All of the activities under the Santander Group (that includes Santander Asset Management and therefore Santander Pensiones) are held liable under the Group´s Policy on Conflict of Interests. This policy covers:
General Responsibilities of Compliance Management
Disclosure of Conflict of Interests to Clients
Register of Conflict of Interests
This policy is available here:
In addition, Conflict of Interest is also included in Santander Group Code of Conduct which is public here:
Santander Asset Management, which include asset managed by Santander Pensiones, has its own conflict of interest policy and procedures in place to manage potential conflicts in a way that protects the interests of its clients. When potential conflicts are identified, SAM commits to manage them in a fair and effective manner to prevent these from harming the interests of our clients.
This policy is available here: https://www.santanderassetmanagement.es/wp-content/uploads/2018/05/Politica-Conflictos-de-Interes_SAM.pdf
Conflict of interest is a topic that has been also included in the engagement policy develop in 2019 and that will be publicly available in 2020.