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Santander V-POL

POLITICAL AUDIT UPDATED 2026-05-18
V-POL Score 0.80 /10 E Santander — BDS-1000 9
V-POL 0.80

Evidence-only forensic audit. Scoring happens downstream — see the main dossier for the composite assessment.

V-POL Audit: Banco Santander S.A.

Corporate Communications & Public Stance

Santander issued a public statement on March 7, 2022, titled “Santander responds to the war in Ukraine,” including direct condemnation of the Russian invasion, a €1 million donation to Red Cross and UNHCR, employee donation matching, fee relief for Ukrainian customers in Poland, and a clear policy statement on sanctions compliance 1. The bank announced specific financial actions including a €1 million initial donation, employee matching, fee removals on transfers to Ukraine, charge-free ATM access for Ukrainian customers in Poland, €250,000 from Santander Asset Management, and €250,000 from Fundación Banco Santander to small NGOs helping Ukrainian refugees 1.

No public statement, press release, or policy communication addressing the Gaza conflict was found in Santander’s press release archive for any period from October 2023 through June 2026 2. No entry related to Gaza, Israel, or the Middle East appears in Santander Bank US news releases for the same period 3. No Israel-specific lobbying disclosure was found in any Santander Holdings USA LDA filing for 2024 4.

Santander’s 2023 and 2024 Annual Reports make no mention of Gaza, the West Bank, Israeli settlement finance, or any policy related to the occupation, while referencing Ukraine extensively as a risk factor 5. Santander’s offering circulars (2025) describe its Middle East exposure as “very limited” and “not material” — a characterization that addresses direct market exposure but not indirect financing of arms companies supplying Israel 6.

Operations in Occupied or Contested Territories

Santander confirmed it does not operate a physical branch in Israel per Globes reporting from 2018 7. Santander InnoVentures invested $5M in MyCheck Ltd. (Series B, March 2015); MyCheck operated in UK, US, Israel, and Brazil as a restaurant-focused B2B mobile payments platform before being acquired by Visible Alpha in May 2019 89. No evidence of Santander branches, subsidiaries, or authorized partners in West Bank, East Jerusalem, Golan Heights, or settlement areas was identified 10.

Santander is not listed in the UN OHCHR database of business enterprises involved in settlement activity (2020, 2023, or September 2025 iterations, which list 158 companies) 1112. Santander appears in DBIO reports as a financier of settlement-linked companies, not as a directly listed entity 131415. BankTrack maintains an “Active” profile for Banco Santander in its Banks and Conflict Zones project tracking European bank financing of settlement activity 16.

The BDS movement’s official divestment shortlist includes “Banco Santander” alongside BBVA, Barclays, BNP Paribas, HSBC, and others 17. No public evidence was found of a specific BDS campaign targeting a Santander subsidiary, brand partnership, or operational unit distinct from the Group-level inclusion 17.

Internal Governance, Content & Retail Policies

No public evidence identified of HR enforcement actions, employee terminations, or controversies specifically related to pro-Palestinian speech or activity at any Santander entity 53.

No independent reports, academic studies, or regulatory inquiries regarding algorithmic moderation or content suppression related to the conflict were identified for Santander 5.

No public reports or regulatory actions regarding labeling, sourcing, or categorization of settlement-origin products were identified for Santander 5.

Brand Heritage & State Partnerships

No evidence was found of Santander utilizing military heritage, defense sector ties, or state-security origins in its commercial branding or public relations 53.

No evidence was found of Santander accepting state honors, hosting government officials in a non-commercial capacity, or sponsoring Israeli state-backed cultural or public relations campaigns such as “Brand Israel” 53.

Lobbying, Advocacy, Financing & Logistics

Political Lobbying:

Santander Holdings USA Q1 2024 LDA filing ($150,000 in lobbying expenditures) covers Basel III rulemaking, consumer banking, and international bank issues with no Israel-specific lobbying disclosed 4. The foreign entity interest declared is Banco Santander S.A. 4. No evidence of Santander lobbying the U.S. government on Middle East foreign policy, sanctions, boycott legislation, or human rights was found 4.

Financial Contributions:

Santander UK Foundation (Charity number 803655) shows total expenditure of £1,579,749 with no Israeli military-linked recipients such as FIDF, JNF/KKL, or IDF-linked charities identified in Charity Commission filings 18. No direct charitable donations from Santander Group entities to FIDF, JNF/KKL, or Israeli military-welfare bodies were confirmed 1819. Santander Group Annual Report 2024 states that Grupo Santander may only finance political parties on an exceptional and arm’s length basis and prohibits making monetary or in-kind donations and contributions to elections, with no Israel-specific political spending disclosed 5.

Crisis Asset Mobilization:

No evidence of Santander directing corporate resources, physical logistics, or infrastructure to assist state, military, or state-aligned NGO efforts during the Gaza conflict was identified 12.

Arms Financing:

Santander provided identified financing to arms companies manufacturing weapons used in Gaza including Boeing F-15 fighters ($1.218B), Leonardo F-35 fighters ($198M), Rheinmetall M109-52 self-propelled howitzers ($1.8M), General Dynamics 155mm artillery projectiles, Day & Zimmerman M830A1 tank ammunition, and Oshkosh military vehicles, with total identified arms-linked financing of approximately $2.442B 20. Santander’s own published defence sector policy explicitly prohibits financing related to nuclear, chemical, or biological weapons, anti-personnel mines, cluster munitions, and depleted uranium ammunition, but does not broadly exclude conventional weapons such as fighters, artillery, and armored vehicles 2122. Over 96% of transactions identified in Centre Delàs Report 71 (2025) occurred between 2022 and 2024, indicating acceleration of arms financing during the Gaza genocide period 21. Elbit Systems (Israel’s largest private arms manufacturer) was identified in Centre Delàs Report 71 through its joint venture with Spanish defence company Escribano Mechanical Engineering (EME), which received $29M in identified financing, though a specific direct Santander-to-Elbit financing transaction was not confirmed 21.

Corporate Structure & Primary Mission

Santander Group’s corporate charter and ownership structure show no explicit tie to advancing state geopolitical goals or infrastructure beyond standard commercial enterprise 5. No state-held golden shares or similar structural arrangements were identified in available filings 5.

Executive & Leadership Footprint

Personal Philanthropy & Financing:

No evidence was found of personal donations, family foundation grants, or fundraising by Santander founders, C-suite executives, or ≥10% shareholders directed toward regional advocacy groups, parastatal organizations, or military-welfare funds such as FIDF, JNF/KKL, or IDF funds 323.

Public Advocacy & Statements:

Ana Botín (Executive Chairman) holds board positions at The Coca-Cola Company, MIT CEO Advisory Board, and chairs Fundación CyD and Empieza por Educar, with no ties to Israeli advocacy organizations identified 3. Christiana Riley (CEO, Santander US) serves as Trustee at The Clearing House, Partnership for New York City, and American Friends of the Munich Security Conference, with no ties to Israeli advocacy organizations identified 3. Nadia Schadlow (International Advisory Board) is a former Deputy National Security Advisor for Strategy (Trump administration) and Senior Fellow at Hudson Institute, with no settlement or pro-Israel NGO affiliations identified beyond her government service 23. Mark Werner (Board Director, SHUSA) has a former J.P. Morgan background with advisory roles at Cerberus, with no Israeli advocacy affiliations identified 3.

Board Memberships & Affiliations:

The International Advisory Board includes George Kurtz (CEO, CrowdStrike), Sebastian Gunningham (former Amazon executive), and James Whitehurst (former IBM executive) — companies named in A/HRC/59/23 2324. No evidence confirms these individuals hold simultaneous roles at both Santander and these named companies, or that Santander’s own services flow to these entities 2324. No named board member or executive was found to hold simultaneous roles at companies named in A/HRC/59/23 including CrowdStrike, Amazon, or IBM 323.

End Notes

Footnotes

  1. https://www.santander.com/en/press-room/press-releases/2022/03/santander-responds-to-the-war-in-ukraine ↩ ↩2 ↩3

  2. https://www.santander.com/en/press-room/press-releases ↩ ↩2

  3. https://www.santanderus.com/leadership ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  4. https://lda.senate.gov/filings/public/filing/e7226366-ebe1-4f1e-bbec-60be4b23651a/print ↩ ↩2 ↩3 ↩4

  5. https://www.santander.com/en/shareholders-and-investors/financial-information/annual-reports ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  6. https://www.lexology.com/gdf/document/3100756637 ↩

  7. https://en.globes.co.il/en/article-santander-seeks-israeli-startup-investments-1001027601 ↩

  8. https://techcrunch.com/2015/03/29/santander-innoventures-leads-5m-round-in-israeli-mobile-payments-startup-mycheck ↩

  9. https://tracxn.com ↩

  10. https://www.fdic.gov/resolutions/santander-bank-2025-idi-resolution-plan-public-section.pdf ↩

  11. https://www.ohchr.org/en/business/bhr-database ↩

  12. https://en.wikipedia.org/wiki/List_of_companies_operating_in_West_Bank_settlements ↩

  13. https://dontbuyintooccupation.org/wp-content/uploads/2021/10/DBIO-report-DEF_aangepast.pdf ↩

  14. https://www.lo.no/globalassets/pr---dbio-2024-report-eng_.docx.pdf ↩

  15. https://dontbuyintooccupation.org/wp-content/uploads/2025/11/2025-DBIO-V-report-1.pdf ↩

  16. https://www.banktrack.org/news/new_report_exposes_billions_in_european_financial_support_to_companies_in_illegal_israeli_settlements ↩

  17. https://bdsmovement.net ↩ ↩2

  18. https://register-of-charities.charitycommission.gov.uk/charity-details/?regid=803655&subid=0 ↩ ↩2

  19. https://www.icjpalestine.com/2025/03/06/jnf-uk-subject-of-complaint-and-request-for-charity-commission-investigation ↩

  20. https://centredelas.org/wp-content/uploads/2024/11/informe_66_ES_CentreDelas_ArmedBankingGenocide_ENG_DEF.pdf ↩

  21. https://centredelas.org/wp-content/uploads/2025/04/informe71_ArmedBankingGlobalMilitarism_ENG_DEF.pdf ↩ ↩2 ↩3

  22. https://www.santander.com/content/dam/santander-com/undefined/PDFs/Santander-Defence-Sector-Policy.pdf ↩

  23. https://www.santander.com/en/about-us/our-people/international-advisory-board ↩ ↩2 ↩3 ↩4 ↩5

  24. https://www.un.org/unispal/document/a-hrc-59-23-from-economy-of-occupation-to-economy-of-genocide-report-special-rapporteur-francesca-albanese-palestine-2025/ ↩ ↩2