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.
Portfolio Paris Alignment analysis of this institution's activities in this portfolio area in 2020–2021.
Value Assessed: $92.6B
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.
Portfolio Paris Alignment analysis of this institution's activities in this portfolio area in 2020–2021.
Value Assessed: $43.6B
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.
ING appears to have had some detailed engagement on sustainable finance policy, with mixed positions.
ING has stated support for a role for finance in achieving the goals of the Paris Agreement and EU’s 2030 target, as well as investment strategies in line with net-zero by 2050, as part of the Net Zero Banking Alliance (NZBA). ING has also supported urgent action to tackle biodiversity loss, as well as increased ambition in EU sustainable finance regulation.
During 2021-23, ING has stated broad support for regulated corporate ESG disclosures on its website. In 2021, it appeared to support the SEC’s efforts around climate disclosures in a website article, but otherwise does not appear to have engaged with this policy. In response to the European Financial Reporting Advisory Group (EFRAG) on the European Sustainability Reporting Standards (ESRS) in 2022, ING Poland argued that sector-agnostic disclosures should not account for double materiality and limited "as not to burden entities". However, in response to the Commission’s proposal on the ESRS in 2023, it urged the Commission to make climate requirements as well as disclosures required under the Sustainable Finance Disclosure Regulation (SFDR) mandatory irrespective of the materiality assessment.
ING stated high-level support for the taxonomy in a 2020 website article, however, most recent references to the EU Taxonomy do not state a clear position. In response to the Commission’s consultation on the Renewed Sustainable Finance Strategy in 2020, it supported a taxonomy that also covered 'social' issues. 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”.
In response to the Commission in 2020, while ING appeared to support the EU Green Bond Standard, it did not support the accreditation of verifiers nor possible labels for professional investment funds, and did not appear to support the Commission's proposed actions on integrating ESG preferences into advice to retail clients. In response to the Commission in 2020, ING also supported the inclusion of ESG factors in bank risk calculations and prudential regulation. In a report in 2021, ING appeared to support the EU sustainable finance disclosure regulation (SFDR). In a 2023 letter to Friends of the Earth published on its website, ING appeared to support increased transparency under a number of EU regulations, such as the Sustainable Finance Disclosure Regulation (SFDR).
ING has published a partial account of its positions and engagement activities on specific sustainable finance policies in website articles, but excludes recent material evidence of direct sustainable finance policy engagement identified by InfluenceMap's database. For instance, it has not disclosed recent engagement with corporate disclosures regulation in the EU during 2022-2023. ING has disclosed a complete list of industry association memberships on its website, but has not included any details on positions or engagement activities.
InfluenceMap’s methodology for assessing lobbying on sustainable 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 assessment of sustainable finance lobbying, InfluenceMap considers engagement on all financial policies which intersect with climate and/or other sustainability issues. 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 sustainable finance 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 sustainable finance policy issue, across each of the data sources.
The following table outlines the key queries and data sources, which FinanceMap uses to assess asset managers' corporate engagement programs. 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.
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Gary Prince is on the board of AFME (last checked July 2023).
Gary Prince (Global Head of FX & Rates Trading and, Head of Financial Markets EMEA)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Obbe Kok is on the board of AFME
Obbe Kok (Head of Financial Markets EMEA and Global Head Balance Sheet Management, ING)
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Gary Prince is on the board of AFME (last checked July 2023).
Gary Prince (Global Head of FX & Rates Trading and, Head of Financial Markets EMEA)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Obbe Kok is on the board of AFME
Obbe Kok (Head of Financial Markets EMEA and Global Head Balance Sheet Management, ING)
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
EBF is listed in ING's memberships (last checked July 2023).
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
ING is a member of UK Finance which is a national association member of EBF
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
EBF is listed in ING's memberships (last checked July 2023).
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
ING is a member of UK Finance which is a national association member of EBF
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
ING Bank NV is an associate member of Japanese Bankers Association (last checked December 2021).
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
ING Bank NV is an associate member of Japanese Bankers Association (last checked December 2021).
not specified
--no extract--
Internationale Nederlanden Groep (ING) is aligned with the TCFD’s recommendations regarding the governance of climate-risk. The board appears to have oversight of strategic climate-related risk and opportunity management and approves ING’s overall risk appetite. Management-level positions and committees are assigned clear climate-related responsibilities, and there are processes in place to ensure they monitor the progress of climate-related issues and initiatives.
ING appears to consider climate-related risks and opportunities on its lending business activities as well as over different time horizons and has identified various acute and chronic physical risks relevant to its business. However, it does not define other relevant climate-related risks and opportunities over different time horizons.
It provides some examples of how it considers climate-related risks and opportunities in business planning in its Terra Progress report and Climate Risk report. For example, ING has committed to steer its lending portfolio to align with the Paris Agreement using its Terra approach.
ING has tested the resilience of its business strategy using climate scenarios across some units. Its 2020 Climate Risk Report references robust analysis conducted on its real estate portfolio's sensitivity to physical risks. 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
ING references some processes for identifying and assessing climate-related risks. For example, the organization investigated the effect of transition risk across numerous sectors in the form of a heatmap and has identified which sectors are high, medium, or low risk and extended this analysis to cover physical risks in its 2021 Climate Report. It also uses an ESR assessment criteria to assess client activities. and it considers climate-related risks in assessments of credit, market, liquidity, underwriting, and operational risks.
The organization outlines some processes for managing climate-related risks, including an Environmental and Social Risk (ESR) Framework that applies to ING’s business engagements which a dedicated team safeguards. Additionally, ING’s Sustainable Finance team supports clients via products, services, and strategic governance designed to drive its Terra commitment.
ING appears to integrate climate-related risks into its overall risk management; for example, its ESR framework includes a climate change and environmental policy, which is one of its two fundamental cross-sector policies. Furthermore, climate-related risks are increasingly overseen by relevant risk management committees across the organization.
The organization is transparent about the key metrics used to measure and manage climate-related risks, including metrics on water, waste, energy consumption, etc. However, it is unclear if it uses metrics to measure and manage climate-related opportunities. ING discloses Scope 1 and Scope 2 emissions data and some Scope 3 emissions data. It publishes emissions intensity data for various high emitting sectors and portfolio emissions of its residential real estate portfolio using a methodology in line with PCAF.
In August 2021, ING joined the Net Zero Banking Alliance, increasing the ambition of its previous targets. The Terra approach is broken down into nine sectors, five of which are already in line with the NZBA pathways, and it is in the process of updating its positions and targets for the other four sectors. It has set a target to reduce its financing to upstream oil and gas by 12% by 2025 in line with the IEA net-zero scenario.
ING is aligned with elements of TCFD guidance on the role for coal in the energy mix up to 2050. The bank has established coal financing exclusion policies and will not finance new coal-fired power plants or thermal coal mines. Additionally, it is phasing out of coal-fired power generation, reducing its exposure to close to zero by 2025. It is unclear if it plans to exit the coal mining value chain on the same timeline.
The organization has set similar exclusionary policies for oil and gas, limiting certain activities related to shale gas in Europe, Arctic offshore oil and gas, and oil sands. Additionally, ING has set a target to reduce its financing by 12% by 2025 and in March 2022, it announced it will no longer provide dedicated upstream finance for new oil and gas fields approved for development after 31 December 2021.
ING appears to be supportive of a future role of nuclear in the energy mix, but requires certain conditions to be met to ensure clients meet international safety standards. Moreover, the organization has communicated support for a low-carbon economy and has made progress in supporting clients in the energy transition and facilitating sustainable investment in renewable energy. On March 23rd, 2022 ING announced it is aiming to increase new financing for renewables by 50% by the end of 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.
Open PDF file of Data Source