"It is our role as a financial institution to support and promote economic, social and environmental
progress, leading to a better quality of life for people in society while generating adequate returns for
shareholders. We work on this every day together with our employees, customers and partners.
Together, we have the scale, ability and drive to make a difference.

ING became a signatory of the United Nations Global Compact in 2006, and I am pleased to reaffirm
ING Group’s support of the Global Compact's 10 principles governing the private sector's
responsibilities in the areas of Human Rights, Labour, Environment & Anti-Corruption.

There are many serious challenges that we as global citizens face. From the dangers of climate
change to equal opportunities and human rights. We understand the responsibility that the private
sector has to drive positive and sustainable change, and therefore remain fully committed to the
Global Compact.

Ralph Hamers
Chief Executive Officer ING Group"

Source: https://s3-us-west-2.amazonaws.com/ungc-production/attachments/cop_2017/381251/original/UN_Global_Compact_principles_2016_ING.pdf?1493978835

- The ING Values are based on the commitment to respect human rights and care for the environment, avoiding or managing impact. Human rights are an integral part of ING’s ESR Framework and apply to all economic sectors. In addition, within our sphere of influence and wherever permitted by law, we will support the aims of the UDHR, International Labour Organization (ILO) Core Conventions, the UN Global Compact, the Universal Declaration of Human Rights (UDHR), the Children’s Rights and Business Principles (CRBP) and the Corporate Responsibility to Respect Human Rights under the UN Guiding Principles on Business and Human Rights.

- In countries where local legislation goes further than the principles set out by the UDHR, ILO Core Conventions and/or UN Global Compact, ING will also apply that additional local legislation. In countries where local legislation prevents ING from upholding aspects of the UDHR, ILO Core Conventions, provisions of the UN Global Compact or ING’s own human resources policies, ING strives to act in the spirit and nature of these principles while respecting and adhering to applicable local legislation.

- The human rights and climate policies are the two overarching fundamental policies in ING’s ESR Framework. We recognise our responsibility to respect human rights in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs). We can contribute to the advancement of human rights through appropriate due diligence as well as client and stakeholder engagement locally and globally (ING Environmental and Social Risk Framework 2019, human rights section, page 23)

- At ING, we ask our suppliers to agree to comply with the UNGC principles that promote human rights, fair labour practices, environmental protection, and anti-corruption. Our goal is ultimately to advance our collective thinking—and actions—on issues including human rights. That’s why we partner and share knowledge on Human Rights. ING is member of the Thun Group of Banks, dedicated to investigating how the United Nations guidelines on business and human rights can be applied. The OECD Guidelines for Multinational Enterprises and the UN Guiding Principles for Business and Human Rights form the basis for what businesses should adhere to. We are also a signatory to the Dutch Banking Sector Agreement on Human Rights (DBA). ING has committed itself to promote the offering of sustainable products and services by enhancing the sustainability of its procurement practice and take into account, environmental and social aspect of the products and services procured; ING expects its suppliers to embrace, support and enact, within their sphere of influence, a set of core values in the area of human rights. Suppliers shall adhere to the United Nations Global Compact principles and therefore support and respect the protection of internationally proclaimed human rights and not to be complicit in human rights abuses.

- We also expect our clients to avoid causing or contributing to human rights abuses; to comply with the human rights laws of the countries they operate in and to seek to meet the standards as set out in the Universal Declaration of Human Rights, where local law does not meet these standards; to identify and manage human rights risks where they are active in countries or regions associated with these risks (like conflict zones); to be transparent about (potential) human rights impacts; to assess potential human rights risks in their supply chain and use their leverage to address the most severe human rights with their suppliers and customers (while acknowledging that managing supply chain human rights risks is complex, and the influence compared to clients’ own operations is lower); to engage with their stakeholders and, commensurate with the size and impacts of their operations, enable access to remedy where necessary (Our ING Environmental and Social Risk Framework gives insight into which human rights related topics can potentially be at risk in the sectors where ING’s clients are active and provides focus on common and sensitive issues, page 24)

-ING’s Statement on Human Rights provides a full overview of our means of embedding human rights in our business conduct. It outlines our responsibility to respect the internationally recognised human rights of our employees, suppliers, clients, business partners and other stakeholders. It refers to our underlying policies and expectations and provides guidance to our business. While our Statement on Human Rights provides the roadmap for our approach to human rights, our due diligence with respect thereto is also embedded in other policies and commitments.

- ING was an early adopter of the EP in 2003 and chair of the Steering Committee from 2012 – 2014, where we played a key role in finalising the committee’s second review update. We actively advocate for and enforce the EP, as we recognise their positive contribution to society. We are an active member of the EP Social working group, which discusses the social and human rights challenges when applying the EP for its more than 90 current financial institution members. ING is currently coordinating the EP4 review where human rights are a key part of the discussion.

- Moreover, all ING representatives must abide by these values and behaviours such as: The Orange Code, Human Rights statement for Employees, Diversity Manifesto, compliant Procedures and Whistleblower Policy.

References:
1. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/2019-Annual-Report-ING-Group-NV%20(2).pdf
2. https://www.ing.com/Sustainability/Sustainable-business/Human-Rights.htm
3. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/2019-Human-rights-report-ING-Groep-NV%20(1).pdf
4. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/Human-Rights-Report-2018.pdf
5. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/Human%20Rights%20and%20the%20workplace%20(1).pdf
6. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/IPSS.pdf
7. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/ING-Environmental-and-Social-Risk-Framework%20(1).pdf
8. https://www.ing.com/Sustainability/Our-own-operations/Diversity-inclusion.htm

- As a bank, we make a substantial contribution to human rights as financier, employer, taxpayer and driver of progress and prosperity. Our impact is on our workplace, supply chain, on how we do business and who we do business with.

- Regarding human rights governance of the ING bank, we established a Group-level Steering Committee (SteerCo) to oversee and take responsibility for the implementation of the Dutch Banking Sector Agreement on human rights (DBA). The Steerco includes: ING’s CFO and Management Board Banking member; the head of Regulatory and International Affairs; the global head of Sustainability; the global head of Corporate Communications; the Wholesale Banking chief risk officer; the Wholesale Banking chief operations officer; and the Wholesale Banking head of Sectors. The SteerCo meets every quarter to monitor the progress of our DBA commitments. In addition to the creation of the SteerCo, we established a multi-disciplinary working group comprising management and staff from various departments.
Our multi-disciplinary working group works to deliver a revised Whistleblower policy and complaint mechanism; set up a programme for proactive engagement on (salient) human rights risks with selected corporate clients; and share lessons from human rights client assessments. ING’s Whistleblower policy encourages and protects employees who speak up when they encounter behaviour in the workplace that is unethical, illegal or goes against the values of our Orange Code. Employees can use ING’s whistleblower channels to raise their concerns (also anonymously) and without fear of reprisal. It alerts management to allegations of crimes or other suspected misconduct and helps ensure appropriate and adequate action is taken to address the situation.

- Additionally to the Whistelblower Policy, reporting any misconduct or behaviour which is suspected to be criminal or unethical is possible for customers, shareholders, suppliers and other stakeholders who can report their suspicions. Any stakeholder can now report “suspected or actual criminal conduct, unethical conduct or other misconduct, including a human rights violation, by or within ING via the chief compliance officer”.

- ING’s management of our staff is based on our Group-wide policies but also reflects local conditions and norms. To understand the differences in policies that inform our risks we sent a questionnaire to Human Resource directors in a selection of countries where ING has either significant operations, a sizeable workforce, or where the operational context for ING is known to be challenging from a human rights perspective. Moreover, all ING employees are required to complete Orange Code training. This includes e-learning and discussing hypothetical work-related ethical scenarios with their respective managers.

- We have also supported training for 430 women entrepreneurs and financial education for 25,000 women in India. Our biennial research report ‘A Billion to Gain’, produced together with universities and knowledge centres such as Netherlands Platform for Inclusive Finance, has yielded valuable end-user insights and in-depth knowledge of impact finance over a number of years. Since 2006, we have issued seven reports and organised five international conferences. Together with ING Turkey, ING Impact Finance has drawn up a plan to help existing entrepreneurs offer employment for refugees in Turkey and support them in setting up their own businesses. This project contributes to the social resilience pillar of ING's sustainability direction and is in line with EU and Dutch government policy by developing local facilities in the region.

- In the field of children’s rights, ING and UNICEF have a long history of working together to empower the next generation. There are 1.2 billion adolescents (aged 10–19) worldwide, nearly 60 percent of whom live in developing countries. With the Power for Youth partnership, ING and UNICEF aim to give adolescents the 21st century skills they need to improve their futures and the future of those around them. ING was also the only bank involved in the consultation process and hosted the launch of the Children’s Rights and Business Principles in the Netherlands.

- We believe that stakeholder engagement is a crucial part of human rights due diligence. Banks should engage with potentially affected individuals and groups in order to truly understand their interests and concerns. In May 2018, we discussed our salient human rights issues and underlying approaches with external stakeholders. We invited representatives from NGOs, trade unions and the Dutch government to check our conclusions and any possible missed considerations. Our process for prioritising salient human rights risks was complex, and generated significant internal debate about what is considered most salient.

References:
1. https://www.ing.com/Sustainability/Our-Stance/Human-rights.htm
2. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/Human-Rights-Report-2018.pdf
3. https://www.ing.com/About-us/Compliance/Whistleblower-Policy.htm
4. https://www.ing.com/About-us/Compliance/Complaints.htm

- In November 2019, BankTrack Human Rights Benchmark 2019 published its Human Rights Benchmark 2019, the third edition of the benchmark. It evaluates 50 of the largest private sector commercial banks globally against a set of 14 criteria based on the UN Guiding Principles on Business and Human Rights (UNGP). ING’s final score is 7 out of 14, up 1.5 points from the previous benchmark, putting the bank in the ''Front runners'' group of banks. ING’s progress reflects our implementation of the UNGP, which we began in 2018, and our follow-up on salient human rights risks in 2019. ING’s Human Rights Update, published in November 2019, gives an update on the steps we’ve taken to improve human rights.

- In 2018, our human right journey mapped human rights risks in the gold, palm oil and cocoa, focused on value chains, working to expand engagement efforts with corporate lending clients on human rights, updating ING’s group-wide complaints mechanism making clear reference to human rights and underlining its availability to all stakeholders, announced that ING will withdraw from the tobacco industry by 2023, adopted non-financial risk assessments on potential human rights impacts, signed the UN Global Compact Women Empowerment Principles, supported the UN standards for tackling LGBT+ discrimination in the workplace, published a first human rights report in line with the UNGP Reporting Framework, working towards an updated ESR Framework, including an expanded overarching human rights policy. Since the last reporting period, in 2019 we began to follow up on the recommendations from DBA working groups and publications, such as exploring ways to increase leverage, we published an update of our ESR Framework with an enhanced stand-alone Human rights policy that includes potential human rights risks indicators per sector. The updated policy encourages clients to identify, manage and disclose human rights issues in their supply chains. Other changes include enhanced policies on topics relating to human rights (such as tobacco). Moreover, at the request of the UN Human Rights Office of the High Commissioner, we hosted a meeting with the Dutch private industry and the UN High Commissioner for Human Rights, Ms Michelle Bachelet, during her first official visit to the Netherlands. We have also became a founding signatory to the UNEP FI Principles for Responsible Banking and we completed the exercise phase for proactive human rights engagement.

- Regarding the aspect of human rights violation, every ESR Transaction Assessment happens when ING engages in a lending activity with a Wholesale Banking client. A transaction assessment is performed to understand the environmental and social risks associated with the transaction. The ESR transaction assessments includes, inter alia, alleged human rights violations. Moreover, the Group published a discussion paper in January 2017 on banks’ due diligence in terms of potential human rights violations. This builds on the first discussion paper and Group statement published in 2013 on the implications of the UN Guiding Principles for banks in retail and private banking, corporate and investment banking, and asset management. The Group has had various discussions with stakeholders, such as NGOs and former UN Special Representative for Business and Human Rights John Ruggie, about the January 2017 paper and after thorough consideration published a revised discussion paper in December 2017. The Group continues discussions on how to embed human rights due diligence effectively in the financial sector.
Evaluating human rights risks related to our business engagements is not a static process and requires regular monitoring, as client’s operations or community sentiments evolve. For example, through various platforms, we have a better understanding of how society’s expectations have moved on when it comes to the human rights responsibilities of corporates and financial institutions. As a result, we have updated our due-diligence questionnaires for corporate clients. Our environmental and social risk evaluation includes a clearer emphasis on human rights, explicitly taking account of whether a company has a human rights policy and if it is associated with (severe and systemic) human rights and other social risks.

- In May 2017 we conducted a thorough review of our Wholesale Banking lending portfolio for potential human rights risks. We focused on three business segments through which ING serves corporate clients. These were selected because they are engaged in industry lending, are material to our loan book and, in our view, hold the biggest potential concentration of human rights risks. We then worked with a specialist consultant in human rights, who advised us on which sectors in our portfolio qualify as low, medium or high risk from a human rights viewpoint. ING can encourage improvement by working with clients over time to strengthen their capacity and commitment to managing human rights risks. If the client fails to deliver on the remedial measures within a mutually agreed time-frame, we may need to review the situation.

- As part of the salience analysis, we further reviewed past transactions and clients to see where the greatest risks had emerged in practice. We found risks were higher in: large energy, infrastructure and extractive projects; countries with weak governance; and certain manufacturing and commodity supply chains. In implementing our approach, we recognise that poverty is the root cause for child labour in many emerging economies and is directly linked to the need for children to provide supplemental income for their families. Our challenges also arise in contexts where host country legislation allows for a lower minimum age compared to the ILO norm. We review such instances together with our clients on a case-by-case basis. If our due diligence uncovers incidents of child labour, we investigate these instances and engage the implicated clients.

- Example of ING standard in a specific sector of Palm oil.
Palm oil is the most widely used vegetable oil globally and the industry has grown at a rapid pace due to increasing global demand. The industry has been subject to continuous issues relating to deforestation, illegal logging, human rights (including forced resettlement of communities/indigenous people and labour issues) and pollution (particularly related to haze hazards as a consequence of illegal burning practices).
Therefore, ING has no intention to expand its palm oil client base. For existing clients, ING performs strict assessment criteria that are closely monitored. The closer a client is to the source the more stringent our assessment becomes. Therefore, we make a distinction between production companies and traders in the standards we expect of our existing clients: (....) Have policies in place that prevent child/forced and bonded labour.

- In our DBA Value Chain working groups we have also identified that the abusive use of migrant labour is prominent in agriculture, including in palm oil and cocoa plantations, though by no means restricted to this sector. Issues related to migrant workers can include confiscation of identity documents, compulsory overtime and/or deliberate non-payment of wages, and recruitment agents charging workers excessive recruitment fees, often driving them into high levels of debt. This value chain work will help us to refine approach to supporting elimination of forced labour in the value chains of our clients.

References:
1. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/Human-Rights-Report-2018.pdf
2. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/2019-Human-rights-report-ING-Groep-NV%20(1).pdf
3. file://ad.ing.net/wps/NL/P/UD/200022/JX90PG/Home/Downloads/ING-Environmental-and-Social-Risk-Framework%20(15).pdf

- ING has committed itself to promote the offering of sustainable products and services by enhancing the sustainability of its procurement practice and take into account, environmental and social aspect of the products and services procured; ING expects its suppliers to embrace, support and enact, within their sphere of influence, a set of core values in the area of labour standards. Supplier shall adhere to the United Nations Global Compact principles and therefore: Uphold the freedom of association and the effective recognition of the right to collective bargaining; Eliminate of all forms of forced and compulsory labour; Effectively abolish child labour and eliminate discrimination in respect of employment and occupation.

- ING supports eliminating all forms of human trafficking, slavery, forced and child labour that go under the general term of “Modern Slavery”. We ensure compliance within our own organisation and support elimination within those we do business with. With over 52,000 employees, we aim to be a responsible employer that provides staff with good working conditions and opportunities for growth.

- In general, ING encourages its clients to disclose their sourcing practices (origin of the products or services, i.e. country and facilities) and to demonstrate commitment to taking account of human rights (especially labour and health and safety standards) and environmental matters in their supply chain policy. ING spends significant amounts per year on procuring goods and services from external suppliers. We have a wide range of suppliers, as a financial institution, our suppliers are mainly service suppliers ranging from IT, retail services, and logistics to catering and cleaning, as well as a very wide variety of services in between. Involving suppliers that see sustainability the way we do – including zero tolerance towards Modern Slavery – helps to make a difference. They must have solid governance in place and show they can act responsibly. In 2012 we implemented ING’s Procurement Sustainability Standards (IPSS), based on the UN Global Compact Principles. The standards are global and outline how we expect our suppliers to treat sustainability and conduct business in a principled and responsible manner. We require suppliers to ensure that all subcontractors and parties within their supply chain will also be compliant with the IPSS or equivalent.

- Human rights are universal. This means that every person around the world deserves to be treated with dignity and have their interests considered equally. We involve employees when dealing with complex human resources policy issues, ensuring their point of view is taken into account. This also enhances communication between management and staff and supports a culture of shared responsibility. The way employees are consulted depends on local legislation and culture. This Human Rights Statement for employees has existed since 2006, expressing our commitment to support international labour rights standards. We uphold the freedom of association for all our employees and recognise the right to collective bargaining.
ING follows various standards for human rights when it comes to our workforce. The most widely accepted statement on human rights is the United Nations’ Universal
Declaration of Human Rights (UDHR), adopted in 1948 by the General Assembly of the United Nations. It describes civil, political, economic, social and cultural rights.

- ING adheres to local labour laws and regulations. Within our sphere of influence and wherever permitted by law, we will also support the UDHR, the International Labour Organisation (ILO) Core Conventions, and the UN Global Compact.
UN Global Compact, Principle IV: ING upholds the elimination of all forms of forced labour and compulsory labour
UN Global Compact, Principle V: ING upholds the effective abolition of child labour.
ILO Core Conventions 138 and 182: ING doesn’t use child labour in any of its global operations.In the absence of any national or local law, ‘child’ means a person less than 16 years old. If local minimum-age law is set below 16 years but is in accordance with ILO Convention 138, that lower age will apply. ING doesn’t tolerate any form of exploitative child labour, as defined in the ILO Convention 182, Article 3 (Worst Forms of Child Labour)

- As part of our commitment to a diverse and inclusive organisation, ING is a signatory to the United Nations’ Global Compact Women Empowerment Principles and we support the UN Standards for Combatting LGBTI Discrimination in the Workplace.

- ING commits to the signing of the Modern Slavery Act UK, since 2017, which we update each year as of then. (reference #7)

References:
1. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/IPSS.pdf
2. https://www.ing.com/Sustainability/Sustainable-business/Human-Rights.htm
3. file://ad.ing.net/wps/NL/P/UD/200022/JX90PG/Desktop/UNI/Ip-8/Human%20Rights%20and%20the%20workplace.pdf
4. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/ING-Environmental-and-Social-Risk-Framework%20(1).pdf
5. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/INGs%20approach%20to%20the%20Modern%20Slavery%20Act%20(1).pdf
6. https://www.ing.com/Sustainability/Our-Stance/Human-rights.htm
7. https://www.ing.com/web/file?uuid=a203afe5-5957-4d65-92f3-0022d74304a6&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=46751

- We aim to respect human rights and we expect our clients to do the same, as demonstrated through proper management of, inter alia, labour rights in their own operations (including strict avoidance of any forced labour practice and child labour16), the security and livelihood of local communities and supply chain impacts through supplier screening. ING will not directly engage in business activities that are known to have elements of human rights abuses and/or where such violations exist. Where such violations are observed with existing clients, ING will negotiate for remedial action and steps to seek to prevent new violations in the future.

- ING rejects all forms of human trafficking, slavery, forced and child labour that go under the general term of ‘Modern Slavery’. Our aim is to work to compliance within our own organisation and the client operations we finance, as well as to support its elimination within the value chains of those with whom we do business. In applying the Equator Principles for project financing we pay particular attention to the rights of migrant workers from the moment of recruitment, during overseas employment and through to further employment or safe return to their home countries. In this respect, our focus on the recruitment process includes preventing fees being paid in excess of legally permitted amounts, ensuring that any contract terms are clear and legal, that wages or benefits are not falsely promised, and that repatriation terms are clear and migrants are free to return home with passports not withheld. The types of situation that we look out for that may indicate existence of forced labour include:
Workers being charged fees, directly, by recruitment agencies or by the employer, including for travel or accommodation. Workers deprived of their passports, visas and other identification documents. Workers not feeling free to terminate employment as a result of fees owed to the employer or an agent. Workers not being entitled to leave the workplace or accommodation whenever they wish, subject to reasonable security measures applicable in remote or dangerous sites. Delays in wage payments where the promise of paying wages in arrears is used to coerce workers to stay in a job or to create a dependency. Excessive wage advances or loans provided to workers where such payments exceed 10 percent of the worker’s wages and the loan terms exceed six months.
Forced overtime if beyond the number of overtime hours allowed by national law or collective agreement, including threats to fire the worker or never offer the worker overtime again.

- We seek to judge employees on their merit and skills and without discrimination according to race, age, sex, religion, ability or belief. We believe that by respecting human rights and increasing our efforts in diversity, we are strengthening our workforce and our business.We seek to judge employees on their merit and skills and without discrimination according to race, age, sex, religion, ability or belief. We believe that by respecting human rights and increasing our efforts in diversity, we are strengthening our workforce and our business. As part of our commitment to a diverse and inclusive organisation, ING is a signatory to the United Nations’ Global Compact Women Empowerment Principles and we support the UN Standards for Combatting LGBTI Discrimination in the Workplace. These standards guide our approach and are a source of learning for our own practices to combat discrimination and promote diversity and inclusion.

References:
1. file://ad.ing.net/wps/NL/P/UD/200022/JX90PG/Home/Downloads/ING-Environmental-and-Social-Risk-Framework%20(15).pdf
2. file://ad.ing.net/wps/NL/P/UD/200022/JX90PG/Home/Downloads/Human-Rights-Report-2018.pdf
3. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/2019-Annual-Report-ING-Group-NV%20(2).pdf

- Externally, ING is recognised worldwide as a top employer, also among IT professionals. Our achievements in 2019 include: Certified by the Top Employers Insitute in Belgium, France, Italy, Luxembourg and Poland; Recognised by ‘Great Place to Work’ in Germany, Austria and Turkey; Ranked by IT professionals as one of the top three favourite IT employers in the 2019 Dutch IT Labour Market Monitor; Named by recruitment platform Intermediar as the top financial employer (and number three across all industries) among highly educated professionals. Recognising our efforts and commitment to gender equality, Bloomberg also included ING in its 2019 Gender-Equality Index (GEI).

-ING was a finalist for a Workplace Pride Gala Award for best media representation. We are a founding partner of the International Platform for Lesbian, Gay, Bisexual And Transgender (LGBT) Inclusion at work. Its activities include the International Workplace Pride Global Benchmark, which scores companies in seven areas and identifies best practices. In 2019, ING significantly improved its score in the benchmark, placing us in the top tier and earning us recognition as Workplace Pride Ambassador.

- We continued our engagement in Dutch multi-stakeholder platforms to implement the Dutch Banking Sector Agreement on International Responsible Business Conduct Regarding Human Rights. In 2018, we published our first human rights report in which we disclosed our saliency process and the human rights salient to ING – child labour, forced labour and land-related community issues. In 2019, we published an update focused on our role as a corporate lender and the outcome of an exercise where we proactively engaged with 29 clients in human rights.

- Total workforce gender breakdown in 2019 was 48.3% women and 51.6% men. in 2019, women in leadership positions remained stable at 37 percent of managers (38 percent in 2018) and 29 percent of managers of managers (30 percent in 2018). Looking at succession, 41 percent of the high-potential graduates that joined the 2019 International Talent Programme are female. For the Supervisory Board and Management Board there is a 30 percent gender target set by the Dutch government. The Supervisory Board met this in 2019. Three of its nine members (33 percent) are now female: Mariana Gheorghe, Margarete Haase and Herna verhagen, the latter appointed on 23 April 2019, with her membership becoming effective per 1 October 2019. The Supervisory Board strives to have a diverse composition with regards to gender, ethnicity, nationality and generation. However, the Management Board is not there yet. Nevertheless, in 2019, we announced the appointment of Pinar Abay to the Management Board with effect from 1 January 2020. This will take the number of women on the Management Board to two of its seven members.

References:
1. file://ad.ing.net/wps/NL/P/UD/200022/JX90PG/Home/Downloads/ING-Environmental-and-Social-Risk-Framework%20(15).pdf
2. file://ad.ing.net/wps/NL/P/UD/200022/JX90PG/Home/Downloads/Human-Rights-Report-2018.pdf
3. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/2019-Annual-Report-ING-Group-NV%20(2).pdf

- Our approach to sustainability is in the areas of climate action and financial health. So we focus on the SDGs for promoting climate action (goal 13), sustainable consumption and production (goal 12) , and sustainable and inclusive economic growth (goal 8). In doing so, we work with other financial institutions, multinational enterprises and industry organisations to advance our understanding of the SDGs and capture impact opportunities.

- ING has been climate neutral since 2007 and we have ambitious goals to reduce our CO2e emissions by 50% by 2020 (base year 2014), to reduce global residual waste by 20% by 2020 (base year 2014), to reduce our water footprint by 20% by 2020 (base year 2014), to remain carbon neutral by offsetting remaining carbon emissions, to procure 100% renewable electricity for all ING buildings by 2020, to preferably procure green energy from local renewable projects: electricity supplied by energy sources that are naturally and continually replenished, such as wind, solar power, geothermal and hydropower, to maintain a standard for transparency about our progress by reporting to CDP and disclosing material environmental performance indicators in our annual report. We also aim to double our funding by 2022 to organisations that help combat climate change and positively impact society and the environment. By the end of 2025, we’ll no longer finance clients in the utilities sector that are over 5% reliant on coal fired power in their energy mix. We will however continue to finance non-coal energy projects for these clients in support of their energy transition.

- We aim to reduce, reuse and recycle plastic packaging within our own operations as well as to support our clients in the packaging and recycling parts of the plastics value chain. We have a cross-business working group to address these areas in an integrated way. We aim to improve our own operations, creating awareness among employees and working with suppliers to meet new policies. ING offices in Spain, the Netherlands, Poland, Belgium and Luxembourg have already taken steps to phase out single-use plastics. We will expand this to other local headquarters in the Netherlands in 2020. We will also replace plastic bottles at our branches in the Netherlands with a more sustainable version, at the latest in 2020.

- At ING we believe that managing our environmental impact is key to achieving our goal of being truly sustainable. That’s why we monitor and manage the impact of our operations though our Environmental Programme. With the help of the Environmental Programme, ING has decreased our total carbon footprint by 57% as of year-end 2019 compared to 2014, achieving our 2020 target a year early. This is thanks to reducing business travel, an increase of renewable electricity consumption and a decrease in total energy consumption. Since 2014 we reduced our overall energy consumption by 29%.

- We apply strict social, ethical and environmental criteria in our financing and investment policies and practices: Every client and transaction is assessed, monitored and evaluated against the requirements of our Environmental and Social Risk (ESR) framework to ensure compliance and limit negative impact on the environment and communities. This way, climate and environmental impact are taken into account every time we make financing or investment decisions. We also say ‘no’ to certain companies and sectors. We have a loan book of about €600 billion across many sectors, which we have begun steering towards meeting the Paris Agreement’s two-degree goal. We call our strategy to get there the Terra approach.

- Moreover, the ESR screening process applies to any in-scope customer and further depends on the product and service to be provided. The ING Environmental and Social Risk Framework provides a visualized version of this process in detailed on the page 7.

References:
1. https://www.ing.com/sustainability/sustainability-direction/climate-action.htm
2. https://www.ingwb.com/insights/articles/sustainability-rating-is-good-for-your-business
3. https://www.ing.com/sustainability/our-own-operations/environmental-performance.htm
4. https://www.ing.com/Newsroom/News/ING-further-sharpens-coal-policy-to-support-transition-to-low-carbon-economy.htm
5. https://www.ing.com/Sustainability/Sustainable-business/Terra-approach.htm
6. https://www.ing.com/Sustainability/Our-own-operations/Environmental-performance.htm
7. https://www.ing.com/sustainability/the-world-around-us-1/sustainable-development-goals.htm
8. https://www.ing.com/Sustainability/Our-Stance/Plastic.htm
9. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/ING-Environmental-and-Social-Risk-Framework%20(1).pdf

- We’ve financed billions of euros in energy projects, from wind farms, solar energy, and geothermal power production; to energy efficiency in buildings and production lines; to electric vehicles and bio-based plastics; to (waste) water treatment and supply and circular economy solutions. We do this through green loans, green bonds, and other innovative products and financing constructions. One such innovation is our sustainability improvement loan, which offers corporate clients a lower interest rate for improved sustainability performance. Companies cannot just announce that they are sustainable. Stakeholders need to have confidence that this is the case, while companies trying to improve their sustainability performance need to have some way to measure their progress. This is where ESG ratings come in.

- Moreover, ING is committed to 100% renewable energy powered buildings via the RE100 initiative. This initiative pushes us to reduce our direct environmental impact by providing clean energy for our operations, buildings and IT systems. A good example of the integration of the programme’s sustainable strategy within ING is our new corporate office ‘Cedar’ opened in Amsterdam in January 2020. Cedar’s design has been awarded the highest sustainability rating by BREEAM-NL. It was partially built with the concrete from the previous building on the same location. Around 3,000 square meters of solar panels provide energy for the building, while triple glazing and insulated window frames help to save energy. Various sustainable measures save up to 12 million litres of water per year and single-use plastic is banished from the restaurants and coffee bars.

- ING has also endorsed the New Plastics Economy (NPEC) Global Commitment vision by the Ellen MacArthur Foundation. This is a joint effort by the industry and governments to tackle plastic waste and pollution and increase the recycled content of plastic packaging from 2% now to an average of 25% by 2025. We’ve had a segregated stream for plastics in our headquarters’ waste management for years and in our new global headquarters, the catering and drinks suppliers won’t use single-use plastic disposables and condiments.

- To understand and reduce our energy use, we carry out regular monitoring, reporting and reduction strategies across our global operations. Our strategies range from more efficient use of building space, to increasing the energy efficiency of our buildings and data centres, to increasing our use of renewable energy. In order to reduce travel, we are focusing on increased use of technology for seamless digital collaboration such as video conferencing. Where travel cannot be avoided, we discourage the use of air travel where possible and promote the use of public transport and electric vehicles. Although as a financial institution our water footprint is comparatively small compared to other industries, we have still launched an extensive monitoring and water-reduction strategy to minimise our impact. We make use of water-efficient infrastructure such as rainwater collection for sanitation, aerators for faucets and updated appliances for optimal efficiency. Paper use and waste are also two focus areas due to our concern for the conservation of natural resources. This is why we aim to reduce our use of paper through greater utilisation of digital media and more efficient printing. We are also increasing our use of eco-labelled and environmentally friendly paper and recycle disposed paper worldwide. For general waste we have focused our efforts on increasing our recycling rate, management of e-waste and overall reduction of residual waste.

- With a considerable global procured spend and an extensive network of suppliers worldwide, we have a real opportunity to drive our sustainability agenda through our supply chain. By encouraging suppliers to share our standards and work towards continual improvement, we believe we can make a demonstrable impact while mitigating risks. At ING, our procurement policies and procedures require us to take into account the social and environmental aspects of the products we procure as well as the attitude of the supplier towards sustainability. We have implemented, globally, a supplier qualification (Know Your Supplier, or KYS) process and sustainability is an explicit part of that process, helping us to determine the levels of social, environmental and financial risks associated with a supplier, specifically related to human rights, including forced and child labour, fair labour standards, environmental protection, and anti-corruption. Once suppliers pass the KYS process, they are qualified to become ING suppliers and the ING Procurement Sustainability Standards (IPSS) apply. Every supplier shall adhere to the United Nations Global Compact principles and therefore: Support a precautionary approach to environmental challenges and work to limit its environmental impact and undertake initiatives to promote greater environmental sustainability and encourage the development and diffusion of environmentally friendly technologies.

- The Environmental Programme is headed by our Environmental Programme Steering Committee, which is chaired by the global head of Tech Infrastructure. ING’s chief operations officer (COO) is the MBB sponsor of the programme. The Steering Committee ensures that the Environmental Programme strategy is integrated into daily business activities and has an impact across the global ING network. The ESR Team must verify compliance with the applicable policy to the satisfaction of Approval Authorities. Moreover, the ESR policy framework is reviewed regularly to ensure we adequately identify and manage not only existing but also new environmental and social risks. We conducted a full review of the ESR policy framework in 2018. This was done with the active participation of internal stakeholders and guidance from external stakeholders such as clients, peers and NGOs. Changes to the updated ESR policy framework (valid as of 1 July 2019) include standalone human rights and climate change policies. The updates reflect external developments, societal expectations and our ambitions for these topics and sustainability in general. The Global Sustainability department advises ING management on the bank’s sustainability strategy. As such, they analyse sustainability trends in relation to ING’s business conduct. The Global Credit & Trading Risk Policy Committee (GCTP) has the exclusive mandate to decide on any: Change to the ESR Framework, including the ESR list of restricted activities and the ESR list of fully restricted companies; FO request for an exemption to the ESR Framework supported by an ESR Team Advice. Such requests will only be considered on a very exceptional basis.

- We actively manage potential climate and human rights risks through our framework and regularly engage with stakeholders to inspire clients, peers and others to do the same. In May 2019, we hosted a meeting with the UN High Commissioner for Human Rights and the Dutch private sector to discuss the role and leverage of the private sector in this important area. The new framework also affects companies with both controversial and non-controversial activities. We’ve lowered the limit that we generally use to determine whether to exclude existing clients to 30% (from 50%), meaning we now exclude them if over 30% of their revenue comes from controversial activities. For new clients this threshold is generally even lower.

References:
1. https://www.ingwb.com/insights/articles/sustainability-rating-is-good-for-your-business
2. https://www.ing.com/sustainability/our-own-operations/environmental-performance.htm
3. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/IPSS.pdf
4. https://www.ing.com/Sustainability/Our-Stance/Plastic.htm
5. https://www.ing.com/Sustainability/Sustainable-business/Environmental-and-social-risk-policies.htm
6. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/ING-Environmental-and-Social-Risk-Framework.pdf
7. https://www.ingwb.com/media/268991/ing-environmental-and-social-risk-framework-09-16.pdf

- Our policies and actions are assessed by independent research and ratings providers, which give updates on them annually. ING remains ranked second in our market-cap group by Sustainalytics as of February 2020. ING retains ‘A’ rating in MSCI ESG, an investment research firm that provides indices, portfolio risk and performance analytics to institutional investors. The rating was confirmed in December 2019, remaining unchanged from the preceding three years. ING again named to CDP Climate A-list in January 2020. This year, ING maintains its A-list status in CDP’s annual list of the world's businesses leading on environmental performance. This shows ING’s continuous commitment on climate action leadership, being recognised by CDP as an A-list company for the fifth year in a row. The score reflects much more than our own operational environmental performance. It reflects our commitment and progress made on many other indicators: governance; risk management; opportunity management, including (financial) products and services; and result climate change strategy, including our metrics and targets. ING’s shares are also included in the sustainability indices of Euronext, STOXX, FTSE Russell and Morningstar.

- We have a loan book of about €600 billion across many sectors, which we have begun steering towards meeting the Paris Agreement’s two-degree goal. We call our strategy to get there the Terra Approach. We are proud of the progress we’ve made so far, which is the result of leadership that casts a global vision colleagues can get behind. Some specific progress includes that: ING commits to close to zero coal-fired power generation and thermal coal mining by 2025, ING aims for a net energy positive mortgage portfolio by 2050, ING has the ambition to align its Dutch commercial real estate portfolio with the below two-degree goal by 2040 – 10 years ahead of target date, ING has joined the Poseidon Principles, committing to support the shipping industry’s ambition to reduce CO2 emissions by 50% in 2050, ING has the ambition to increase our aviation portfolio to 50% ‘outperforming aircraft’ by 2023 (compared to 33% in 2018), 4. ING aims for the automotive sector portfolio to outperform the market (in terms of carbon intensity) in the short term. We currently provide results and targets for five of the nine sectors. This is a pioneering approach to climate transparency that we hope will inspire our peers. But we’re clearly not finished yet. We have four more sectors to go to cover all key sectors in scope of our Terra approach. We are working hard with our partner, 2˚ Investing Initiative (2˚ii), and peer banks in the pilot to finalise the methodologies for these sectors. We aim to have a quantitative update on these sectors for our next disclosure wave in 2020.

- ING discloses several stakeholder engagement cases in the ING Annual Report 2019, from page 442 onwards.

References:
1. https://www.ing.com/newsroom/news/ing-continues-to-be-climate-action-leader-says-cdp.htm
2. https://www.ing.com/Sustainability/The-world-around-us-1/Ratings.htm
4. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/2019-ING-Terra-progress-report.pdf

- ING Procurement Sustainability
Standards ING spends billions of euros per year procuring external goods and services. We can make a difference by making sure that money goes to suppliers that value sustainability as we do—protect human rights, prohibit the use forced or harmful child labour, and prohibit discrimination, bribery and corruption. We expect our suppliers have solid governance in place and show they can act responsibly. For this reason, sustainability aspects are integrated into ING’s supplier qualification process “Know Your Supplier” (KYS). The ING Procurement Sustainability Standards are based on the ten UN Global Compact principles. They are a global outline of how we expect our suppliers to embrace sustainability.

- Zero Tolerance Bribery Statement
Zero tolerance approach to bribery and corruption. We expect all ING employees at every level of the organisation to always do business in accordance with the values and behaviours of our Orange Code. We have a zero tolerance approach when it comes to bribery and corruption. We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose. Nor do we, or will we, accept bribes or improper inducements or anything that could be perceived as such. We expect the same from our customers, business partners and third parties we retain or that perform services or deliver business on our behalf. Bribery and corruption is not accepted in any form.

- The principles of ING’s Anti-Bribery and Corruption Policy state:
All forms of bribery and corruption, including facilitation payments, are strictly prohibited.
Gifts or entertainment must always be proportionate and reasonable; must have a legitimate purpose; and must not create a conflict of interest or the perception thereof. Employees and third parties may not make gifts or donations to political parties nor offer gifts or entertainment to candidates for political positions on ING’s behalf. Paid and unpaid internships and secondments should be based on merit. Questionable behaviour should be challenged and (suspected) improper payments or activities should be reported to management or via the whistleblower channels.

References:
1. file://ad.ing.net/wps/NL/P/UD/200022/JX90PG/Home/Downloads/Human-Rights-Report-2018.pdf
2. https://www.ing.com/About-us/Compliance/Zero-Tolerance-Bribery-Statement.htm

- Compliance risk ING faces the risk of compliance failures, especially in areas where regulations are unclear, subject to multiple interpretations, in conflict with each other, or where regulators revise their guidance. While we are vigilant in our efforts to comply with applicable laws and regulations, it remains a significant operational challenge to meet all the requirements within the regulatory timelines. People with the necessary knowledge and skills are scarce and implementing the necessary processes and procedures has significant implications for IT systems and data.

- ING employees are encouraged to report violations via the internal reporting lines outlined in the Whistleblower Policy. Shareholders, third parties and other stakeholders can report their suspicions to ING’s chief compliance officer.

- To help us manage and mitigate compliance risks we have a set of policies and procedures based on laws and regulations, as well as the standards defined for managing all non-financial risks as set out in ING’s internal control framework. We provide training for employees on topics such as money laundering, terrorist financing, sanction and export control compliance and conduct risks such as conflicts of interest, misselling, corruption and protection of customers’ interests. There is also training on risk culture, the Foreign Account Tax Compliance Act (FATCA), the Common Reporting Standard (CRS), and US withholding tax and information reporting regulations. Some of these trainings are specifically for risk and compliance experts, others aim to raise awareness among all employees and new joiners.

- To reinforce the values and behaviours in our Orange Code, which puts integrity above all, we invite all employees to participate in e-learnings that aim to equip them to make the right decisions when faced with a dilemma or issue.

We’re not only improving processes and procedures, but building the right compliance culture. That starts with ING’s senior leaders
To further highlight the importance of KYC/AML in the organisation and to tighten the culture of the organisation in this area, to achieve continuous compliance: a KYC/AML leadership day was held at the beginning of 2018 for senior management, led by the COO and the CRO of ING.
In March 2018, the ‘i for integrity’ programme was rolled out at ING in the Netherlands to have an impact not only on the minds, but also the hearts of the ING employees. This programme, aims at strengthening the internal compliance culture.
A team with psychological training has been appointed and started the roll out of behaviour risk assessments to detect high risk behaviours and intervene where needed. The head of this team reports to ING’s CRO.
In March 2019 KYC/AML enhancement was extensively addressed during the ING leadership days, led by the Management Board Banking.

References:
1. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/2019-Annual-Report-ING-Group-NV%20(2).pdf
2. https://www.ing.com/about-us/compliance/complaints.htm
3. https://www.ing.com/About-us/Compliance/Zero-Tolerance-Bribery-Statement.htm
4. https://www.ing.com/About-us/Compliance/KYC-and-anti-money-laundering-measures.htm

- In 2019, we commenced the creation of new e-learnings on anticompetitive conduct, anti-bribery and corruption and data protection for launch early 2020. We also developed a global code of conduct that builds on the Orange Code and sets the standards we expect our people to uphold. This global code of conduct was launched during 1Q 2020.

References:
1. file://ad.ing.net/WPS/NL/P/UD/200027/TL84AL/Home/Downloads/2019-Annual-Report-ING-Bank-NV%20(1).pdf (especially Stakeholder engagement section, page 442)
2. https://www.ing.com/About-us/Compliance/KYC-and-anti-money-laundering-measures.htm