FinanceMap scores this financial institution in the following areas. Please navigate to the relevant tab for in-depth analysis
FinanceMap assesses these portfolios for this financial institution. Please navigate to the relevant tab for in-depth analysis.
Internationale Nederlanden Groep (ING) is somewhat aligned with the TCFD’s recommendations regarding the governance of climate-risk. The board appears to have incorporated climate-related issues into corporate strategy and risk management processes through a board ESG committee. Management-level positions and committees are assigned clear climate-related responsibilities, though details on how management is involved in the implementation and management of climate strategy lacks granularity.
ING appears to consider climate-related risks and opportunities on several different business activities as well as some climate action targets over different time horizons. It has clearly described its processes for determining which risks are relevant to its business and has outlined its methodology for steering its loan book to net zero.
ING provides examples of how it considers climate-related risks and opportunities in business planning across various business areas including operations, client engagement, advisory services and its net zero financing approach.
ING has tested the resilience of its business strategy using climate scenarios across some units. In its 2021 Climate Report, ING outlines how it conducted proof of concept (PoC) scenario analysis covering transition and physical risks on a sample portfolio that included companies in energy, transport and logistics, and metals and mining sectors. In 2022, ING participated in the ECB’s industry-wide climate stress test, as well as an internal combined climate risk stress test. The organization states that it has developed a procedure to formally integrate climate risk stress testing into the group stress testing framework.
ING references some processes for identifying and assessing climate-related risks. For example, the organization has conducted heatmap analyses for both physical and transition risks. It also conducts quantitative assessments of physical risks on its mortgage portfolio.
The organization outlines various processes for managing climate-related risks, including a risk mitigation process for reducing, avoiding, monitoring, and transferring risks. Additionally, ING has an ESR policy and framework for environmental and social risk-sensitive sectors.
ING appears to embed climate-related risks into its overall risk management; for example, it has formally integrated its climate risk stress testing into the group’s ICAAP Stress Testing Framework. Furthermore, it uses its heatmapping analyses to integrate climate and environmental risk into its Risk Appetite Setting cycle.
The organization is transparent about several key metrics used to measure and manage climate-related risks, including assets and business activities vulnerable to climate risks and sustainable finance metrics. It has reported on operational Scope 1 and 2 emissions as well as limited Scope 3 emissions. ING also discloses comprehensive financed emissions data that covers several asset classes and has a high level of granularity by sector, and includes client Scope 3 emissions for several sectors.
In August 2021, ING joined the Net Zero Banking Alliance, increasing the ambition of its previous targets. The organization’s Terra approach to reach net zero includes interim targets for eleven sectors, though many of these targets have been set in emissions intensity metrics rather than absolute emissions reductions. Sectors covered include power generation, oil and gas, commercial real estate, residential real estate, cement, steel, automotive, aviation, and shipping. ING has revised and added new targets over the past several years.
ING has established coal financing exclusion policies and will not finance new coal-fired power plants or thermal coal mines, and will not take on new clients whose reliance on coal is greater than 10% or do not have a strategy to reduce reliance to 5% by 2025. Additionally, it is phasing out lending to coal-fired power plants by 2025, but has outlined a few exceptions to this target and it is unclear if restrictions to thermal coal mining are robust.
ING announced will not provide dedicated upstream finance for new oil and gas fields approved for development after 31 December 2021. Additionally, it will not provide project financing for new oil and gas fields or mid-stream infrastructure or provide general finance to pure-play upstream oil and gas companies, and aims to phase out upstream oil and gas financing by 2040. The organization has also set some exclusionary policies for unconventional oil and gas, excluding certain types of unconventional projects as well as companies that generate more than 30% of revenue from unconventional activity. ING also has set interim reduction targets for both credit exposure and emissions for its oil and gas portfolio.
ING has included nuclear energy in its ESR Framework, however it is unclear how its financing of nuclear relates to the wider energy transition. Moreover, the organization has made progress in supporting clients in the energy transition and facilitating sustainable investment in renewable energy. Renewables make up 60% of ING’s power generation portfolio and has more than tripled its target for financing of renewables, aiming to finance €7.5 billion in renewables by 2025.
FinanceMap’s Climate Governance and Policies analysis assesses statements financial institutions (FIs) are making on how they are incorporating climate issues into their decision-making and operations using FinanceMap’s matrix methodology. This methodology is adapted from the Task Force on Climate-Related Financial Disclosures (TCFD) recommendations and guidelines, Net-Zero Banking Alliance (NZBA) or equivalent Glasgow Financial Alliance for Net-Zero (GFANZ) initiative reporting, and IPCC and IEA technology statements. The TCFD provide guidance on 11 recommendations across four areas which are reflected in our matrix: Governance, Strategy, Risk Management, and Metrics and Targets. Additional benchmarks have been introduced to strengthen the ambition of scoring criteria in the assessment of targets, which are supplemented by guidance from the NZBA or equivalent GFANZ initiatives.
Additionally, Science-Based Policy (SBP) benchmarks are used to measure alignment of an FIs technology positions with the science of climate change. These benchmarks are applied to an FIs internal policies on technologies including coal, oil, gas, nuclear, and renewables and also assesses its engagement with broader climate and energy policy issues such as advocacy on the role and importance of different strategy types in the future energy mix.
For each TCFD recommendation and technology, FIs statements are applied to a five point scoring scale ranging from +2 to -2, measuring alignment with the relevant benchmarks. The detailed scores for this FI are displayed below within each matrix cell.
The following table outlines the key queries and data sources, which FinanceMap uses to assess financial institutions climate governance, targets and policies. Every evidence piece is assessed on a five-point scale of -2,-1,0,1,2 or NA (not applicable)/NS (not scored). All queries, data sources, and evidence pieces are weighted against one another in a matrix system to arrive at a final top-level score. Clicking on specific cells will load the underlying evidence and information on how it has been assessed.
Fossil fuel companies are those whose primary sector falls within coal mining and services, or up-, mid-, and downstream oil and gas sectors. Green companies are defined as companies having over 75% revenue deriving from Substantial Contribution to Mitigation activities under the EU Taxonomy.
Portfolio Paris Alignment analysis of this institution's activities in this portfolio area assesses deals in 2020–2024.
Value Assessed: $264B
Sector Paris Alignment scores for the sectors to which this portfolio has exposure. FinanceMap Paris Alignment analysis is limited to the automotive, upstream fossil fuel, and power sectors.
Fossil fuel companies are those whose primary sector falls within coal mining and services, or up-, mid-, and downstream oil and gas sectors. Green companies are defined as companies having over 75% revenue deriving from Substantial Contribution to Mitigation activities under the EU Taxonomy.
Portfolio Paris Alignment analysis of this institution's activities in this portfolio area assesses deals in 2020–2024.
Value Assessed: $99.6B
Sector Paris Alignment scores for the sectors to which this portfolio has exposure. FinanceMap Paris Alignment analysis is limited to the automotive, upstream fossil fuel, and power sectors.
Climate Lobbying Overview: Internationale Nederlanden Groep (ING) has displayed mostly positive engagement on climate-related policy, and specifically takes a positive position on real economy climate policy.
Top-line Messaging on Climate-Related Financial Policy: ING CEO Steven van Rijswijk, has stated support for a role for finance in achieving the goals of the Paris Agreement] in a September 2024 Financial Times article and the EU 2030 target in a March 2022 press release. ING has also supported increased ambition in EU sustainable finance regulation and, as part of the Net Zero Banking Alliance (NZBA), ING has supported investment strategies in line with net-zero by 2050.
Position on Regulated Corporate Climate Disclosure: ING has stated broad support for regulated corporate climate disclosures on its website. In response to the European Financial Reporting Advisory Group (EFRAG) on the European Sustainability Reporting Standards (ESRS) in 2022, ING Poland expressed concerns that ESRS disclosures would be too complex. However, in a July 2023 response to the Commission’s proposal on the ESRS, ING urged the Commission to make climate disclosure requirements mandatory irrespective of the materiality assessment. In the Climate Progress Update 2024, ING expressed support for the Corporate Sustainability Reporting Directive (CSRD). In a March 2024 article, ING strongly supported the SEC’s climate disclosure rules.
Position on Taxonomies: ING appears to take a mixed position on the EU taxonomy. In a 2023 letter in response to Friends of the Earth, ING appeared to support the EU taxonomy. In a media interview in 2023 with Hans Biemans, Head of Sustainable Markets at ING and member of the Commission Platform on Sustainable Finance, he stated clear support for the EU Taxonomy, although highlighted that simplification is a key area to work on “for the sake of usability”. ING however did advocate for a weakening of the EU taxonomy green asset ratio in a 2024 Climate Progress Update.
Position on ESG Ratings: ING appears to support policy on ESG ratings. In 2022 ING Bank Śląski S.A. actively supported regulation on ESG ratings and ratings agencies in a consultation response to the European Commission. ING also appeared to support ESG ratings of the European Securities and Markets Authority in its 2024 Climate Progress Update.
Position on Incorporating Climate Factors Into Risk Management/Prudential Regulation: ING generally appears to have an unclear position on incorporating climate factors into risk management and prudential regulation. In an April 2023 article ING did not specify whether it supports efforts from the Fed to address climate change through stress testing. ING opposed climate-related capital adjustments and a double materiality approach to prudential regulation in response to a 2022 European Banking Authority (EBA) consultation. It did however appear to support the EBA's risk-based approach to prudential regulation on climate issues
Position on Real Economy Climate Policy: Generally, ING is supportive of real economy climate policy. ING has expressed support for a carbon price on several occasions, including in its 2024 Climate Progress Update and in its 2023 Climate Progress Update. ING has also supported methane emission regulation policy, in its 2023 Annual Report and in its 2023 Climate Report. ING has supported energy efficiency legislation in the shipping industry in its 2023 Climate Report, and buildings sector through the EU Energy Performance Buildings Directive (EPBD) in its 2024 Climate Progress Update. In its 2023 Climate Report however, ING advocated for the weakening of the EPBD, opposing minimum energy performance standards and supporting subsidies and loans as an alternative. In a 2023 website article ING supported circular economy regulation.
Position on Energy, Industry, and Land Transitions: ING has published detailed positions on energy, industry and land transitions in its Climate Progress Update 2024. In this report, ING supported the decarbonization of the steel industry, agriculture, transport and the energy sector. ING strongly supported the removal of fossil fuel subsidies and has advocated for this in both its Climate Progress Update 2024 and Summary for policymakers - Climate Progress Update 2024. ING has also stated support for government action to boost renewables, including subsidies, in the 2023 Climate Report.
Industry Association Governance: ING has disclosed a partial list of its industry association memberships but appears to exclude its membership to certain industry associations such as DigitalEurope for example. ING does not appear to have disclosed an account of its industry associations' climate positions and engagement activities.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q3 2024.
InfluenceMap’s methodology for assessing lobbying on climate finance policy closely follows InfluenceMap’s established methodology on climate policy engagement, which is used extensively by investors, including via the Climate Action 100+ investor engagement process. Our full methodology can be found here.
Under our lobbying assessment, InfluenceMap considers engagement on all financial policies which intersect with climate issues, as well as “real economy” climate change policies.
The analysis takes into account both the engagement of the financial institution and the activities of industry associations they hold membership of. InfluenceMap’s methodology covers seven publicly available data sources, searching for evidence of engagement and corporate positioning since 2017. To determine the policy issues within the scope of the analysis, InfluenceMap breaks down policy engagement into a series of subcategories, or 'queries'. These are designed to cover high-level issues relating to the importance of sustainable finance, as well as more specific areas of sustainable finance policymaking. InfluenceMap’s research process searches for evidence of an organization's engagement with each policy issue, across each of the data sources.
The following table outlines the key queries and data sources, which InfluenceMap uses to assess financial institutions' policy engagement. Every evidence piece is assessed on a five-point scale of -2,-1,0,1,2 or NA (not applicable)/NS (not scored). All queries, data sources, and evidence pieces are weighted against one another in a matrix system to arrive at a final top-level score. Clicking on specific cells will load the underlying evidence and information on how it has been assessed.
In this section, we depict graphically the relationships the corporation has with trade associations, federations, advocacy groups and other third parties who may be acting on their behalf to influence climate change policy. Each of the columns above represents one relationship the corporation appears to have with such a third party.
In these columns, the top, dark section represents the strength of the relationship the corporation has with the influencer. For example if a corporation's senior executive also held a key role in the trade association, we would deem this to be a strong relationship and it would be on the far left of the chart above, with the weaker ones to the right. Click on these grey shaded upper sections for details of these relationships. The middle section contains a link to the organization score details of the influencer concerned, so you can see the details of its climate change policy influence. Click on the middle sections for for details of the trade associations. The lower section contains the organization score of that influencer, the lower the more negatively it is influencing climate policy.
