ING Groep NV

Lobbying Governance

AI Extracted Evidence Snippet Source

ING wants to actively contribute its views in this dynamic landscape. We do this by monitoring new developments from the moment they take shape and, where appropriate, engage with the public sector as they develop new policies, regulation and approaches to supervision. [...] Concretely, we analyse changes to our regulatory and supervisory environment and assess its potential impact. We regularly engage on specific topics with policymakers – banking regulators, supervisors, public sector officials and politicians – as well as NGOs, industry- and consumer associations, think tanks, academics and other relevant stakeholders. When determining ING points of view on public policy, we weigh the interests of ING and all stakeholders involved. [...] ING is registered in the EU Transparency Register and adheres to the EU code of conduct for organisations engaged in EU policy-making and implementation. We adhere to nationally applicable advocacy transparency initiatives when it applies to us.

https://www.ing.com/About-us/Corporate-governance/Supervisory-Public-and-Regulatory-Affairs.htm

Response ING aims to play an important role in accelerating our clients' transition to net zero by 2050. To improve how we advise and finance clients in support of their transitions, we're increasingly incorporating sustainability- and climate- related considerations in our decision-making processes. For example, ING's Green-Light Committee (GLC), the body that validates the fit and alignment of potential transactions with the bank's strategy and priorities, now also reviews transaction proposals from a climate-alignment perspective. The GLC assesses information on the (prospective) client's current climate performance, their net-zero targets and transition plans, and these climate-related factors are considered alongside other due diligence and acceptance criteria such as the client's financial standing and our mandatory ESR screening. We are guided by our ESR policy framework, which we update regularly. We want the framework to reflect changing social norms and regulation relating to sustainability, and to challenge our own increasingly strong commitments on the topics of human rights and climate change. If clients in scope of our ESR framework don't meet those standards and aren't willing to change, we don't do the deal. As we assess potential clients and deals, our approach is to have a dialogue and support them in improving their environmental and social impact where possible. Our response to funding requests is often, "yes, but…", outlining improvements that the company will have to make first. We feel that this is how we can make the most positive impact. One example is with our client Wilmar, which is detailed|Links and references Climate Report 2023, pp. 24 – 28; p. 30; and p. 57 ff. (in relation to client/customers of each Terra sector), available at: https://www.ing.com/Media EditPage/2023-Climate- Report-1.htm ING.com > Sustainability > Sustainable business > Environmental and social risk (ESR) [...] Response Sustainability is an overarching priority of ING's overall 'Making the difference' strategy, and sustainability and climate-relate topics are therefore a regular item on the the Management Board Banking's (MBB) agenda. In addition, as we take steps to further integrate and embed climate action into the business, many of the other topics on the MBB's regular meeting agenda have a sustainability angle. This means that the MBB is discussing and taking decisions on sustainability- and climate- related topics on a frequent basis. The MBB also has a role in the global ambition-setting and oversight of our Terra climate- alignment approach. For all major ESG-related regulatory programmes and/or opportunities, dedicated Steering Committees have been set up with the aim of ensuring that relevant ESG-related regulations and programmes are monitored, assessed, and implemented. The ESG Sounding Board, comprised of around 15 senior leaders from across the organisation, helps guide the development and implementation of our strategy related to ESG topics, as well as monitoring and reporting on our progress. The financial health and inclusion target is monitored monthly. ING aims to align its remuneration policy with its risk profile and considers the broader interests of all stakeholders. To that end, targets in areas such as customer centricity, risk & regulations, sustainability and people are just as important as financial results. At least 50% of our Executive Board's variable remuneration targets are based on nonfinancial performance criteria, including ESG-related targets. See the 2023 Climate Report for more details on remuneration practices linked to sustainability targets.|Links and references Climate Report 2023, p. 15, available at: https://www.ing.com/Me diaEditPage/2023- Climate-Report-1.htm See also Our ESG governance approach, Annual Report 2023 Climate Report 2023, p. 17, available at: https://www.ing.com/Me diaEditPage/2023- Climate-Report-1.htm

https://www.ing.com/MediaEditPage/2023-UN-Principles-for-Responsible-Banking-assessment.htm

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]In developing ING Group's external advocacy, we seek to align our business and our strategy with the expectations of our stakeholders and society as a whole. Regular internal alignment with key internal stakeholders and senior management consultations ensures that our external engagement activities is consistent with our climate commitments and/or climate transition plan.

CDP Questionnaire Response 2023

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes

CDP Questionnaire Response 2023