ING

In terms of its approach towards impact management, ING identified and prioritised its impacts through a materiality assessment which includes topics important to external stakeholders. It links the remuneration of its executive team to sustainability performance criteria. The bank publicly commits to gender equality and women’s empowerment and discloses actions it takes to address any pay gaps, such as reviewing remuneration policies annually. ING has an environmental and social risk (ESR) policy framework where it describes its approach on sustainability themes and impact topics with clients. The bank discloses a list of trade associations of which it is a member including sustainability- and non-sustainability-related organisations as well as the positions it takes in its lobbying and political engagement activities on sustainability themes.

As a member of the Net-Zero Banking Alliance, ING has set a target of net-zero financed emissions by 2050. It discloses absolute financed emissions financed by its loan book and discloses the key sectors it has identified as priorities to engage with on climate change, specifically on the topic of alignment with the Paris Agreement. The bank discloses the aggregate amount and share of finance it devotes to climate solutions and defines them according to an internationally adopted framework. ING identified sectors and areas with the highest dependency and impact on nature and biodiversity and discloses nature- and biodiversity-related impacts as one of its engagement topics with clients.

ING has a publicly available policy statement committing it to respect human rights and the ILO core labour rights. It describes its process for assessing human rights risks, discloses what it considers to be its salient human rights issues and describes its global system to take action to prevent, mitigate or remediate them, including a description of how the system applies to its financing activities. Further, the bank discloses categories of stakeholders whose human rights have been or may be affected by its activities. ING discloses the proportion of its total direct operations workforce for each employee category by age group and gender and the proportion of its total direct operations workforce covered by collective bargaining agreements. It discloses a global tax strategy and income tax payments for all its tax jurisdictions.

In terms of its approach to senior leadership accountability, ING could assign responsibility for oversight of sustainability topics to the group’s supervisory board and clarify whether variable remuneration based on sustainability performance applies to its management teams. Further, the bank has an opportunity to reach at least 40% female representation in supervisory board and senior leadership positions. While ING discloses the total ratio of basic salary to men and women for its UK operations, it could to provide the same figures for its global operations, including a breakdown per employee category. The bank could further disclose clear frameworks with success criteria and escalation points in its environmental and social risk policy.

ING has an opportunity to set interim absolute emissions reduction targets at the group level, such as a 45% reduction in financed emissions by 2030. The bank discloses that it collectively engages with other banks on climate metrics but it could clarify how it collectively engages with its clients. ING could also require its clients to have a strategy aligned with the Paris Agreement. It could disclose time-bound targets explicitly for its climate solutions and report progress against them. No evidence was found regarding ING’s approach to fossil fuels that spans across the fossil fuel value chain and its financing activities, such as the amount or share of finance it directs towards fuels, or its stance on financing companies with new fossil fuel projects.

ING describes the process to identify its human rights risks and impacts through its lending activities but it could clarify if the process covers its investment banking and advisory activities. To provide transparency on financial inclusivity, ING has an opportunity to disclose the amount of finance directed towards, for example, women-owned businesses, small- and medium-sized enterprises (SMEs) or low-income developing countries.