ING Groep NV

ING discloses a general process for ensuring its external public policy advocacy aligns with its climate commitments, stating that "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" and that "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." However, beyond noting that sustainability and climate topics are "a regular item on the Management Board Banking's agenda" and that an "ESG Sounding Board" guides ESG strategy development, the company does not identify a specific individual or formal body responsible for reviewing its lobbying alignment, nor does it disclose monitoring procedures for indirect engagement through industry associations. We found no evidence of a dedicated climate-focused lobbying audit or criteria for reassessing association memberships whose positions might conflict with ING's climate goals.