Sustainability Report | 2022

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
About this report
Scope
This report relates to the activities of Santander 
Consumer Bank AS (organisation number: 
983521592) from 1 January to 31 December 
2022. Santander Consumer Bank AS is a 
Norwegian commercial bank that holds a 
banking licence granted and regulated by the 
Financial Supervisory Authority of Norway, and 
which also operates in Sweden and Denmark, 
with a wholly owned subsidiary in Finland, 
collectively referred to as “the Group”. It is a 
fully owned subsidiary of Santander Consumer 
Finance S.A., which in turn is owned by Banco 
Santander S.A.
Regulations, reporting standards and other 
references
The report is developed in accordance with the 
Global Reporting Initiative (GRI) 2021 Universal 
Standards and highlights the organisation’s 
progress on ESG and sustainability related 
matters. Additionally, the Task Force on 
Climate-related Disclosures (TCFD) framework 
is utilised as a reference to report climate 
related risks and opportunities. The report also 
references progress on specific UN Sustainable 
Development Goals.
GRI indicators are included in each chapter 
and sub-chapter corresponding to the GRI 
content index. Likewise, Annex II Global 
Reporting Initiative (GRI) content index provides 
a consolidated overview of the reporting 
standards as well as referencing to where 
related information can be found in this report 
and elsewhere.
Material aspects and stakeholder involvement
The Group maintains an active dialogue with 
stakeholders to understand their expectations 
and has conducted a materiality assessment 
to identify material ESG-related topics. 
Emerging regulatory requirements and market 
practices are closely monitored and the Group 
is committed to continuing its focus on evolving 
its response and maturity related to ESG 
matters.
This report provides insight into the 
sustainability of the organisation’s Nordic 
operations, in particular in relation to internal 
and external impacts. The process for defining 
material topics and materiality assessment 
findings is presented in chapter 3 ‘Materiality 
Assessment’. 
External verification
PricewaterhouseCoopers AS, an independent 
firm charged with auditing the financial 
statements of Santander Consumer Bank AS, 
has issued a verification report, with limited 
assurance, on the non-financial information 
required under the GRI standards found in this 
report. The assurance conclusion can be found 
in the “Independent verification report” at the 
end of this report.
This sustainability report is issued by Santander Consumer Bank AS and 
provides consolidated non-financial information relating to the organisation’s 
progress on Environmental, Social and Governance (ESG) matters for the 
financial year 2022. The report is developed in accordance with the GRI 2021 
standards. 
GRI 1, 2-2, 2-3, 2-5

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Table of contents
Sustainability Report | 2022
Santander Consumer Bank AS
Published 13 September 2023
Introduction
•	
CEO’s foreword
•	
Sustainability highlights 2022
Our Approach to Responsible Banking
•	
Santander Responsible Banking Ambitions, Strategy and Agenda 
•	
Nordic approach to Responsible Banking 
•	
Climate risks and opportunities
Materiality Assessment
•	
Process to identify material topics 
Our Sustainable Priorities
•	
Material topics
•	
Non-material topics
Annexes
I.     Our progress in numbers
II.    Global Reporting Initiative (GRI) content index 
III.   Task Force on Climate-related Financial Disclosures (TCFD)
IV.   Overview of the Group’s policies linked to Material Topics
V.    How the Group works with Sustainable Development Goals (SDGs)
Independent Verification Report
Contact Details

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
CEO’s foreword and 
Sustainability Highlights 2022
Doing business in a responsible 
and sustainable way
Grupo Santander, one of the world’s 
largest financial groups, has ambitious 
and progressive sustainability goals and 
was in 2022 ranked amongst the world’s 
most sustainable banks in the Dow Jones 
Sustainability Index1, placing amongst the 
top three in Europe. Our Nordic organisation 
is fully committed to these goals and to 
establishing sustainability throughout our 
end-to-end value chain. 
This summer we have witnessed record 
temperatures and wildfires around the globe. 
It serves as a stark reminder of the need 
to continue the transition to a low carbon 
economy. However, individuals alone cannot 
solve the world’s sustainability challenges.
We are fully mindful that our business is 
to finance consumption. Consumption, by 
its nature, has a climate footprint, whether 
this be vehicles, consumables or travel. The 
motivation is not to inhibit consumption, 
moreso to support our customers in making 
sustainable consumption choices. This 
philosophy is exemplified by our brand concept 
“When it feels right”, where we raise the 
question of what responsible consumption 
means for people living in the Nordics.
Shifts in consumption behaviour amongst 
consumers towards more sustainable choices 
presents businesses with opportunities. We, 
as a bank, are committed to being there to 
support our customers and partners in making 
this transition. 
In our view, society’s transition to a more 
sustainable and equitable future requires four 
key elements; governmental policy making, 
corporate response, consumer willingness and 
importantly, organisations such as ourselves 
to finance it. A very relevant example of how 
these elements come together in combination 
for the good of society is the continued 
adoption by Nordic consumers of electric 
powered vehicles. As the region’s largest auto 
finance provider, we are making a significant 
contribution to the green transition within the 
mobility sector.
In Santander, we believe in a broad approach 
to sustainability, from how we take care of our 
employees and support our local communities, 
to how we advise and work together with 
our customers and partners on sustainable 
choices. Listening to our stakeholders is of 
vital importance to ensure we are focused on 
those sustainability topics that are of most 
relevance and importance to them and us. 
In releasing our second Sustainability Report, 
we are proud of our Responsible Banking 
achievements in 2022 – summarised below. 
We are mindful though that much work lies 
ahead, in particular in adopting and adapting 
to the emerging regulatory landscape as 
well as embedding sustainability principles 
throughout the organisation. We are fully 
committed to this for the good of our 
customers, partners, stakeholders and 
society at large.
“Society’s transition 
to a more sustainable 
future requires 
four key elements; 
governmental policy 
making, corporate 
response, consumer 
willingness and 
importantly, organisations such as 
ourselves, to finance it.”
As an organisation, we are committed to our Responsible Banking agenda 
and in supporting our customers’ and society’s transition to a more 
sustainable future.
Michael Hvidsten
CEO, Santander Consumer Bank AS
1) Santander Press release 10 December 2022

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Sustainability highlights 2022
ESG component
Strategic ambition
2022 Highlights
Environmental
Support climate 
transition
Deliver on Santander’s Net Zero 
ambition by 2050, helping our 
customers in their transition to a 
sustainable and low carbon economy
As a member of the Banco Santander Group, the ambition to become net zero by 2050 is fully embraced.
The Group continues to support and finance the decarbonisation transition in transportation. As a leader in the Nordic auto 
finance market, the Group’s share of all new BEV (Battery Electric Vehicles) financed in the Nordic market was 13.9%.
The financing of home energy solutions is an increasingly attractive business segment. The Finnish market is the Group’s 
largest market for home energy financing, and the home energy solutions business has grown significantly in 2022 by 266% 
(by number of contracts).
The Group has progressed initiatives to capture and report climate related aspects both in our own operations as well as in 
our financing activities, aligned with emerging regulatory requirements.
The Group is implementing the groupwide Santander Sustainable Funding Framework for future issuances of green bonds.
100% of the energy supplied to the offices in the Nordic countries came from renewable energy sources.
Social
Contribute to generate 
positive returns to 
society
Support productive inclusion across 
our main stakeholders, employees, 
customers, and communities
In April 2022, the Group launched its new brand concept “When it feels right” to encourage responsible consumption.
The Group continued to place strong focus on responsible lending and compliance with regulations.
The Group mobilised to adopt and respond to the Norwegian Transparency Act in relation to human rights and decent 
working practices in its value chain. In June 2023, the inaugural Transparency Act Statement was published on the Group’s 
Norwegian website.
The Group is a proud sponsor of many sporting events across the Nordics, in addition to supporting selected charities.
The Group continued to operate a Flexiworking model to promote a healthy work-life balance amongst its employees.
In 2022, the Group donated NOK 250 000 to humanitarian aid through the Norwegian Red Cross, in addition to donations 
from Santander Global to assist in the response to the war and resulting humanitarian crisis in Ukraine.
Governance
Embed ESG across the 
organisation
Incorporate ESG in behaviours, 
policies, processes, and governance 
throughout the Group
During 2022, the Group further progressed operationalisation of its Responsible Banking agenda, including the publication 
of its inaugural Sustainability report 2021.
The Group adopted the groupwide Santander Responsible Banking Framework.
The Group continued its focus on embedding ESG risks and opportunities into its risk management and other strategic 
management processes.
The Group rolled out a broad program of mandatory training on internal control and governance related aspects, including 
mandatory ESG training for all employees.
The Group further incorporated Responsible Banking updates into the Board of Directors’ agenda for 2023.

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Our Approach to Responsible Banking
Banco Santander’s vision is to play a major role 
in society’s transition to a low carbon economy, 
driving inclusive and sustainable growth and 
addressing social and environmental risks and 
opportunities. ESG is embedded throughout 
its culture and strategy, which is focused on 
helping customers transition to a low carbon 
economy, by offering them best in class 
sustainable propositions in a simple, personal, 
and fair way.
Banco Santander aims to be net zero in carbon 
emissions by 2050. This applies to operations 
and emissions from lending, advisory and 
investment services. Banco is a founding 
member of the Net Zero Banking Alliance 
(NZBA, under the United Nations Environment 
Programme Finance Initiative), committing 
them to:
•	
Support the transition of operational 
and attributable greenhouse gas (GHG) 
emissions from lending and investment 
portfolios towards pathways to net zero 
by 2050 
•	
Set intermediate targets for priority GHG 
emitting sectors for 2030 (or sooner)
•	
Prioritize client engagement with products 
and services that facilitate transition in the 
real economy
Banco Santander is also working to align 
portfolios with the Paris Agreement and 
maintaining carbon-neutral operations. Fully 
integrating climate within risk management is 
key to delivering on this ambition.
Figure 1. Banco Santander’s 3 Strategic Pillars
(S)
Promote inclusive 
growth
(G) 
Strong 
governance and 
culture across 
the organisation
Deliver our Net zero 
ambition by 2050
•	 Set targets in our portfolios to align with pathways to net zero, while taking into 
consideration other environmental goals 
•	 Support customers in their transition, engaging with them and developing a best-in-
class sustainable finance and investment proposition
Support inclusive 
growth across our 
main stakeholders: 
employees, customers 
and communities
•	 Diverse and inclusive workplace that fosters employees’ wellbeing  
•	 Support financial inclusion and financial health promoting access to financial 
products and services and offering financial education
•	 Support communities, with focus on Education, Employability and Entrepreneurship
Incorporate ESG in 
behaviours, policies, 
processes and governance 
throughout the Group
•	 Drive culture, conduct and ethical behaviour
•	 Integrate ESG into strategic processes, Risk Management & rest of relevant units 
and build capabilities
3 strategic pillars
Ambition
Strategic Actions
(E)
Support the 
transition to 
a low carbon 
economy
Santander Group Responsible Banking Ambitions, Strategy and Agenda
GRI 2-6, 2-25
A climate strategy based on the 
following green pillars has been 
established to support the green 
transition: 
Aligning portfolios with Paris 
Agreement goals
Supporting customers in the green 
transition
Reducing the organisation’s 
environmental impact
Embedding climate within risk 
management
ESG Agenda
Banco Santander has established 
a Responsible Banking agenda, 
based on three ESG-aligned 
strategic pillars to guide its 
actions – outlined here.

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Banco’s public commitments are outlined in the table below:
Climate and environmental targets
As a founding member of the UN Principles 
for Responsible Banking, Banco Santander 
has established a series of targets and public 
commitments in areas where it has the 
greatest potential impact. These are “SMART” 
(Specific, Measurable, Achievable, Realistic and 
Timebound) and are supportive of the targets 
set out in the Paris Agreement, including 
commitments related to exposures in the 
power generation, energy, aviation and steel 
industries related to reducing the greenhouse 
gas emissions intensity of Banco Santander’s 
lending portfolio.
In 2022, Banco Santander outlined 3 new 
interim targets to decarbonise its portfolios by 
2030, focusing om the most carbon intensive 
and material sectors: -29% absolute emissions 
financed in the energy (oil & gas) sector; -33% 
emissions intensity in the aviation sector and 
-32% emissions intensity in the steel sector, 
alongside a target of -46% emissions financed 
in the power generation sector set in 2021. 
Table 1: Banco Santander’s public commitments
2018
2019
2020
2021
2022
Target
Green finance raised and facilitated
(cumulative) (EUR)A
19 bn
33.8 bn
65.7 bn
94.5 bn
120 bn by 2025 
220 bn by 2030
Socially Responsible Investments AuMs
27.1 bn
53.2 bn
100 bn by 2025
Electricity used from renewableB energy sources
43%
50%
57%
75%
88%
100% by 2025
Thermal coal-related power & mining
phase-out (EUR)
7 bn
5.9 bn
0 by 2030
Emissions intensity of power
generation portfolioC,D
0.21
0.17
0.11 tCO2e /
MWh in 2030
Absolute emissions of energy (oil &
gas) portfolioC
23.84
16.98 mtCO2e
in 2030
Emissions intensity of aviation portfolioC
92.47
61.71 grCO2e /
RPK in 2030
Emissions intensity of steel portfolioC
1.58
1.07 tCO2e / tS
in 2030
Women in senior positions (%)E
20%
22.7%
23.7%
26.3%
29.3%
30% by 2025
Equal pay gapF
3%
2%
2%
1%
1%
~0% by 2025
Financially empowered people (cumulative)G
2.0 mn
4.9 mn
7.5 mn
11.8 mn
10 mn by 2025
Cumulative target
From...to...

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
The purpose of Santander Consumer Bank 
AS, including its branches and subsidiaries 
(hereafter referred to as “the Group”) is to 
“help people and businesses prosper” with the 
ambition to be the “leading Nordic consumer 
finance platform” by acting responsibly 
and earning the lasting loyalty of people, 
customers, shareholders and communities. 
Achievement of these ambitions is pursued 
through a strategy based upon 3 strategic 
pillars: 
•	
Grow Selectively – placing sustainable 
profitability at the core of existing and new 
business propositions
•	
Operate Efficiently – ensuring an efficient, 
robust, and scalable operating model and 
resource allocation
•	
Work Collaboratively – an organisational 
model underpinned by collaboration and 
engagement
A key foundation of this strategy is to operate is 
a “responsible and sustainable way” embracing 
the concept of “Responsible Banking” and 
through this ensuring full alignment with Banco 
Santander’s ESG strategy and ambitions. The 
Nordic approach to Responsible Banking is 
founded upon the achievement of a sustainable 
end-to-end value chain throughout business 
operations – as outlined in figure 2 below.
Nordic approach to Responsible Banking
Funding
Fund our business 
through sustainable 
funding sources
Business Practices
Promote sustainable 
business practices within 
own operations and 
organisation
Partners & Vendors
Collaborate with partners 
who share our own 
commitment to 
sustainability 
Value Propositions
Oﬀer sustainable value 
propositions to our 
customers and partners
Society & Communities
Support wider society 
and communities
Responsible Banking
Figure 2. Our value chain
UN Sustainable Development 
Goals
The Group’s sustainable value chain 
also embraces relevant UN Sustainable 
Development Goals, where it considers 
that it can provide the greatest positive 
contribution. These include:
How the Group works with these SDGs 
are outlined in Annex V.

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Executing on Banco Santander’s Climate 
Strategy
Banco Santander’s four pillar climate strategy 
guides the Group’s approach to supporting its 
Nordic customers’ sustainability transition and 
the achievement of net zero by 2050 ambitions. 
Figure 3 below illustrates how the Group 
supports and executes on Banco Santander’s 
climate strategy:
Aligning with Banco Santander’s commitments 
to the Net Zero Banking Alliance, the Group is 
working on developing 2030 and 2050 GHG 
emission targets and trajectories for its Nordic 
Auto finance business during H2 2023. The 
aggregated baseline emissions and emission 
targets for 2030 will be published in Grupo 
Santander’s Annual Report 2023. 
Climate risks and opportunities 
The application of the Task Force on Climate-
related Financial Disclosures (TCFD) framework 
provides analysis on the chronic and acute 
physical risks of climate change that our 
business operations are exposed to, as well 
as risks associated with the transition to a low 
carbon economy. 
The TCFD framework addresses four 
main aspects: Governance, Strategy, Risk 
Management and Metrics & Targets. How each 
of these aspects are addressed in this report 
are included in Annex III Task Force on Climate-
related Financial Disclosures (TCFD), as well 
as the results of the risk and opportunities 
assessment. 
Aligning portfolios with the 
Paris Agreement goals
Supporting customers in the 
green transition
Reducing 
environmental impact
Embedding climate into 
risk management
Contribute to limiting temperature 
increases to 1.5ºC in line with the 
NZBA and NZAMi
Support customers transition to a low 
carbon economy, offering guidance, 
advice and investments and business 
solutions
Remain carbon neutral and consume 
electricity from renewable energy
Manage climate and environmental 
risk according to regulatory & 
supervisory expectations
•	
Manage the environmental 
impact of our financing activities
•	
NZBA emissions target setting 
initiatives in our Auto portfolio
Offer sustainable financing 
propositions
•	
Auto Financing BEVs & PHEVs
•	
Solar panels & other green 
home improvements
•	
Bicycles & E-Bikes
•	
Manage the environmental 
impact of our own activities
•	
100% renewable electricity 
in our offices 
•	
Improve data on business 
travel and staff commuting
•	
Embed ESG risks into our 
EWRM processes
•	
Exposure monitoring by 
sector and emissions
•	
Integrate TCFD risks 
and opportunities
Figure 3. Embedding Banco Santander’s climate strategy into our Nordic environmental ambitions and activities
Embedding Banco Santander’s climate strategy into Nordic environmental ambitions and activities

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Materiality Assessment
The Group’s Responsible Banking efforts are guided by ensuring consciousness 
around the most material sustainability topics potentially impacting the 
environment, society and own business.
Process to identify material topics
A materiality assessment was conducted to identify the organisation’s most significant sustainability- 
related material topics. The assessment was performed as a four-step process in accordance with the 
GRI 2021 standards to assess actual and potential negative and positive impacts upon the economy, 
environment, and people, including impacts on their human rights:
1
Understand the 
organisation’s 
sustainability context
Conduct business and value chain mapping, including interviews with internal 
and external stakeholders2.
2
Identify actual and 
potential impacts
Produce a comprehensive list of potential and actual impacts – both positives 
and negative based on the value chain mapping in step 1.
3
Assess actual and 
potential impacts
Assess significance of impacts towards scale, scope and likelihood of the 
impact occurring, with greater emphasis on human rights-related impacts 
as per the updated GRI 2021 standards. Group positive and negative impacts 
into related topics considering social, economic and environmental factors.
4
Establish materiality 
threshold and 
validate
Evaluate (score and weigh) topics according to their individual impacts and 
obtain a list of potential material topics. Finally, determine the material 
topics by establishing a materiality-threshold through discussions with 
management and key stakeholders.
This resulted in a final list of six topics most materially impacting the 
environment, society and the business, establishing the league table of 
material topics and baseline for reporting.
The process identified nine key topics with associated impacts on the Group’s business and 
stakeholders (potential material topics). Of these, six topics were determined material, ranked in 
order of their actual and potential impacts. The material topics are listed below and constitute the 
Group’s league table of material topics and baseline for sustainability reporting. 
1.	
Promoting responsible consumption 
2.	
Minimising our carbon footprint
3.	
Ensuring human rights and good working conditions in our value chain
4.	
Acting as a responsible lender
5.	
Protecting the organisation’s and customers’ data
6.	
Preventing corruption, money laundering and terror financing
The remaining three topics were deemed relevant, but not of a material nature to the Group’s 
business activities. These were: Enabling financial inclusion and financial health, Supporting 
communities, and Promoting diversity, equality and inclusion.
Material topics validation
The six material topics identified for the 2022 Sustainability report are different from those 
reported previously (2021). The changes in material topics are a result of the Group’s increasing 
maturity in conducting materiality assessments, the use of updated GRI standards and an 
increased focus on impacts, as well as responses to new and developing legislation on human 
rights, such as the Transparency Act (Åpenhetsloven) in Norway, Anti-Money Laundering (AML) 
regulations and an increasing focus on data protection and cyber security.
The results of the materiality assessment have been reviewed by internal stakeholders, including 
senior management, to ensure validation and to capture insights into how the Group actively 
works with these topics. The material topics and are described in detail in the following chapter – 
“Our Sustainable Priorities”.
GRI 3-1, 3-2
 Table 2: Four-step approach to determine material topics
Figure 4. Material topics
2) Internal stakeholders are experts employed in different business areas of the organisation, external stakeholders are 
third-party expert organizations or individuals with industry experience

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Sustainability Report 2022
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Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
GRI 3-3, 203-2, 205-1, 205-2, 205-3, 305-1, 305-2, 305-3, 404-1, 404-2, 404-3, 407-1, 
408-1, 409-1, 414-1, 414-2, 418-1
Our Sustainable Priorities
Material topics
The six material topics identified represent 
primary areas where the Group can make 
positive environmental or societal impacts, or 
where it is crucial to address and mitigate any 
negative impacts arising from its operations.
To ensure standardisation, comparability, and 
continuous progress, relevant Global Reporting 
Initiative (GRI) Disclosures have been linked to 
each material topic. GRI Disclosure 3-3 has been 
applied across all identified material topics 
to provide an explanation of how we manage 
each of these areas. In addition, Environmental, 
Social, and Governance (ESG) Key Performance 
Indicators (KPIs) are used to measure the 
Group’s progress. These KPIs help guide 
decision-making processes, support strategic 
ambitions, and enhance sustainability efforts. 
Company-specific KPIs pertinent to the Group’s 
operations have been integrated where existing 
GRI Disclosures do not fully encompass the 
Group’s impact.
This chapter describes the management of 
each material topic, associated impacts on 
the environment, society and economy, KPIs 
and measures, as well as plans to improve 
performance consistent with the Group’s 
strategic ambitions. 
Promoting responsible consumption
GRI 3-3, 203-2
What this means to the Group
Aligned with Banco Santander, the Group is committed to achieving net-zero CO2 emissions by 2050 in support of the Paris 
Agreement’s climate change objectives. This applies both to own operations and customers’ emissions. Recognising the impact of 
consumer demand and credit provision on the environment, responsible and sustainable consumer choices to drive the transition 
to a low-carbon economy is a priority. This aligns with the Group’s sustainable value chain approach; offering sustainable value 
propositions to customers and partners.
Key activities and measures 
Consumer financing activities are split into two main product areas: auto finance and unsecured consumer finance. The status of 
the Group’s sustainable financing activities in 2022 are set out in table 3. 
Metric
Description
2022 Actual
2021 Actual
Auto
(New Business Volumes 
– € equivalent)
Electric vehicles financed in the Nordics
1 482 MM EUR
1 084 MM EUR
Commercial
(New Business Volumes 
– € equivalent)
Real estate (solar panels, green heating systems, 
energy efficiency & retrofit) and Clean mobility 
(bicycles and e-bicycles) in the Nordics
61.5 MM EUR
18.8 MM EUR
Green bonds
(Issuance size – € equivalent)
Volume of funding raised through Green Bond 
program; proceeds are used to fund new passenger EVs
0 MM EUR
248 MM EUR
Table 3. Sustainable financing in the Nordics

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Auto
As the Nordic region´s largest auto finance 
provider, the Group plays an important 
role in driving the transition to vehicle 
electrification. In 2022, 48% of all new 
vehicles financed (by number of contracts) 
were Battery Electric Vehicles (BEVs) 
and approximately 29% Plug-In Hybrids 
(PHEVs). Notably, BEV financing saw an 
impressive 26.8% growth compared to the 
previous year and the Group’s market share 
of new BEVs registered in the Nordics was 
13.9%, from 14.8% in 2021. 
The Nordics has been a frontrunner in BEV 
adoption, thanks to robust political support 
and favourable consumer subsidies, which 
in turn has attracted BEV manufacturers to 
focus on the region. Leveraging the Group’s 
market leading position in auto finance 
has established a prominent presence in 
the BEV financing market. BEV financing 
growth and market share in 2022 has been 
driven by the influx of new brands and high 
registrations in December 2022, due to 
tax changes coming into effect in January 
2023 in Norway and Sweden. Collaborative 
efforts with BEV manufacturers and 
dealerships have further enabled the 
achievement of higher finance penetration 
rates for BEVs compared to other vehicle 
types.
Nordics TOTAL
2022
2021
Difference (%)
New Business Volumes (NBV) (€ equivalent)
1482 MM EUR
1 084 MM EUR
36.6
New BEV registrations
277 614
204 449
35.79
Financed by SCB
38 471
30 349
26.76
SCB market share
13.86 %
14.84%
-0.99
Norway TOTAL
New BEV registrations
138 870
113 715
22.12
Financed by SCB
15 182
16 852
-9.91
SCB market share
10.93%
14.82%
-3.89
Sweden TOTAL
New BEV registrations
95 063
57 469
65.42
Financed by SCB
19 617
11 374
72.47
SCB market share
20.64%
19.79%
0.84
Denmark TOTAL
New BEV registrations
29 151
23 175
25.79
Financed by SCB
1 493
1 110
34.50
SCB market share
5.12%
4.79%
0.33
Finland TOTAL
New BEV registrations
14 530
10 090
44.00
Financed by SCB
2 179
1 013
115.10
SCB market share
15.00%
10.04%
4.96
Table 4. Development of the Group’s BEV financing in 2022 versus 2021
Figure 5. The Group’s BEV market share 2022
13.9%
86.1%

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Sustainability Report 2022
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Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Consumer
Within the consumer finance market, focus has been on Real Estate (including solar 
panels, green heating systems and other energy efficiency and retrofit improvements) and 
Clean Mobility (bicycles and e-bikes) sectors. The Group serves these markets through its 
Checkout lending product. The Group’s development within financing of Real Estate and 
Clean Mobility in 2022 versus 2021 is illustrated in the table below:
Eco Card
The Group launched its first “Eco” card in 
Norway in 2022, to be subsequently rolled 
out in other markets. TietoEVRY’s bio-based 
VISA card was selected as the Group’s Eco card 
solution, with the composition of cards being 
approximately 84% plant-based materials.
Way forward
The Group has a strategic commitment to 
support decarbonisation by financing the 
transition to vehicle electrification. Expectation 
is that the popularity of BEVs will continue to 
grow in the Nordics due to increasing climate 
awareness and implementation of regulations 
restricting internal combustion engine vehicles 
in Norway by 2025, Sweden 2030, Finland 
2035, and Denmark 2035. The Group aims to 
strengthen collaborations with OEMs and 
dealerships, facilitating customers’ transition 
to a low-carbon economy.
In unsecured consumer lending, the Real 
Estate and Clean Mobility segments represent 
attractive and growing markets. The Group 
intends to continue developing propositions 
in these areas to further promote responsible 
consumption and meet consumer demand for 
more sustainable products and technologies. 
Additionally, progression of sustainable 
initiatives in Deposits and Eco Cards are 
underway. 
Green Bonds 
Banco Santander’s Green, Social and 
Sustainability Funding Global Framework 
published in June 2022 guides green bond 
issuances. In the Nordics, green bonds are 
issued to fund financing of new and existing 
passenger BEVs. However, fixed income 
markets – including green bonds – suffered in 
2022 as a result of increased inflation, central 
bank rate increases, and the war in Ukraine. The 
Group issued no new green bonds in 2022. As 
per year-end 2022, the Group had outstanding 
green bonds of 1 000 MM NOK and 2 500 MM 
SEK.  
New Brand Platform
The new brand platform “When it feels right” 
was launched in April 2022, with the objective 
to connect prosperity with responsibility. The 
ambition is to empower and enable responsible 
consumer choices through customer centric 
finance solutions, knowledge sharing, and 
education. The platform relies on value-added 
information, motivating and guiding consumers 
to act responsibly and feel right about the way 
they finance their consumption.
Deposits
During Q4 2022, a new sustainable initiative 
linked to deposits activities was launched in 
Denmark, in collaboration with the Norwegian 
company CHOOOSE. For every new deposit 
customer, a tree has been planted in the 
Rondônia province in Brazil, with the purpose 
of capturing CO2 in the atmosphere, increasing 
biodiversity and battling deforestation. 
Norway 
2022
Sweden 
2022
Denmark 
2022
Finland 
2022
Total 2022
Total 2021
Real Estate
(New Business volumes 
- € equivalent)
0
0
4.2 MM 
EUR
52.3 MM 
EUR
56.5 MM 
EUR
17.2 MM 
EUR
Real Estate
(# Financed Contracts)
0
0
322
5 499
5 821
1 591
Clean Mobility
(New Business volumes 
- € equivalent)
0.3 MM 
EUR
0.9 MM 
EUR
3.5 MM 
EUR
0.2 MM 
EUR
5 MM EUR
1.6 MM 
EUR
Clean Mobility
(# Financed Contracts)
337
425
1 226
79
2 067
1 003
Table 5. Development of the Group’s consumer financing 2022 versus 2021
Eco cards are mainly composed 
of plant-based materials.
84 %

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Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Minimising our carbon footprint
GRI 3-3, 305-1, 305-2, 305-3
What this means to the Group
The Group is dedicated to reducing its carbon footprint and environmental impact, in line with Banco Santander’s net-zero 
ambition and the Paris Agreement’s objectives. The sustainable value chain approach promotes responsible practices within the 
Group’s operations, guided by the General Sustainability policy.
The Group’s carbon footprint is assessed using the Greenhouse Gas Protocol’s standardised reporting forms for GHG emissions3, 
which include:
Scope 1 Emissions from directly owned or controlled sources, such as company vehicles.
Scope 2 Indirect emissions from purchased energy.
Scope 3 Emissions generated upstream and downstream in the value chain, covering business travel and staff commuting.
Key activities and measures
Based on the Group’s current emissions coverage, estimated emissions for 2022 are outlined below:
Scope 1
Scope 2
Indirect emissions4  from electricity 
consumed in Group premises
Scope 3
Business travel from flights and staff 
commuting5
2022                                                 
2021
2022                                                 
2021
2022                                                 
2021
Under review
0 tCO2e
0 tCO2e
707.1 tCO2e
47.4 tCO2e
Market-Based on
100% of electricity 
consumed from 
renewable sources
35.7 tCO2e
Location-Based
Market-Based on
100% of electricity 
consumed from 
renewable sources
31.9 tCO2e
Location-Based
Business travel 
from flights 
80,2 tCO2e
Staff commuting 
627 tCO2e
(Staff commuting 
only)
3) See Banco Santander’s internal reporting criteria for emissions calculations are included in Climate Finance Report 2022 - June 2023
4) Electricity emissions factors obtained from the IEA (International Energy Agency)
5) Emissions factors corresponding to fuels and air travel obtained from the UK’s DEFRA (Department for Environment, Food and Rural Affairs)
Table 6. The Group’s estimated emissions in 2022

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During 2022, the Group migrated to a central business travel portal, enabling quantification and 
calculations of scope 3 GHG emissions related to flights used for business travel. Furthermore, to 
improve understanding of staff commuting-related emissions, an employee survey was conducted 
in Q1 2023. This survey enabled the extrapolation and estimation of GHG emissions resulting from 
employees commuting to their workplaces during 2022. As travel activity increased due to the 
easing of COVID-19 restrictions, this data provides valuable insights into staff commuting-related 
emissions and builds on an initial assessment in base year 2021, the first year the Group began 
recording and calculating emissions data.
In February 2022, Banco Santander introduced its Sustainable Finance Classification System (SFCS), 
which incorporates international industry guidelines, standards, and principles such as the EU 
Taxonomy, ICMA, LMA Principles, UNEP FI framework, and Climate Bond Standards. Adopting 
the SFCS across the Santander Group ensures a unified and standardised approach to ESG and 
sustainable finance, facilitating activity monitoring, product development, and safeguards against 
the risk of greenwashing. 
Way forward
The Group continuously seeks to improve capture, quality and provision of emissions data across 
the organisation and value chain, in support of Banco Santander’s net-zero by 2050 commitment. 
The greater part of emissions not yet measured primarily relate to the supply of financial products 
to consumers (Scope 3) particularly within the auto financing business, which constitutes a 
significant portion of the Group’s lending portfolio. As part of Banco Santander’s commitment to the 
Net Zero Banking Alliance (NZBA), the Group is in the process of evaluating the financed emissions 
of its Auto finance portfolio to develop decarbonisation goals and set a pathway to net-zero.
Starting from the financial year 2023, the Group will report the Green Asset Ratio in compliance 
with the EU Taxonomy requirements. Furthermore, under the European Banking Association’s Pillar 
III ESG-disclosure requirements, semi-annual reporting on ESG-related financing activities has been 
ongoing since 2023, which further strengthens reporting of emissions data across the portfolio.
Work to enhance the capture and reporting of Scope 1-related emissions is ongoing. The primary 
focus lies in addressing emissions related to company vehicles. The Group’s Nordic Company Car 
policy mandates that all new company vehicle renewals must be Battery Electric Vehicles (BEVs) 
with zero emissions, except in cases where the country’s infrastructure does not support BEV 
usage.
Scope 2 emissions are based on the electricity consumed on the Group’s premises. In 2022, the 
combined electricity usage was 2 272 201 kWh, showing a 4% increase from base year 2021 
(2 180 416 kWh), the first year that the Group began recording and calculating emissions data. As 
a result, location-based emissions increased to 35.7 tCO2e (2021: 31.9 tCO2e) mainly attributed to 
an increase in staff returning to the office after the COVID-19 pandemic. During 2022, 100% of the 
electricity used on the Group’s premises came from renewable sources, resulting in zero tonnes of 
CO2 equivalent (tCO2e) market-based emissions. 
100 %
During 2022, 100% of the electricity used 
on the Group’s premises came from 
renewable sources.
Net Zero
We are a part of Banco Santander’s 
commitment to the Net Zero Banking 
Alliance (NZBA).

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Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Ensuring human rights and good working conditions in our value chain
GRI 3-3, 407-1, 408-1, 409-1, 414-1, 414-2
What this means to the Group
The Group cares about upholding human rights and fair working conditions throughout its value chain. Employees are a priority, responsible 
and sustainable procurement practices are promoted, and work is conducted in collaboration with partners and vendors to ensure that they 
share the Group’s commitment to fundamental human rights.
Key activities and measures
In Norway, the Transparency Act (Norwegian: Åpenhetsloven) took effect on July 1, 2022. This law reflects the 
increasing demand for corporate responsibility across organisation’s value chains. Similar initiatives are also 
being developed in the EU, such as the Corporate Sustainability Due Diligence Directive (CSDDD). Under the 
Transparency Act, companies are encouraged to follow the OECD’s guidelines for multinational companies for 
conducting proper due diligence throughout their value chains. 
The Group is proud to have published its inaugural statement under the Transparency Act on June 26, 2023. No 
specific incidents or actual negative impacts on human rights and working conditions were identified as part of 
its initial due diligence on four identified duties of care (see table 7 for more details), although this is a continuous 
process that will continue to be monitored and assessed. 
Following publication, the Transparency Act statement and related information were also communicated to all 
employees on the intranet site. 
Table 7. Main results from due diligence 2022-2023
Working conditions and 
employment processes
Supply chain vendors
Distribution of products and services 
through business partners
Provision of credit to consumers
•	
No specific incidents, 
actual negative impacts or 
significant risks identified 
during the reporting period.
•	
Not considered to exist any 
material risks to human rights 
and good working as regards to 
the organisation’s employees.
•	
No specific incidents or 
actual negative impacts on 
human rights and working 
conditions identified.
•	
No higher risk vendors 
identified.
•	
No specific incidents or actual 
negative impacts on human rights 
and working conditions identified.
•	
The Group is actively monitoring 
partners identified as potentially 
higher risk during initial screenings, 
but as of this report’s publication, no 
significant risks to human rights and 
working conditions within the partner 
supply chain have been identified.
•	
Not considered to exist any 
material risks to human 
rights and working conditions 
as regards to the provision 
of credit to consumers.
Transparency Act 
Statement, published 
June 2023
Read the report here.

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Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Policies
The Group enforces several policies and procedures to ensure best practices and minimum 
standards for its operations, employees, partners, and vendors throughout its value chain. These 
include policies for Human Rights, Code of Conduct (CoC), Culture, and Flexi Working. Furthermore, 
Banco Santander’s Outsourcing and Third-Party Agreements Corporate Framework guides the 
Group’s collaboration with third parties and suppliers. For an extended overview of policies and 
procedures, refer to Annex IV.
The Santander Way
The Group aims to develop talented and motivated employees and to be an employer of choice. In 
2022, new corporate behaviours – “TEAMS” were launched to further support these ambitions. 
Cultivating a workplace where people can be themselves and which reflects our diverse society is 
a continuous process. The Group prioritises non-discrimination, inclusion, and equality throughout 
its workforce. In 2022, women held 30% of senior leadership and 39% of mid-managerial positions, 
representing 45% of the total workforce of the Group. 
The Gender Pay Gap was 16.6% in 2022 (2021: 15.5%) calculated on the total earnings of all male 
and female employees and therefore affected by workforce composition. The Equal Pay Gap (EPG) 
indicating fair wages for men and women in the same roles was -4.7% (2021: 11.8%). The Group 
targets equality in employee compensation within each of its local markets going forward. For 
more details see the Group’s Annual Report 2022 - Responsible Banking chapter.
The “Your Voice” quarterly internal survey showed improved employee engagement in 2022, with a 
score of 7.1, up from 6.5 in 2021 (on a scale of 1-10 where 10 is best).
Way forward
The Group is dedicated to complying with legislation and adapting to emerging market practices 
to safeguard fundamental human rights and decent working conditions. With the implementation 
of the Transparency Act in Norway, establishment of necessary processes to evaluate and address 
potential risks related to human rights and working conditions has been a priority. As part of due 
diligence process, key areas for improvement were identified and remain ongoing priorities. These 
include developing processes in line with market practices, improving data quality, and updating 
documentation relating to our business partners.
Think Customer | Embrace 
Change | Act Now | Move 
Together | Speak up
Equality
The Group targets equality in employee 
compensation within each of its local 
markets going forward.

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Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Acting as a responsible lender
GRI 3-3, 404-1, 404-2, 404-3
What this means to the Group
As a responsible lender, the Group offers simple, personal, and fair products and services, 
prioritising customer satisfaction and ethical consumer protection. 
Embracing responsible banking principles, customers’ needs and wider societal interests are 
taken into consideration to mitigate over-indebtedness and product misrepresentation. The Group 
practices prudent and responsible credit provision, providing fair banking solutions in accordance 
with the UN Principles of Responsible Banking. Furthermore, a culture of responsible banking and 
supporting employees’ growth through ESG-related training and awareness is nurtured. 
Key activities and measures
The table below outlines of the key performance indicators (KPIs) employed to monitor responsible 
lending performance, including the 2022 results compared with 2021 performance.  
Non-performing loans (NPL) ratio
Number of complaints
Net promoter score (NPS)
The NPL ratio for 2022 
improved to 2.62% from 
3.08% in 2021, indicating 
robust underwriting processes 
and a focus on customer 
affordability.
Complaint levels are closely 
monitored based on number 
of complaints per 10 000 
customers and adjusted by the 
Uphold Ratio (% of complaints 
resolved in the customer’s 
favour). In 2022, the average 
number of complaints per 10 
000 interactions – adjusted for 
the Uphold Ratio – was 2.25 
(2021: 2.22) which is below 
the internal Alert threshold 
of 3 complaints per 10 000 
customers, indicating effective 
levels of customer service.
NPS is used to identify the 
likelihood of customers 
recommending the Group. In 
2022, the Group significantly 
improved NPS tracking, 
with over 52,000 customer 
responses and 38,000 
comments received. The 
overall NPS score was 26.3, 
and country-specific scores 
were Norway: 21.4, Sweden: 
8.1, Denmark: 46.7, and 
Finland: 52.9.
Mandatory training
Training is a priority to raise awareness, reinforce internal control, and ensure responsible 
behaviour amongst employees. The Group’s digital learning platform, DOJO, supports individual 
and collective competence development. In 2022, employees underwent various mandatory 
training courses, covering topics within sustainability, business continuity management, regulatory 
compliance, AML, risk, antitrust, cyber security, PSD, diversity & inclusion and more.  
Additionally, Grow@Santander, a combination of activities and initiatives that focus on developing 
mindsets, work practices, leadership skills, and fostering a culture of continuous learning within 
the organisation, was introduced in 2022. Throughout the year, all employees received regular 
performance and career reviews.
The Group’s Consumer Protection policy guides its responsible lending practices. It is built on 
the value of treating customers fairly and encompasses the responsible lending principles of 
transparency, accurate and sufficient information, and responsible pricing.
Additionally, the Banco Santander Responsible Banking Framework sets common principles, roles, 
and governance to integrate ESG criteria for a sustainable business model, demonstrating an 
ongoing commitment to responsible banking.
Way forward
As a responsible lender, the Group is dedicated to support customers during challenging and 
uncertain times – helping people and businesses prosper in a responsible way. The values simple, 
personal and fair guide the approach to the Group’s product offering, focusing on simplification, 
accessibility and customer understanding. Development of customer experience monitoring and 
feedback also enables high-quality service and ongoing customer satisfaction.
Mandatory individual career development plans were introduced for employees to address future 
competence requirements. Additionally, responsible banking and ESG principles are integrated 
into credit and underwriting processes to ensure customer affordability. The Group is committed to 
adapting its business model and ensuring strong governance to comply with consumer protection 
regulations.
Table 8. Overview of key KPIs and results within responsible lending
Simple | Personal | Fair

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Protecting the organisation’s and customers’ data
GRI 3-3, 418-1
What this means to the Group
In today’s digital environment, it is critical to safeguard customers’ personal data by securing 
systems and managing risks related to cyber security, privacy, and data protection. The Group is 
fully committed to following personal data protection regulations and using customer data only for 
necessary and informed purposes throughout its entire life cycle, as required by law.
Key activities and measures
Privacy and data protection
The Group’s Data Protection & Privacy policy outlines functional responsibilities, key processes, and 
governance pertaining to the confidential handling of personal data. Adhering to the principles of 
lawfulness, transparency, and legitimacy, ensuring that individuals have control over their personal 
data, its use, and destination is top priority at Santander. This robust governance model is further 
strengthened by a dedicated Data Protection Officer to oversee policy implementation. 
Additionally, all reasonable measures to promptly erase or rectify irrelevant, inaccurate, or 
incomplete data are applied, and personal data is retained only for the period strictly necessary for 
its legitimate use.
Data cleaning week 
Data Cleaning Week is an internal initiative designed to raise employee awareness, educate and 
establish routines around the use of the Group’s data. During Data cleaning week 2022, employees 
deleted over 1 TB of data from servers and mailboxes. This thorough examination of data not only 
ensures compliance with requirements in the General Data Protection Regulation (GDPR) but also 
contributes to a reduction in energy consumption and its corresponding carbon footprint.
Cyber security
The Group places significant emphasis on operational risks related to cybersecurity, as outlined in 
the Cyber Security Corporate Framework. Furthermore, the Group implements knowledge sharing 
and collaboration with public and private sector organisation to actively combat cybercrime and 
assist customers and society in staying secure in the digital environment.
Awareness campaigns and mandatory training
Cyber security issues are communicated to employees to raise awareness around cyber threats 
and emerging hacking techniques and internal phishing exercises via email helps build resilience 
to threats and encourages employees to actively report any potential incidents or suspicious 
messages through appropriate channels. 
Furthermore, the Group ensures that its employees undergo various mandatory interactive training 
programs aimed at developing their cyber security competencies. By engaging in these training 
sessions, employees can strengthen their understanding and proficiency in cyber security, fostering 
a more secure and vigilant work environment.
Way forward
Ensuring data privacy and -protection continues to be an important priority for European and Nordic 
regulators. The Group places considerable importance on protecting customers through employing 
high standards and robust governance processes, whilst also preparing for future legislation such 
as the EU’s Digital Operational Resilience Act (DORA), to be implemented by January 2025.
Digital transformation continues to revolutionise the banking landscape, creating promising new 
business opportunities, but also increased risks related to technology and cyber security. This 
is why the Group is firmly committed to maintaining a strong control environment that not only 
strengthens operational resilience but also meets all regulatory requirements. The goal is to 
safeguard the Group’s reputation and credibility, and most importantly, to earn the loyalty and 
protect our customers, shareholders, and communities.

Throughout the year 2022, the Group’s Cyber Security team identified 
no data leaks, thefts, or losses, affirming the Group’s dedication and 
efforts to safeguard sensitive information.

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Preventing corruption, money laundering and terror financing
GRI 3-3, 205-1, 205-2, 205-3
What this means to the Group
The Group works actively and continuously to ensure compliance with all applicable financial crime 
regulations and mitigating actions, and to prevent any illegal activity relating to corruption, money 
laundering and terror financing arising from the use of its products or services.
Key activities and measures
Throughout 2022, the Group demonstrated a strong commitment to enhancing its internal 
control framework. The “Financial Crime Prevention Unit” was transformed into the “Anti-
Money Laundering Office” and the Group realigned activities under Operations for improved 
risk ownership. In addition, the Compliance and Conduct function introduced an AML taxonomy, 
enabling a comprehensive approach to managing financial crime regulations. Moreover, the 
existing AML Control Framework was reconstructed to better address this critical area.
Through such proactive measures, the aim is to bolster financial crime prevention capabilities, 
nurture a robust control environment, and uphold the highest standards of regulatory compliance. 
These efforts underpin the dedication to safeguarding the interests of stakeholders and 
maintaining the trust of customers and communities.
The general Code of Conduct (CoC) is applicable to all employees and Board members and sets out 
the ethics, principles and rules of conduct by which all the Group’s activities should be governed. 
The CoC comprises the central component of the Group’s Compliance Program. The CoC and 
associated Conflicts of Interest and Gifts and Invitations policies are available to all employees via 
the Group’s Internal Governance portal.
A digital and secure Whistleblowing channel exists for the reporting of improper conduct that 
is suspected to be illegal, or which violates the Group’s Code of Conduct (CoC) or other internal 
policies. Employees can also report concerns anonymously to the Compliance and Conduct 
function. Employees who report such concerns in good faith are protected from retaliation.
All employees must complete mandatory compliance training to meet internal requirements and 
demonstrate an understanding of ethical principles. The training covers Code of Conduct (CoC), 
Product Governance, Consumer Protection, Data Privacy, and Anti-Money Laundering (AML). New 
joiners complete the training during onboarding and are then required to refresh every two years. 
At the end of December 2022, 97% of employees had completed the training.
The Group’s risk culture, “Risk Pro”, is a core element of its corporate culture and purpose. Risk 
Pro emphasises that risk management is everyone’s responsibility, covering finance, operations, 
conduct, compliance, cyber security, reputation, fraud, financial crime, and climate. Each employee 
is accountable for recognising, controlling, managing, and reporting risks. Risk objectives are 
integrated into the performance review process to anchor Risk Pro throughout the organisation. 
More information is available in the Group’s Annual Report 2022 – Risk Management and 
Compliance chapter.
Following a routine inspection carried out in September 2021, Santander Consumer Bank NO 
received an administrative fine of 150 MM NOK from the Financial Supervisory Authority of 
Norway (NFSA). The fine was a result of deficiencies in the Group’s routines and systems for risk 
assessment, reporting and follow-up, and control of the customer portfolio. There was no suspicion 
of money laundering in any specific case – and no customers or partners were affected by the 
identified shortcomings. Compliance with AML regulations and addressing deficiencies highlighted 
in corrective orders from the NFSA has been top priority for the Group. On February 1st, 2023, the 
Board of Directors submitted a response to the NFSA, outlining the progress made in all areas.
Way forward
Preventing financial crime and ensuring compliance with related regulations remains a top priority 
for the Group. Continuous improvement remains essential to ensure adherence to relevant 
regulations, implementing mitigating actions, and preventing illegal activities. To achieve this, the 
Compliance & Conduct function has bolstered and refined the Compliance and Conduct program 
by structuring teams based on four compliance risk areas. This specialisation will allow compliance 
subject matter experts in each function to focus on their respective markets.
Furthermore, approval and implementation of a local version of Banco Santander’s Anti-Bribery 
and Corruption policy is anticipated during the second half of 2023.

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Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
In line with Banco Santander’s public commitments, the Group aims to foster financial 
empowerment, extend access to personalised financial products and services, and enhance overall 
resilience and financial well-being through educational initiatives.
Financial education is a strategic part of the Group’s responsible banking agenda and one of the key 
principles of our Nordic Consumer Protection policy. Through educational channels, the Group aims 
to make economic concepts easier to understand and provide the tools, skills and knowledge to 
support consumers to make informed financial decisions and safeguard against over-indebtedness.
To support financial health, the Elä kohtuudella (Live in moderation) calculator is active on the 
Group’s Finnish website and helps provide an indicative estimate for customers of their financial 
situation and capacity. Additionally, the Group has launched educational articles relating to 
personal finance and sustainability on their websites across the Nordics.
Non-material topics
Enabling financial inclusion and financial health
Supporting communities
Promoting diversity, equality and inclusion
Three additional topics were deemed relevant, but not material to the Group’s ESG and 
sustainability activities:
The Group seeks to support the communities it operates in and help them grow in a positive and 
sustainable way. Community investment is approached in accordance with the UN Sustainable 
Development Goals on promoting decent work and economic growth, fostering quality education 
and contributing to improving the health and wellbeing of the communities served.
Support to the people of Ukraine – Following the commencement of the war in Ukraine in February 
2022, the Santander Group supported the response to the ongoing humanitarian crisis, as well as 
ensuring compliance with the imposed sanctions against Russia. Top priority has been the safety 
and security of those associated with the Group located in Ukraine, including employees of our 
suppliers. In addition to the groupwide support, the Group donated 250 000 NOK of humanitarian 
aid through the Norwegian Red Cross.
Helsinki Ski Weeks – Between January and February 2022, the Group acted as the official climate 
partner to Helsinki Ski Weeks to promote consciousness around sustainability. Held in Helsinki 
Olympic Stadium, an estimated 200 000 participants had the opportunity to cross-country ski for 
free and culminated with sprint competitions between world class skiers.
The Group continuously strives to better reflect the communities it serves, help empathise with 
its customers and improve employees’ wellbeing and sense of belonging. Important KPIs to track 
progress include women in senior positions, Equal Pay Gap, Gender Pay Gap and “Your Voice” 
employee engagement survey scores, all disclosed in chapter 3. (“Material Topic: Ensuring human 
rights and good working conditions in our value chain”). 
The Group’s Culture policy establishes the guidelines and standards to embed a healthy and 
inclusive culture throughout the organisation, including setting and promoting the principles of 
diversity, equity and inclusion. Additionally, flexible working is encouraged, with practices and 
standards outlined in the Flexi Working policy. 
Oslo Business Forum – The Group renewed its cooperation for the business leader conference 
in 2022. The 2022 conference’s main focus was on “Future-Focused Leadership” with speakers 
including Steve Wozniak (co-founder of Apple) and Carla Harris (former managing director at 
Morgan Stanley).
Education through sports – The Group was a proud sponsor of the handball cup Santander Final4 in 
Denmark, as well as “En Svensk Klassiker”, a multi-discipline sporting competition. Furthermore, 
a number of employees took part in the Cycling4Cancer event in Denmark, with 200 000 DKK 
collected and donated to the Danish Cancer Society.

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Sustainability Report 2022
Annexes
I.	
Our progress in numbers
II.	
Global Reporting Initiative (GRI) content index 
III.	
Task Force on Climate-related Financial Disclosure (TCFD) 
IV.	
Overview of the Group’s policies linked to Material Topics
V.	
How the Group works with Sustainable Development Goals (SDGs)

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I. Our progress in numbers
KPI
Description
Current 
Period 
2022-12-31
Prior period 
2021-12-31
(In [unit of measurement])
[Unit]
Green bonds (Issuance size - € equivalent)
Volume of funding raised through established Green Bond program
0
248
MM EUR
EV market share
Number of new passenger EVs financed by the Group as a percentage of overall Nordic market
13,9%
14,8%
Group BEV market share (%)
Secured - "Green mobility" (Auto finance)
Total BEV financing by New Business Volumes - € equivalent (included as part of BEV financing 
table 2022 vs 2021) for Nordics (Total)
1 482
1 084
MM EUR
Auto finance - EV financing 2022 / 2021
Table of BEV financing in 2022 versus 2021 including total new BEV registrations, Financed by 
Group, Group market share and by country 
277 614
204 449
Number of new BEV registrations 
(Market)
(Norway, Sweden, Denmark and Finland)
38 471
30 349
Number of new BEV registrations 
(Group)
Consumer - home energy solutions
New Business Volumes - € equivalent in Norway, Sweden, Denmark and Finland
56,5
17,2
MM EUR
Consumer - bicycles and e-bicycles
New Business Volumes - € equivalent in Norway, Sweden, Denmark and Finland
5,0
1,6
MM EUR
Consumer - home energy solutions and bicycles 
and e-bicycles 2022 versus 2021
Total number of contracts and by country
5 821
1 591
Real Estate financed contracts
 (Norway, Sweden, Denmark and Finland)
2 067
1 003
Clean Mobility financed contracts
Scope 2 emissions
Emissions from consumed electricity (offices) according to GHG protocol  (market based)
0
0
tCO2e
Emissions from consumed electricity (offices) according to GHG protocol  (location based)
35.7
31.9
tCO2e
Consumed electricity (offices) usage (kWh)
2 272 201
2 180 416
kWh
Scope 2 emissions - electricity from renewable 
sources
Electricity (offices) consumed from renewable sources.
100%
100%
Renewable sources (%)
Scope 3 emissions
tCO2e emissions from employees commuting to place of work from home.
627,0
47,4
tCO2e
Scope 3 emissions
tCO2e emissions from flight business travel according to GHG protocol.
80,2
New KPI
tCO2e
Incidents of negative human rights or decent 
working conditions impacts in the value chain
Number of incidents (including whistleblowing, serious workplace incidents, customer 
complaints or incidents raised by business partners or supply chain vendors) of actual or 
potential negative impacts identified in the value chain.
0
New KPI
Number

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Total number of partners and vendors 
considered potentially higher risk
Total number of potentially higher risk partners and vendors for follow-up assessment after 
application of geography and industry risk lenses in due diligence process.
95
New KPI
Number
Women in senior positions
Women in the top three most senior categories in the Bank.
30%
33%
%
Gender Pay Gap
Calculated as the difference between the amounts paid to a man and a woman and not 
attributable to any admitted compensable factor divided by the amounts.
16,6%
15,5%
Gender Pay Gap (%)
Equal Pay Gap
Comparison of wages between women/men performing same job, on the same level, and on 
the same function. 
-4,7%
11,8%
Equal Pay Gap (%)
Employee engagement
“Your voice” survey scores conducted internally on a quarterly basis (on a scale of 1-10 where 10 
is best).
7,1
6,5
Score
Non-Performing Loans (NPLs)
% of Group´s total loans considered non-performing.
2,62%
3,08%
%
Net Promoter Score (NPS)
NPS – Overall and by country (Norway, Sweden, Denmark and Finland).
26,3
New KPI
Overall score
Formal complaints
Average (average of months) number of complaints per 10 000 customers, adjusted for the 
Uphold Ratio.
2,25
2,22
Number
Data loss
No identified leaks, thefts or losses of data.
0
New KPI
Number of data losses
Anti-corruption training
Total percentage of employees completing mandatory compliance training on anti-corruption, 
including required learning modules and knowledge tests (approx. 1 hour completion time).
97%
New KPI
%
Anti-corruption knowledge
Percentage of employees that the organisation's anti-corruption policies and procedures have 
been communicated to.
100%
New KPI
%

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II. Global Reporting Initiative 
(GRI) content index
GRI Standard
Disclosure
Page / Details
Omission
GRI 2: GENERAL DISCLOSURES
THE ORGANISATION AND ITS 
REPORTING PRACTICES
SR226  p. 2: About this report
2-1 Organizational details
Santander Consumer Bank AS (organisation number: 983521592) is a Norwegian commercial bank that holds a banking 
license granted and regulated by the Financial Supervisory Authority of Norway, and also operates in Sweden and 
Denmark, with a wholly owned subsidiary in Finland, collectively referred to as "the Group." The Group's principal 
offices are located at Strandveien 18, Lysaker, Norway. The Group is a wholly owned subsidiary of of Santander 
Consumer Finance S.A., which is part of Grupo Santander
-
SR22 p. 2: About this report
2-2 Entities included in the 
organization’s sustainability reporting
Santander Consumer Bank AS, its branches in Sweden and Denmark and the wholly owned subsidiary Santander 
Consumer Finance OY in Finland all consolidated in the same manner
-
SR22 p. 2: About this report
SR22: Contact
AR22 p. 58: Accounting Principles (1. - 2.3.)
2-3 Reporting period, frequency and 
contact point
Reporting period 01 January - 31 December 2022
2-4 Restatements of information
AR22 p. 58: Accounting Principles (1. - 2.3.)
-
2-5 External assurance
SR22 Annex: Independent verification report
-
Statement of use
Santander Consumer Bank AS has reported in accordance with the GRI Standards 
for the period between 01 January 2022 and 31 December 2022
GRI 1 used
GRI 1: Foundation 2021
Applicable GRI Sector Standard(s)
N/A - Reporting in accordance with Universal Standards 2021
GRI Standards: General Disclosures
6)  ”AR22” - Santander Consumer Bank AS Annual Report 2022, “SR22” - Santander Consumer Bank AS Sustainability Report 2022, “TAS” - Santander Consumer Bank Transparency Act Statement 2023

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GRI Standard
Disclosure
Page / Details
Omission
ACTIVITIES AND WORKERS
SR22 p. 8-9: Nordic approach to Responsible Banking
AR22 p. 12-17: Loans and deposits performance
2-6 Activities, value chain and other 
business relationships
TAS p. 13-14: Due diligence to identify actual and potential negative impacts
-
AR22 p.40: People and Culture 
AR22 p.145: Permanent employees as of 31.12.2022
SR22: p. 16-17: Ensuring human rights and good working conditions in our value chain
2-7 Employees
Temporary Employees by Head Count as of 31.12.2022:
Male: 39 (of which part-time 8)
Female: 66 (of which part-time 4)
-
2-8 Workers who are not employees
The Group does not currently have a register of non-employees. In the medium and long term the Group may evaluate 
the possibility of reporting this indicator.
Omission
GOVERNANCE
2-9 Governance structure and 
composition
AR22 p. 28-29: Corporate Governance
-
2-10 Nomination and selection of the 
highest governance body
The Group has a succession plan for directors that is build the external board assessment. 
Stated in the Group’s Rules of Procedure for the Board of Directors of Santander Consumer Bank AS, the Owners elect 
the members of the board of directors in the organisation’s General Meeting. The General Meeting is conducted in 
accordance with Aksjeloven. The number of members of the board is regulated through the organisation’s Articles of 
Association.  
Employee representatives are elected among the organisation’s employees and the roles and mandates are described 
in the Group’s Special Negation Body agreement.
The Group’s aim is to have at least 40% women as Board of Directors. Future legislations in Norway would require the 
Group to have at least 40% women of the board. At the end of 2022, the Group’s Board comprised 43% women when 
employee representatives are included with no decisions mandate. Without employee representatives the Board of 
Directors has 20% women. 
The Board has 2 external independent members and 1 vacant post, with the aim for a total of 3 external independent 
members. The chair of the Board is 1 of the external independent members. The Board has 3 Non-executive internal 
members employed by Santander Consumer Finance S.A.
Each Board member is assessed with a suitability assessment prior to the nomination and election to ensure they 
are suitably qualified. The Board is also assessed on yearly basis in a board assessment. Every 2nd year the Board 
assessment is completed with an external partner that assesses the Board’s work and competencies. Every alternative 
year this work is completed internally. 
-

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GRI Standard
Disclosure
Page / Details
Omission
2-11 Chair of the highest governance 
body
The Board of Directors does not include executive personnel.
-
AR22 p. 29 & 34: Corporate Governance & Governance, policies, and frameworks
TAS p. 6: How the Group ensures human rights and good working conditions
The object and activities of the Board focuses on the main areas, strategy, organization, monitoring and control, and 
Board specific tasks. The Board is overall responsible for the Bank’s organisation and administration of its affairs, 
including the internal governance and control structure. The responsibility includes establishing an appropriate 
organisation with clear responsibilities and to decide on overall objectives, strategies and major changes for the 
organisation as well as policies and procedures. More details in Rules of Procedure for the Board of Directors of 
Santander Consumer Bank AS. Governance and Internal Control Policy. 
(i) Board meetings and planned agenda and annual plan to cover the board’s responsibilities
(ii) The board gives feedback to management and takes actions, both in requests to management but also uses their 
control tools with Internal Audit and Compliance to follow up matters that they need closer attention to.
2-12 Role of the highest governance 
body in overseeing the management of 
impacts
The board receives CEO update every month with latest updates. The board receives an Organisation report once a 
year that describes the Organisation with strengths and development potential, the board also receives an HR report 
twice a year. Out from this the board take actions if needed.
-
TAS p. 6: How the Group ensures human rights and good working conditions
SR22 p. 8-9: Nordic approach to Responsible Banking
The Group employs a three-line of defence model, whereby 1st line functions are responsible for identifying and 
managing risk, 2nd line functions promote adherence to rules and supervisory requirements while monitoring 
risk performance, and where Internal Audit serves as the 3rd line of defence to conduct independent reviews of 
compliance with internal and external regulations and guidelines. The Group CEO and Board of Directors hold ultimate 
responsibility for ensuring compliance with applicable legal and internal obligations.
In addition to the above outlined responsibilities, the Responsible Banking team, located within the Chief Operating 
Officer function, is responsible for coordinating the Group’s development, approval, and publication of Transparency 
Act-related disclosures.
2-13 Delegation of responsibility for 
managing impacts
Sustainability Report is communicated once per year, Responsible Banking chapter in the Annual Report is 
communicated once per year
Responsible Banking updates provided to the Board of Directors 3 times per year 
Management updates on a regular basis and at a minimum once per quarter. 
Senior Management and CEO approve the Sustainability Report and Board of Directors to be informed.
-

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GRI Standard
Disclosure
Page / Details
Omission
2-14 Role of the highest governance 
body in sustainability reporting
Sustainability reporting is based on the Group’s Responsible Banking strategy and agenda approved by the Board and 
kept informed 3 times per year.
-
2-15 Conflicts of interest
Board members are assessed through suitability assessments to ensure they are not part of any other organisations or 
roles that could cause conflict of interest.
The Group has a special situation management policy stating when and how the board are informed and included in 
critical situations.
CEO shares an update every month with the Board and Internal Audit and Compliance have direct access to the Board. 
-
2-16 Communication of critical concerns
The Group does not publicly disclose the nature and number of critical concerns.
Omission
2-17 Collective knowledge of the 
highest governance body
Sustainability is an area previously assessed in Board assessments as a need to strengthen. The Board has 3 members 
both internal and external that is working in different roles on the scope of sustainability outside their work on the 
board of Santander Consumer Bank AS.
-
2-18 Evaluation of the performance of 
the highest governance body
The Group carries out a Board assessment annually. Every second year an external partner performs an independent 
Board assessment.
The assessment is part of the Group’s succession plan for Board members and steers the work of the Board for the 
following year.
-
2-19 Remuneration policies
AR22 p. 217: Note 30 - Remuneration
Board remuneration is decided in the General Meeting by the Group’s owner. The Board of Directors receive fixed pay 
and no sign-on bonuses, termination payments or clawbacks.
The Group’s Senior Management are remunerated according to the Group’s Remuneration Policy
AR22 p. 28 & 217: Corporate Governance & Note 30 - Remuneration
-
2-20 Process to determine 
remuneration
The Group engages stakeholders through the Bank’s internal remuneration committee. No external consultants are 
used in this process.
-
2-21 Annual total compensation ratio
The Group does not publicly disclose further information other than included in its Annual Report 2022 Note 30 - 
Remuneration (p.142-145)
Omission
2-22 Statement on sustainable 
development strategy
SR22 p. 4: CEO’s foreword
SR22 p. 40-41: Annex IV. Overview of the Group’s policies linked to Material Topics
AR22 p.34-35: Governance, policies, and frameworks
-

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GRI Standard
Disclosure
Page / Details
Omission
SRATEGY, POLICIES AND PRACTICES
Corporate frameworks and corporate instructions and Models approved by SCB’s Board of Directors
Policies and Procedures approved by the Group’s Board of Directors when required by law. In all other cases by the 
Risk Approval Committee. Pre-approval from other committees may be required as defined in the relevant committee 
charter.
Charters are approved by committee giving the mandate for changes in L2 Committee, approved by CEO.
Routine descriptions approved by the Document Owner.
All policies of the Group are created to reflect the activities in the organisation and the requirements and activities that 
should be carried out by the organisation and across its business relationships.
The Group’s Human Rights policy is the first policy to be published externally by the Group. Other internal policies are 
not externally published.
Human Rights Policy: https://www.santanderconsumer.no/globalassets/om-oss/om-santander/human-rights-
policy-2023.pdf 
2-23 Policy commitments
For employees, the Group’s Code of Conduct policy is communicated to new joiners at the onboarding stage. All other 
Group policy documents are available to all employees via the Internal Governance Portal on the Group’s Bank intranet 
site.
-
2-24 Embedding policy commitments
Grupo Santander’s Responsible Banking model includes all responsibilities outlined with relevant functions, as well 
as Grupo Santander’s commitment to “embedding ESG in the organisation”. The Responsible Banking model is not 
publicly disclosed.
-
SR22 p. 6-9: Our approach to Responsible Banking
SR22 p. 10: Materiality Assessment
SR22 p. 20: Preventing corruption, money laundering and terror financing
2-25 Processes to remediate negative 
impacts
Grupo Santander’s whistleblowing channel is publicly available on the Santander website: https://www.santander.
com/en/stories/introducing-canal-abierto-our-right-to-be-heard
-
AR22 p. 30: Compliance and Conduct
-
2-26 Mechanisms for seeking advice 
and raising concerns
SR22 p. 20 Preventing corruption, money laundering and terror financing
2-27 Compliance with laws and 
regulations
SR22 p. 20: Preventing corruption, money laundering and terror financing
Omission
AR22 p. 8, 25, 29, 33, 37
2-28 Membership associations
Additionally, the Group participates in the Finansieringsselskapenes Forening association (FINFO) in Norway, a 
membership organisation for companies that carry out specialist and consumer financing.
-
STAKEHOLDER ENGAGEMENT
2-29 Approach to stakeholder 
engagement
Internal communications to all employees via the Group’s Bank News intranet site.
External communications through various channels and websites in Norway, Sweden, Denmark and Finland including 
LinkedIn posts, Annual Report, Sustainability Report and media training and PR appearances for senior management.
-
2-30 Collective bargaining agreements
All employees are covered under locally defined collective agreements per country, with temporary employees 
defined by the Group as covered related to their working arrangements. The Group does not hold structured data on 
specific memberships and collective agreements.

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GRI Standard
Disclosure
Page / Details
Omission
GRI 3: MATERIAL TOPICS
MATERIAL TOPICS
3-1 Process to determine material 
topics
SR22 p. 10: Process to identify material topics
-
3-2 List of material topics
SR22 p. 10: Process to identify material topics
The previous materiality assessment conducted in 2021 identified eight material topics (Responsible lending, Digitization 
& customer experience, Decarbonize the portfolio, Green finance, Social responsibility, Financial inclusion, ESG products 
and services and Compliance) which were grouped into four themes (Green Finance, Financial Inclusion & Education, 
Responsible Lending and Customer Experience & Satisfaction). 
The drivers for the changes in the current reporting period, and the process for validation with stakeholders are described 
in SR22 p. 10: Process to identify material topics.
-
3-3 Management of material topics
SR22 p. 11-20: Our Sustainable Priorities - Material topics 
The precautionary principle is considered in the management of each material topic.
-
3-3 Management of material topics - 
Promoting responsible consumption
SR22 p. 11-13 
In addition to senior management, stakeholders in the Auto and Consumer sales functions are engaged in ESG forums to 
inform actions undertaken in relation to this material topic. These actions include developing appropriate KPIs and updated 
assessments of the effectiveness of these metrics.  
-
3-3 Management of material topics - 
Minimising our carbon footprint
SR22 p. 14-15 
In addition to senior management, stakeholders in the Facilities and HR functions are engaged in ESG forums to inform 
actions undertaken in relation to this material topic. These actions include developing appropriate KPIs and updated 
assessments of the effectiveness of these metrics.  
-
3-3 Management of material topics 
- Ensuring human rights and good 
working conditions in our value chain
SR22 p. 16-17 
In addition to senior management, stakeholders in the Sourcing, Commercial and HR functions are engaged in ESG forums 
to inform actions undertaken in relation to this material topic. These actions include developing appropriate KPIs and 
updated assessments of the effectiveness of these metrics.  
-
3-3 Management of material topics - 
Acting as a responsible lender
SR22 p. 18 
In addition to senior management, stakeholders in the Marketing, Risk and Operations functions are engaged in ESG 
forums to inform actions undertaken in relation to this material topic. These actions include developing appropriate KPIs 
and updated assessments of the effectiveness of these metrics.  
-
3-3 Management of material topics 
- Protecting the organisation's and 
customers' data
SR22 p. 19 
In addition to senior management, stakeholders in the Data Protection and Cyber Security functions are engaged in ESG 
forums to inform actions undertaken in relation to this material topic. These actions include developing appropriate KPIs 
and updated assessments of the effectiveness of these metrics.  
-
3-3 Management of material topics 
- Preventing corruption, money 
laundering and terror financing
SR22 p. 20 
In addition to senior management, stakeholders in the Compliance, AML and HR functions are engaged in ESG forums to 
inform actions undertaken in relation to this material topic. These actions include developing appropriate KPIs and updated 
assessments of the effectiveness of these metrics.  
-

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GRI Standard
Disclosure
Page / Details
Omission
INDIRECT ECONOMIC IMPACTS
GRI 203: Indirect Economic Impacts 
2016
203-2 Significant indirect economic 
impacts
SR22 p. 11-13: Promoting responsible consumption
-
ANTI-CORRUPTION
GRI 205: Anti-Corruption 2016
205-1 Operations assessed for risks 
related to corruption
AR22 p.20: Operational risk
SR22 p. 20: Preventing corruption, money laundering and terror financing
-
205-2 Communication and training 
about anti-corruption policies and 
procedures
SR22 p. 20: Preventing corruption, money laundering and terror financing
-
205-3 Confirmed incidents of corruption 
and actions taken
SR22 p. 20: Preventing corruption, money laundering and terror financing
The Group does not publicly disclose information on incidents of employee dismissal or disciplinary actions and the 
termination of business partnerships.
Omission
EMISSIONS
GRI 305: Emissions 2016
SR22 p. 14-15: Minimising our carbon footprint
305-1 Direct (Scope 1) GHG emissions
The Group does not currently report Scope 1 data. The Group is currently reviewing its reporting and the possibility of 
including this indicator in future reporting.
Omission
SR22 p. 14-15: Minimising our carbon footprint
305-2 Energy indirect (Scope 2) GHG 
emissions
Grupo Santander Climate Finance Report 2022 - June 2023 p. 70
-
SR22 14-15: Minimising our carbon footprint
Grupo Santander Climate Finance Report 2022 - June 2023 p. 70
The Group does not currently capture and report data on emissions related to its lending portfolio. The Group is working to 
capture emissions related to its passenger car portfolio (as part of NZBA) for future reporting.
305-3 Other indirect (Scope 3) GHG 
emissions
The Group does not include biogenic emissions.
Omission
GRI Standards: Topic-specific disclosures

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GRI Standard
Disclosure
Page / Details
Omission
TRAINING & EDUCATION
GRI 404: Training and Education 
2016
AR22 p. 39: People and Culture
SR22 p. 18: Acting as a responsible lender: Mandatory training
404-1 Average hours of training per 
year per employee
During 2022, the Group migrated to a new digital learning platform. As a result, the average hours of employee training for 
2022 are omitted from this index. Future reporting will benefit from additional data provided by the new learning platform.  
Omission
SR22 p. 18: Acting as a responsible lender: Grow@Santander initiative
404-2 Programs for upgrading 
employee skills and transition 
assistance programs
The Group does not currently offer transition assistance programs.
-
404-3 Percentage of employees 
receiving regular performance and 
career development reviews
SR22 p. 18: Acting as a responsible lender
-
FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING
GRI 407: Freedom of Association 
and Collective Bargaining 2016
407-1 Operations and suppliers 
in which the right to freedom of 
association and collective bargaining 
may be at risk
SR22 p. 16-17: Ensuring human rights and good working conditions in our value chain
TAS p. 3 - Key findings
-
CHILD LABOR
GRI 408: Child Labor 2016
408-1 Operations and suppliers at 
significant risk for incidents of child 
labor
SR22 p. 16-17: Ensuring human rights and good working conditions in our value chain
TAS p. 3: Key findings
-
FORCED OR COMPULSORY LABOR
GRI 409: Forced or Compulsory 
Labor 2016
409-1 Operations and suppliers at 
significant risk for incidents of forced 
or compulsory labor
SR22 p. 16-17: Ensuring human rights and good working conditions in our value chain
TAS p. 3: Key findings
SUPPLIER SOCIAL ASSESSMENT
GRI 414: Supplier Social Assessment 
2016
414-1 New suppliers that were 
screened using social criteria
SR22 p. 16-17: Ensuring human rights and good working conditions in our value chain
TAS p. 13: Supply Chain vendors
The Group has performed due diligence on all its active supply chain vendors as part of its obligations under the 
Transparency Act in Norway.

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GRI Standard
Disclosure
Page / Details
Omission
414-2 Negative social impacts in the 
supply chain and actions taken
SR22 p. 16-17: Ensuring human rights and good working conditions in our value chain
TAS p. 3: Key findings
TAS p. 10: Working conditions and employment processes
TAS p. 13: Supply Chain vendors
TAS p. 14: Distribution of products and services through business partners
TAS p. 15-16: Provision of credit to consumers
-
CUSTOMER PRIVACY
GRI 418: Customer Privacy 2016
418-1 Substantiated complaints 
concerning breaches of customer 
privacy and losses of customer data
SR22 p. 19: Protecting the organisation’s and customers’ data 
No identified leaks, thefts or losses of data identified during 2022.
The Group does not publicly disclose details or nature of customer complaints.
Omission

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III. Task Force on Climate-related 
Financial Disclosure (TCFD)
TCDF recommendations
Reference
Governance
a
Describe the board’s oversight of climate-related risks and opportunities
SR227: Annex II GRI content index 2-13
AR22: p. 29 & 34: “Corporate Governance” and “Governance, policies, and frameworks”
b
Describe management’s role in assessing and managing climate-related risks 
and opportunities
SR22: GRI content index 2-14
AR22: p. 29 & 34: “Corporate Governance” and “Governance, policies, and frameworks”
Strategy
a
Describe the climate-related risks and opportunities the organization has 
identified over the short, medium and long term
SR22: Table below; ‘Assessment of physical risks associated with climate change’ and 
‘Assessment of opportunities related to climate change’
b
Describe the impact of climate-related risks and opportunities the organisation’s 
business, strategy and financial planning
SR22: Table below; ‘Assessment of physical risks associated with climate change’ and 
‘Assessment of opportunities related to climate change’
c
Describe the resilience of the organisation’s strategy, taking into consideration 
different climate-related scenarios, including a 2 degrees or lower scenario
SR22: p. 6-9: “2. Our Approach to Responsible Banking”
SR22: Table below; ‘Assessment of physical risks associated with climate change’ and 
‘Assessment of opportunities related to climate change’
Risk Management
a
Describe the organisation’s processes for identifying and assessing climate-
related risks
AR22: p.20: Risk management and compliance – Climate & Environmental risk
b
Describe the organisation’s process for managing climate-related risks 
AR22: p.20 Risk management and compliance – Climate & Environmental risk
c
Describe how processes for identifying, assessing, and managing climate-
related risks are integrated into the organisation’s overall risk management
AR22: p.20 Risk management and compliance – Climate & Environmental risk
Metrics and targets
a
Disclose the metrics used by the organisation to assess climate-related risks and 
opportunities in line with its strategy and risk management process
SR22: p. 6-9: “2. Our Approach to Responsible Banking”
b
Disclose Scope 1, Scope 2, and of appropriate, Scope 3 greenhouse gas (GHG) 
emissions, and the related risks
SR22: p. 14-15: “Minimising our carbon footprint”
c
Describe the targets used by the organisation to manage climate-related risks 
and opportunities performance against targets
SR22: p. 6-7: “2. Our Approach to Responsible Banking”
SR22: p. 8-9 “2. Nordic approach to Responsible Banking”
TCFD Index
7)  “AR22” - Santander Consumer Bank AS Annual Report 2022, “SR22” - Santander Consumer Bank AS Sustainability Report 2022

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Banking risk types
Impact from Physical Risk 
(non-exhaustive)
Time 
Horizon
Impact from Transition Risk
(non exhaustive)
Time 
Horizon
Credit risk
Potential damage to collateral due to exposure to natural 
hazards.
Potential impact on households’ credit affordability due to 
energy price changes caused by an acute or chronic climate 
effect.
ST-MT

ST-MT
Risk that our customers are not be able to adapt their business model; incurring in losses that 
could prevent them from meeting their credit obligations (leading to higher default/non-
performing loans rate).
MT-LT
Residual value risk
No material impact expected.
Risk that advances in EV technology result in significant variance between assumed vehicle 
residual values and actual residual values.
Risk that expanding our presence in operational leasing increases our exposure to residual values 
and the potential risk of divergence between assumed and actual residual value.
ST MT

LT
Market risk
No material impact expected.
High and volatile energy prices cause less demand due to rising costs
SL-LT
Liquidity and Funding 
risk
Environmental crisis can lead to higher withdrawals which 
could put pressure on the liquidity position of the Bank. 
(Liquidity Risk).
LT
ESG factors can affect the availability and/or stability of funding (more expensive access to market 
funding, unstable deposits due to changing customer preferences). (Funding Risk).
ST-MT
Structural risk
No material impact expected.
Risks associated with poor implementation of a sustainable lending strategy. An overly aggressive 
pricing strategy can lead to misalignments in the income statement.
MT-LT
Capital risk
Physical/weather events can have an impact on the Group’s 
capital adequacy as they can impact the risk weight of its 
assets.
ST-LT
No material impact expected.
Operational risk
Extreme physical/ weather events causing damage to office 
premises (buildings/assets/etc.) causing disruption in servicing 
customers.
ST-LT
No material impact expected
Regulatory Compliance 
risk
No material impact expected
Risk of non-compliance with EU taxonomy laws and regulations relating to sustainable finance.
Risk of increasing costs related to reporting on laws and regulations relating to sustainable 
finance.
Risk of national government or municipal regulations and policy effects on the general Public – for 
example vehicle usage in urban areas.
Risk of significant increase in compliance burden relating to EU, national governmental or 
municipal climate-related laws and policies
Risk that meeting our NZBA requirements will lead to the need to reduce financing of non-zero 
emission vehicles, impacting profitability.
Risk of implementation of national legislation preventing the sale of non-zero emission vehicles 
impacting volumes and profitability.
ST-LT
ST-LT

ST-LT
ST-LT

MT-LT

MT-LT
Climate Risk assessment

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Model risk
No material impact expected
Risk that we are unable to develop technology solutions to inform consumers of the climatic 
impact of their consumption in line with their expectations; and as a result, lose customers due to 
lack of communication on the Group’s lending platform.
Risk of not capturing data needed to inform/advise the banks’ management in decision-making 
related to climate risk.
Risk of significant changes in consumer behavioural change based on climate-impact concerns 
impacting our financing activities.
Risk of wholesale shift in mobility models driven by climate-impact perspectives, rendering 
private car ownership, especially in urban areas, less attractive.
MT-LT


LT

MT-LT

MT-LT
Reputational risk
No material impact expected.
Risk of not meeting key stakeholder (customer, partners, regulators, investor) expectations that in 
the Group is operated in a responsible and sustainable manner.
Risk of association with partners who themselves are not viewed by key stakeholders as acting in 
a responsible and sustainable manner. 
Risk of partners not wanting to conduct business with the Group because they do not consider us 
as acting in a responsible and sustainable manner.
LT

MT-LT
MT-LT
Strategic risk
Extreme physical/ weather events impacting the global supply 
chain and our ability to achieve our strategic commercial goals.
ST-LT
Risk of not being able to adjust our business model in accordance with current regulations, losing 
competitiveness. 
Risks arising from significant changes in government support programs/ incentives that may have 
an impact on our business volumes.
Risk of changing customer perspectives whereby customers demand differentiated and lower 
pricing for financing «green assets».
Risk that scarcity or re-allocation of resources to meet ESG regulatory requirements impact 
execution of other ongoing initiatives or strategic projects.
LT

LT

MT-LT
ST-LT

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Theme
Opportunities
Time Horizon
Energy & Resource 
Efficiency
Cost reduction while promoting sustainability and responsible business practices by:
-	
Implementing digital processes and reducing paper usage both internally and towards customers. 
-	
Implementing energy-efficient lighting systems, optimising HVAC systems, and adopting smart building technologies.
-	
Implementing effective waste management practices and promoting recycling among employees. 
-	
Fostering a culture of sustainability among employees (Reducing business travels and commuting; EVs for employees)
-	
Sourcing products and services from environmentally responsible suppliers
Growth in wind and solar renewable energy financing and advisory by:
-	
Supporting customers’ adoption of green home energy solution (solar panels, geothermal heat, etc.)
Foster a circular economy (reuse and regeneration of materials and products) by: 
•	
Providing financing options for companies engaged in remanufacturing and refurbishing automotive components and parts.
•	
Promoting leasing and subscription models for vehicles, encouraging a shift from traditional ownership models. 
•	
Subscription-based services, where customers have access to a fleet of vehicles can be explored as a sust. mobility solution.
•	
Facilitating collaboration between OMEs and dealers, to encourage the reuse and sharing of automotive parts.
•	
Encouraging the reusability of consumables through financing (such as cell phones, computers, etc.)
ST
ST
MT
Automotive sector
Green Auto Loans or specialised financing options for customers looking to purchase or lease low-carbon vehicles (which can include 
competitive interest rates, longer loan tenures, and attractive terms especially tailored to EVs and other clean vehicles)
Provide financing options for the installation and development of EV charging stations
Financing of additional technologies that enable low-carbon mobility solutions
ST
ST
ST
Market intelligence
Enhanced Data Analytics by gathering significant customer data from which we can extract valuable and can help the Group to better 
understand customer preferences, identify trends, and make data-driven decisions to improve products and services, while ensuring 
compliance with regulatory requirements.
Enhanced transparency and accountability by reporting our environmental performance.
This can involve publishing sustainability reports, disclosing carbon emissions, and setting targets for resource efficiency improvements. Such 
reporting can help build trust with stakeholders and attract environmentally conscious customers.
ST
MT
Climate opportunities assessment

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Theme
Opportunities
Time Horizon
Carbon offset programs: Offering of green products to individuals and companies with offsetting options
Green deposits and green funding: 
•	
Develop specific green deposit products that offer competitive interest rates or other incentives to customers.
•	
Designate a portion of the funds from these deposits to finance green initiatives, such as renewable energy projects, energy-efficient 
building developments, or sustainable agriculture.
•	
Offer sustainability-linked loans that incentivise borrowers to achieve specific sustainability targets or metrics.
Growth in green bonds, green loans, and sustainability-linked financing instruments.
Continue issuance of green bonds following the Green, Social & Sustainability Funding Global framework adopted in 2022.
MT
MT
MT
Resilience
Embracing ESG principles and supporting the transition to a low-carbon economy can enhance the Group’s reputation and attract socially 
conscious customers. Demonstrating our commitment to sustainability, can foster customer loyalty and differentiate from competitors. This 
can lead to increased market share and long-term profitability.
MT

39
Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
IV. Overview of the Group’s policies 
linked to Material Topics
Material Topic
Policy / Steering document
Description
Promoting 
responsible 
consumption
Sustainable Finance Classification 
System (SFCS)
Ensures a consistent and standardised approach to sustainable finance, embedding ESG (environmental, social and governance) factors across the 
organisation, enabling activity tracking, product development and mitigating the risk of greenwashing. Based on international industry guidelines, standards 
and principles such as the EU Taxonomy, ICMA, LMA Principles, UNEP FI framework and Climate Bond Standards. 
Green, Social and Sustainability 
Funding Global Framework
A Banco Santander framework for all green, social and sustainability labelled funding instruments traded in sustainable capital markets covering use of 
proceeds, process for project evaluation and selection, management of proceeds and reporting in line with the International Capital Market Association’s and 
Loan Market Association’s guidelines.
Minimising our 
carbon footprint
General Sustainability policy
Compiles overarching sustainability and responsible banking principles, including voluntary undertakings, positioned to create long-term value for the 
Group’s stakeholders.
Nordic Company Car policy
Outlines key requirements and principles for the Group’s company cars, including the requirement for all company cars to be electric, unless infrastructure is 
inadequate to support an electric vehicle.
Ensuring human 
rights and good 
working conditions in 
our value chain
Human Rights policy
Outlines our commitment to protecting fundamental human rights, taking into consideration the UN Guiding Principles on Business and Human Rights.
Culture policy
Forms the standards and principles required to embed a consistent and healthy corporate culture within the Group, including the outlining of diversity, equity 
and inclusion principles.
Flexi Working policy
Sets out the new work model to support a healthy work life balance for Group employees.
Outsourcing and Third-Party 
Agreements Corporate Framework
Establishes the principles to be followed within Banco Santander during the decision-making and regular due-diligence process, and in the formalisation 
of outsourcing agreements, from outset until completion, with third parties. Defines basic responsibilities and sets minimum expectations of supervision, 
control and supplier compatibility with responsible banking values and CoC including relating to human rights, environmental protection and working 
conditions. Sets the minimum expectations of supervision, oversight and appropriate controls of business partners to ensure compliance with obligations 
established under applicable regulations in relation to the provision of services to customers.
Transparency Act Procedure
Sets out how the Group ensures respect for fundamental human rights and decent working conditions, as well as general public access and communication 
processes to anyone who requests in writing for general or specific information about how the Group manages actual and potential negative impacts on 
human rights and working conditions.
Acting as a 
responsible lender
Responsible Banking Framework
The Banco Santander Responsible Banking framework serves, at a global level, to propel the organisation towards a more sustainable business model that 
embeds Environmental, Social and Governance (ESG) criteria. The framework itself lays out common principles, roles, responsibilities, key processes, and 
governance arrangements.
Consumer Protection policy
Sets out operating standards that must be considered in the drafting of internal guidelines, as well as in the interactions with customers, their monitoring and 
supervision, to ensure the adequate protection of the financial consumer.

40
Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Material Topic
Policy / Steering document
Description
Commercialization of Products and 
Services and Consumer Protection 
Framework
Defines the product life cycle requirements for appropriate management and control of compliance, conduct and reputational risks that arise from the 
commercialisation process (design, sale and post-sale).
Complaints policy and Nordic 
Complaint Handling procedure
Sets out the minimum requirements for the handling of complaints, with the purpose to ensure that all complaints are managed in compliance with 
applicable local law, as well as internal and external regulations.
Furthermore, the handling procedure applies to all complaints received by the Group and sets forth the minimum requirements for the handling of such 
complaints.
Protecting the 
organisation’s and 
customers’ data
Data Protection & Privacy policy
Demonstrates how the Group carries out personal data processing in accordance with applicable data protection legislation, applicable to all employees, 
vendors and consultants handling personal data.
Cyber Security Corporate Framework
Establishes the principles that must be adhered to by the Group for the management of cyber security, defines basic roles and responsibilities, establishes 
key processes and defines the essential elements of its governance.
Preventing 
corruption, money 
laundering and terror 
financing
Code of Conduct (CoC)
Assembles ethical standards and rules of conduct employees must attend to and is fundamental to the compliance administration. The Group’s General 
CoC is applicable to all employees and members of the Board and sets the ethics, principles, and rules of conduct by which all activities of the Group should 
be governed, and therefore comprises the central component of Banco Santander’s Compliance Program. All employees are also required to complete a 
mandatory training in the Code of Conduct to ensure proper knowledge and awareness of the ethical principles.
Conflicts of Interest policy
Complementing provisions in the CoC, identifies the relationships, services, activities or operations where conflicts of interest may arise, as well as describing 
measures to reduce possible conflicts of interest, mechanisms and procedures to support identification, internal controls and external communication (for 
example to customers or regulators).
Anti-Money Laundering and Counter 
Terrorist Financing (AML/CTF) policy
Sets the criteria, roles and responsibilities, key processes and governance to be applied by the Group to prevent money laundering and terrorist financing and 
to comply with applicable regulations.
The policy is based on Banco Santander’s AML/CTF corporate policy and reference document which sets the minimum required standards for local units in 
regard to anti-money laundering and counter terrorist financing.
Whistleblower policy & Whistleblower 
procedure
Outlines how to access and raise concerns about breaches via the whistleblower channel, via external whistleblower channels or via public disclosure in a 
prudent and effective way. 
The Whistleblower procedure regulates the use and operation of the whistleblower channel, in accordance with the CoC and Whistleblower policy.
Gifts and Invitations procedure
Defines and specifies the requirements for accepting gifts and invitations, as also set out in general in the Group’s CoC. 
Code of Conduct in Security Markets 
policy
Describes the standards and rules to be followed for trading in securities markets.

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Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
V. How the Group works with Sustainable 
Development Goals (SDGs)
SDG
SDG Target Summary
Sustainability Report 2022 Reference
E
SDG 12 Responsible Consumption and 
Production
12.2 Achieve the sustainable management and efficient use of 
natural resources
Support customers in their transition to a low carbon economy:
•	
Material Topic: Promoting responsible consumption (p. 11-13)
SDG 13 Climate Action
13.1 Strengthen resilience and adaptive capacity to climate-
related hazards and natural disasters in all countries
•	
Ambition to be Net zero by 2050 in Material Topic: Minimising our carbon footprint (p. 14-15)
•	
TCFD Risks and Opportunities (Annex III)
S
SDG 3 Good Health and Well-Being
3.c.1 Health worker density and distribution
•	
Non-material topics – Supporting Communities (p. 21)
•	
Annex IV – Flexi Working policy
SDG 5 Gender Equality
5.5 Ensure women’s full and effective participation in, and 
equal opportunities for, leadership at all levels of decision 
making
•	
Women in senior positions, women on the board, Equal Pay Gap and Gender Pay Gap in Material 
Topic: Ensuring human rights and good working conditions in our value chain (p. 16-17) and Non-
material topics: Promoting Diversity, equality and inclusion (p. 21)
G
SDG 16 Peace, Justice and Strong 
Institutions
16.5 Considerably reduce corruption and bribery in all their 
forms
16.6 Develop effective, accountable and transparent 
institutions at all levels
16.7 Ensure responsive, inclusive, participatory and 
representative decision-making at all levels
Strong governance and culture across the organisation:
•	
Material Topic: Preventing corruption, money laundering and terror financing (p. 20)
•	
The Nordic approach to Responsible Banking
•	
Material Topic: Protecting the organisation’s and customers’ data (p. 19)
•	
Material Topic: Ensuring human rights and good working conditions in our value chain (p.16-17)
•	
Non-material topics: Promoting Diversity, equality and inclusion (p. 21)

42
Sustainability Report 2022
Sustainability report signed on behalf of Santander Consumer Bank AS
13 September 2023
Peter Sjöberg
Chief Operating Officer

43
Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Contact
Head Office: Santander Consumer Bank AS
Strandveien 18, P.O Box 177, N-1325 Lysaker, Norway
Eskil Pedersen | Nordic Communications Director
eskil.pedersen@santanderconsumer.no
Jon Pycroft | Head of Strategy and Investments
jon.pycroft@santanderconsumer.no 
Follow us at LinkedIn
Read more
         Transparency Statement Act 2023 
         www.santanderconsumer.no
         www.santander.com

44
Sustainability Report 2022
Contents 
Introduction  |  Our Approach to Responsible Banking  |  Materiality Assessment  |  Our Sustainable Priorities  |  Annexes
Independent Verification Report

PricewaterhouseCoopers AS, Postboks 748 Sentrum, NO-0106 Oslo 
T: 02316, org. no.: 987 009 713 MVA, www.pwc.no 
Statsautoriserte revisorer, medlemmer av Den norske Revisorforening og autorisert regnskapsførerselskap 
 
 
To the Board of Directors of Santander Consumer Bank AS  
 
 
Independent statement regarding Santander Consumer Bank AS’ sustainability 
reporting 
We have examined whether Santander Consumer Bank AS has prepared a GRI Index for 2022 and measurements 
and reporting of key performance indicators for sustainability (sustainability reporting) for the period of 1 January to 
31 December 2022. Our assurance engagement was conducted to obtain limited assurance. 
● 
Santander Consumer Bank AS’ GRI Index for 2022 is an overview of which sustainability topics Santander 
Consumer Bank AS considers material to its business and which key performance indicators Santander 
Consumer Bank AS uses to measure and report its sustainability performance, together with a reference 
to where material sustainability information is reported. Santander Consumer Bank AS’ GRI Index for 2022 
is available and included in Santander Consumer Bank AS’ Sustainability Report 2022. We have examined 
whether Santander Consumer Bank AS has developed a GRI Index for 2022 and whether mandatory 
disclosures are presented according to the Standards published by the Global Reporting Initiative 
(www.globalreporting.org/standards) (criteria). 
● 
Key performance indicators for sustainability are indicators of sustainability that Santander Consumer 
Bank AS measures and controls. The key performance indicators that are subject to our assurance 
procedures are available and included in a separate table included in Santander Consumer Bank AS’ 
sustainability report for 2022, specifically in the chapter "Annexes: Our progress in numbers". Santander 
Consumer Bank AS has defined the key performance indicators for sustainability and explained how they 
are measured in the same table under the column “Descriptions” (criteria). We have examined the basis 
for the measurements and whether these are developed, measured, and reported in accordance with the 
criteria. 
 
 
Management’s responsibility 
 
Management is responsible for Santander Consumer Bank AS’ sustainability reporting and for ensuring that it is 
prepared in accordance with the criteria described above. Their responsibility includes designing, implementing  
and maintaining internal controls that ensure the development and reporting of the GRI Index and key  
performance indicators for sustainability. 
 
Our independence and quality management 
 
We are independent of the company in accordance with the law and regulations and the International Ethics 
Standards Board for Accountants’ International Code of Ethics for Professional Accountants (including International 
Independence Standards) (IESBA Code), and we have fulfilled our ethical obligations in accordance with these 
requirements. We use ISQM 1 - Quality management for firms that perform audits or reviews of financial 
statements, or other assurance or related services engagements and maintain a comprehensive system of quality 
control including documented guidelines and procedures regarding compliance with ethical requirements, 
professional standards and applicable legal and regulatory claim. 
 
Auditor’s responsibilities  
 
Our responsibility is to express a limited assurance conclusion on Santander Consumer Bank AS’ sustainability 
reporting based on the procedures we have performed and the evidence we have obtained. We conducted our 
work in accordance with the Standard on Assurance Engagements ISAE 3000: “Assurance engagements other 
than audits or review of historical financial information". A limited assurance engagement in accordance with ISAE 
3000 involves assessing the suitability in the circumstances of management's use of the criteria as the basis for the

(2) 
 
 
 
 
preparation of the sustainability reporting, assessing the risks of material misstatement of the sustainability 
reporting whether due to fraud or error, responding to the assessed risks as necessary in the circumstances, and 
evaluating the overall presentation of the sustainability reporting. A limited assurance engagement is substantially 
less in scope than a reasonable assurance engagement in relation to both the risk assessment procedures, 
including an understanding of internal control, and the procedures performed in response to the assessed risks.  
 
The procedures we performed were based on our professional judgement and, among others, included an 
assessment of whether the criteria used are appropriate, as well as an assessment of the overall presentation of 
the sustainability reporting. Our procedures also included meetings with representatives from Santander Consumer 
Bank AS who are responsible for the material sustainability topics covered by the sustainability reporting; review of 
routines for reporting key performance indicators for sustainability; obtaining and reviewing relevant information that 
supports the preparation of key performance indicators for sustainability; and assessment of completeness and 
accuracy of the sustainability reporting.  
The procedures performed in a limited assurance engagement vary in nature and timing from, and are less in 
extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited 
assurance engagement is substantially lower than the assurance that would have been obtained had we performed 
a reasonable assurance engagement. Accordingly, we do not express a reasonable assurance opinion about 
whether the sustainability reporting has been prepared, in all material respects, in accordance with the criteria. 
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion.  
Conclusion 
Based on the procedures we have performed and the evidence we have obtained, nothing has come to our 
attention that causes us to believe that  
● 
Santander Consumer Bank AS’ GRI Index for 2022 is not, in all material respects, developed and 
presented in accordance with the requirements of the Standards published by The Global Reporting 
Initiative;  
● 
Santander Consumer bank AS’ key performance indicators are not, in all material aspects, developed, 
measured and reported in accordance with the definitions and explanations provided in relation to the key 
performance indicators. 
 
Oslo, 13 September 2023 
PricewaterhouseCoopers AS 
 
 
 
Erik Andersen 
State Authorized Public Accountant (Norway)

Signers:
Name
This document package contains:­­­
- Closing page (this page)
-  The original document(s)
 - The electronic signatures. These are not visible in the 
document, but are electronically integrated.
This file is sealed with a digital signature.
The seal is a guarantee for the authenticity 
of the document.
Method
Date
2023-09-13 11:51
BANKID
Andersen, Erik
Revisjonsberetning