Frequently Asked Questions

About EthicsPoint

Addressing fraud, wrong doing and other misconduct in the work place.

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX to assist management and employees work together in addressing fraud, wrongdoing, and other misconduct in the workplace, all while cultivating a positive work environment.

We want to maximise the opportunity and ability for colleagues to Speak Up.

  • By creating open channels of communication, we can promote a positive work environment and maximize productivity.
  • Whilst we are required by regulators to have a mechanism to receive anonymous reports, we also want to maximize opportunities for colleagues to Speak Up.
  • An effective reporting system compliments our strategic blueprint drivers

Reporting – General

May I report using either the Internet or the telephone?

Yes. With EthicsPoint, you have the ability to file an anonymous or named report via either the telephone or the Internet.

What types of situations should I report?

The EthicsPoint system is designed for employees to report breaches of our code of conduct, legal or regulatory violations and breaches of law. For a further list of the type of concerns you should raise via this platform, please consult the Whistleblowing Policy.

Shouldn't I just report it to my manager, security, or human resources and let them deal with it?

Ideally, you should bring any concerns forward to your line manager, or another manager. We recognise, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with EthicsPoint. We would rather you report anonymously than keep the information to yourself.

Why should I report what I know? What’s in it for me?

We all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment.

Does management really want me to report?

Yes. In fact, we need you to report. Colleagues are our eyes and ears. You know what is going on in Santander. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimise the potential negative impact on the Company and our people. Also, offering positive input may help identify issues that can improve our culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server to prevent any possible breach in security. EthicsPoint makes these reports available only to specific individuals within Whistleblowing Team who assess and triage the report. If appropriate it will be then referred for further investigation.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every website that my device connects with, and won’t this log identify me as a report originator?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your device to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work device, you have the option of using a device outside our work environment through the EthicsPoint secure website. Many people choose this option, as EthicsPoint’s data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

A report from home or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is maintained. Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident.

Is the telephone hot line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish.

Tips and Best Practice

I am aware of some individuals involved with unethical conduct and malpractice, but it doesn't affect me. Why should I bother reporting it?

We want to promote and encourage ethical behaviour. Speaking Up is one of our behaviours. Unethical conduct or malpractice, at any level, ultimately hurts the company and will affect colleagues in some way.

I am not sure if what I have observed or heard is a breach of company policy but it just does not look right to me. What should I do?

Raise it. EthicsPoint can help you prepare your report so it can be properly understood. We'd rather you raise a report which turns out to be harmless than let possible wrong-doing or malpractice go un-reported.

What if my manager or other managers are involved in malpractice or wrongdoing? Won’t they get the report and start a cover-up?

The EthicsPoint system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named. This includes a conflict of interest process for the Whistleblowing Team.

What if I remember something important about the incident after I file the report? Or what if Santander has further questions for me concerning my report?

When you file a report using the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique report key and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We ask that you return to the site in the time specified to answer questions.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

Can I still raise a concern if I don’t have access to the internet?

You can raise a concern on EthicsPoint from any computer that can access the Internet. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint hotline, which is available 24 hours a day, 365 days a year.