a specific policy for Water, Oceans, Forests/Biodiversity/Land Use and Air Pollution. Regarding Waste and Energy & Resource Use, we have an environmental management system certified according to the ISO 14001:2015 standard.1.1. For each environmental policy, is it:
Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?
3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?
4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?
5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?
Optional commentThe Banco de Sabadell Group has not been involved in any negative risk event in climate action, neither related to wast nor to energy & resource use. We have recently renewed ISO 14001:2015 certification for BS environmental managementClimate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentPurchased goods and services, Waste generated in operations and Business travel7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change adaptation and resilience?
Optional commentThe action framework for Banco Sabadell’s Commitment to Sustainability is underpinned by four strategic pillars, for which a set of commitments is defined. Each one is described by objectives and activated by two kinds of levers: transformation levers and promotion levers. The four strategic pillars are: Progress as a Sustainable Insitution, Support customers in the transition to a sustainable economy, Offer investment opportunities that contribute to sustainability and Work together for a sustainable and cohesive society. The first pillar, as a institution, is commited to be neutral in GHG emissions and continue reducing our own consumption and incorporating the ESG criteria in governance and participate in the most relevant partnerships. In terms of providing funding, the BStartup10 program in 2021, launched the first edition of BStartup Green to invest in startups that, through technology or digitisation, are able to facilitate the transition to a more sustainable world, from the perspectives of energy transition, industry 4.0, smart cities and the circular economy.Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
Overall Environment
21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.
The Bank sees sustainability as an element of transformation, increasing competitiveness across companies and generating positive social and environmental impact for people and the planet. In its role as a key agent to promote the transition towards a more sustainable economy, the Bank has included sustainability in the contents of the 360 Visit and the conversation between customers and relationship managers. Moreover, during the past year, the Sustainable Finance Plan has become part of a new ESG roadmap, which reinforces material aspects whilst also including actions and broadening the aspirations of the alliances and commitments by signing new initiatives such as the Net Zero Banking Alliance (NZBA), that strengthen the strategy against climate change; therefore, the Bank commits to making all its loan and investment portfolios neutral in their net greenhouse gas emissions by 2050, in line with the more ambitious targets of the Paris Agreement. These commitments involve setting targets for 2030 (or before) and for 2050, with intermediate targets every five years for the most GHG intensive sectors, leveraged in the analysis of customers’ carbon footprints and sector decarbonisation paths based on scientific criteria from internationally recognised bodies. This new initiative reinforces the changes that were made in previous sectoral frameworks such as the Collective Commitment to Climate Act ion of the AEB (Spanish Banking Association), CECA (Spanish Confederation of Savings Banks) and the ICO (Spanish Official Credit Institute) ratified in 2019 during COP25, whose objective is to reduce the carbon footprint of balance sheets. The bank works in remediation of the impacts that directly causes through its facilities and the use of resources on the environment in which it operates. The strategy is based either on reducing emissions of greenhouse gas (GHG) and other ways of polluting and offsetting its own emissions. In consequence, the Bank has offset emissions through the investment in forestry projects in Spain, certified by MITECO (Ministry for Ecological Transition). In addition, one of the offsetting initiatives in 2021 was joining MasterCard’s global project, Priceless Planet Coalition, the main goal of which is to plant 100,000 trees by 2025. Meanwhile, TSB offset its Scope 1 and 2 emissions through reforestation projects in Bolivia and will invest in forests in the United Kingdom to offset its future emissions.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentThe Group undertakes to safeguard integrity and promote a culture of zero tolerance towards corruption, expressly prohibiting any and all actions of this kind. Similarly, as a signatory of the United Nations Global Compact, it is committed to complying with the ten principles established therein, among them that of working to combat corruption in all its forms, including extortion and bribery. One of the basic elements for consolidating a corporate culture is the existence of a set of regulations that reflects the firm commitment of all units to comply with legislation, starting with the Management Body. Furthermore, the Bank has a Code of Conduct and Policies on Compliance, Conflicts of Interest, Anti Money Laundering & Counter Terrorist Financing, Corporate Crime Prevention and Anti Corruption, which are applicable to the entire Group. The Anti Corruption Policy defines all those actions included in the concept of corruption, as well as related actions that are prohibited. Both the Code of Conduct and the Policies detailed above are regularly reviewed and, where appropriate, updated. As regards the Group’s Code of Conduct, its latest update included specific sections on the fight against corruption and bribery.2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
Optional commentSee paragraph 2.2.7 Anticorruption Policy: https://www.grupbancsabadell.com/corp/files/1454349057248/politica_anticorrupcion_gbs_en.pdf See also Conflict of Interest General Policy: https://www.grupbancsabadell.com/corp/en/corporate-governance-and-remuneration-policy/conflicts-of-interest-general-policy.htmlPrevention
3. Who receives training on anti-corruption and integrity?
Optional commentIn relation to the identification and control of corruption related risks, it is worth highlighting that the Institution has a Corporate Crime Prevention Programme, which has a specific section on the fight against corruption. Furthermore, its training programme includes a specific course on anti corruption, which all employees are required to complete. As a result of the activities carried out as part of the aforesaid Corporate Crime Prevention Programme and the management of the whistleblowing channel, which is d escribed later on in this document, it is also worth noting that no risks related to corruption have materialised in 2021 or in 2020.3.1. How often is such training provided?
4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
Optional commentNo cases of corruption have materialized, neither in 2021 nor in previous years.6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Optional commentNo cases of corruption have materialized, neither in 2021 nor in previous years.7. Does your company engage in Collective Action against corruption?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.
Annual review of the crimes that punish corruption and that, according to the Spanish Penal Code, may entail criminal liability for the legal person. These are the crimes of bribery, influence peddling, corruption in international transactions, corruption and embezzlement. Analysis of the different areas potentially exposed to said crime due to their activity. Valuation of these risks obtaining a starting inherent risk. Identification of a total of 155 controls that would mitigate said risks, integrating them into the annual anti-corruption program. Analysis and assessment of said controls to measure their effectiveness. Obtaining evidence that demonstrates the execution of said controls, and evaluation of the same to measure the solidity of these controls. Obtaining a residual risk, resulting from applying the solidity of the controls identified to the initial inherent risk. Within a 4-level scale (LOW, MEDIUM-LOW, MEDIUM-HIGH and HIGH), the average residual risk obtained has been set at a MEDIUM-LOW threshold.