ING Group

ING Group N.V.
Quick Facts
Type	Public
sector	Finance
Headquarters (Benelux Organization)	Amsterdam, Netherlands
Year of Origin	1991
Emissions (All Scopes)	42 megatonnes
NCI assessment	Low
Total Revenue	17.6 billion EUR (2020)
Stock Exchange	Brussels, Amsterdam & New York
Key People	Steven van Rijswijk (CEO) Tanate Phutrakul (CFO)
Number of Employees	14754
Subsidiaries	ING Bank N.V. (Amsterdam) Bank Mendes Gans N.V. (Amsterdam) ING Belgium S.A./N.V. (Brussels) ING Luxembourg S.A. (Luxembourg City) ING DiBa AG (Frankfurt am Main) ING Bank Slaski S.A. (Katowice) ING Financial Holdings Corporation (Delaware) ING Bank A.S. (Istanbul) ING Bank (Australia) Ltd (Sydney) ING Commercial Finance B.V. (Amsterdam) ING Groenbank .N.V. (Amsterdam)

ING Group N.V., stylized as Internationale Nederlanden Group, was founded in 1991 by a merger of the Dutch insurance company Nationale-Nederlanden and national postal bank NMB Postbank. ING Group is active in the financial sector with products like savings, payments, investments, loans, mortgages and wholesale banking. ING serves over 39.3 million individual customers, medium-sized businesses, multinational corporations and financial institutions. ING is active in over 40 countries. In the retail market, ING is market leader in the Netherlands, Belgium and Luxembourg and a challenger in the German market. ING total portfolio amounts to 887.5 billion euro’s worth of outstanding shares. ING recorded a net income of 17.6 billion, and a net result of 2.5 billion euro’s in 2020, which was a 48% decline compared to 2019. ING is headquartered in Amsterdam, the Netherlands. According to the Financial Stability Board and the Nederlandse Bank, ING is both nationally as well as internationally identified as a 'systemically important bank' (G-SIBs) and will therefore be backed by the State in case of problems. G-SIBs are deemed essential for international monetary stability.

In 2021, ING Group's balance value was 951.3 billion euro. In 2020 this was 937.3 billion. ING is a public company with shares listed at the Brussels, Amsterdam and New York Exchange. ING's loan book in 2020 had an estimate of 42 megaton of emissions of CO2 eq.

Company Structure

ING Groep N.V. (ING Group) is a publicly listed company based in the Netherlands. ING Group is the parent of one main legal entity: ING Bank N.V. (ING Bank). ING Bank is the parent company of various Dutch and foreign banks, other subsidiaries, branches and representative offices globally.

Share capital of ING Group consists of ordinary shares and cumulative preference shares. Currently, only ordinary shared are issued. Each share gives right to one vote. Only investor group BlackRock Inc. holds more than 3% of shares in ING group. ING’s shares are listed at the Amsterdam, Brussels and New York stock exchange. Geographically, most outstanding shares are American-owned (40%) with the UK following (18%).

ING is headquartered in Amsterdam. ING is historically a Dutch company and therefore resides in the Netherlands.

ING knows 11 principal subsidiaries and one joint venture. In most of the countries in which ING is active, the local activities are carried out by a branch of its main subsidiary, ING Bank N.V.

Board of Directors

ING Group has a two-tier board structure consisting of the Executive Board and the Supervisory Board. The Supervisory Board has established four permanent committees to prepare its decision-making and to advise the Supervisory Board on specific matters, namely the Risk Committee, the Audit Committee, the Nomination and Corporate Governance committee and the Remuneration Committee.

ING Bank also has a two-tier board structure, consisting of the Management Board Banking and the Supervisory Board. The members of the Executive Board are also members of the Management Board Banking and are therefore double-hatting. In addition, the Supervisory Board and committees of the Supervisory Board are identical for both ING Group and ING Bank.

Executive Board

Name	Function	Remuneration EUR in 2021
Steven van Rijswijk	Chief Executive Officer	1,776,300
Tanate Phutrakul	Chief Financial Officer	1,221,700
Ljiljana Čortan	Chief Risk Officer (as of her appointment as CRO at the AGM on 26 April 2021)	837,600

In 2021, the current board members made 3,835,600 euro’s. This number excludes i) the variable remuneration of 663,471 euro's (the percentage for the Executive Board members are as follows: CEO 17% (301,119), CFO 18% (218,151) and CRO 17% (144.121)), and ii) an additional set of benefits amounting to 495,500 euro's for the CEO, 349,800 euro's for the CFO and 382,200 euro's for the CRO (as of her appointment on 26 April 2021).

Management Board Banking

Management Board Banking

Name	Function
Pinar Abay	Head of Market Leaders
Aris Bogdaneris	Head of Challengers and Growth Markets
Roel Louwhoff	COO and chief transformation officer
Isabel Fernandez	Head of Wholesale Banking

There is no information available on the individual remuneration of the management board banking.

Supervisory Board

Supervisory Board

Name	Function	Remuneration x1000 EUR
Hans Wijers	Chairman	173
Hermann-Josef Lamberti	Vice-chair	48
Mike Rees	Vice-chair	129
Jan-Peter Balkenende	Member	80
Juan Colombas	Member	23
Mariana Gheorghe	Member	108
Eric Boyer de la Giroday	Member	38
Margaretha Haase	Member	105
Herman Hulst	Member	68
Harold Naus	Member	68
Herma Verhagen	Member	100

These numbers exclude the stocks granted to the board and supervisory board.

Accountant

The auditor of ING Group is KPMG. KPMG has been the auditor of ING since the financial year of 2016.

In the annual report of 2021, under the heading Audit Responses to Climate Change Risk, KPMG states that "the Management board is responsible for preparing the financial statements in accordance with the applicable financial framework, including considering whether [...] climate change risks and commitments have been appropriately accounted for and disclosed". Additionally, KPMG argues that it is part of their audit to consider potential effects of climate change risks on the accounts and disclosures. It is also up to them to determine whether said financial statements are "free from material misstatement". In order to do this they i) assessed the minutes of the Climate Change Committee, ii) obtained an understanding of the integration of climate-related risks in credit risk policies and procedures, iii) obtained an understanding of the process to identity climate-related risks and the heatmap developed by ING and iv) held inquiries with staff involved with the integration of climate-related risks into credit risk policies.

Throughout the rest of the audit, it remains unclear what the exact results of this were. However, it is positive to see that the accountancy takes it upon themselves to be critical of and analytical of ING's consideration of global warming as a risk.

Main Activities

ING Group is active in the financial sector with products like savings, payments, investments, loans and mortgages as well as wholesale banking. In wholesale banking ING provides specialized lending, tailored corporate finance, debt and equity market solutions, sustainable finance solutions, payments & cash management and trade and treasury services. ING serves over 39.3 million individual customers as well as small and medium-sized businesses up to multinational corporations and financial institutions.

Government

ING has not received corona-related NOW support from the Dutch government. ING does not have royal status. However, taking into account the fact that ING is classified as a global systemically important bank, ING can count on government support when absolutely necessary. For instance, during the credit crisis in 2008, the Dutch government made 10 billion euro available to help ING.

Paris Agreement until Today

Since the Paris Agreement in 2015, ING has strived to set a pledge to get multiple banks to steer their portfolio towards the well-below two degree goal of the Paris Agreement. This resulted in the signing of the Katowice Agreement together with four global banks. This consequently formed the groundwork for the UN-backed collective commitment to Climate Action in 2019, signed by over 30 banks. The total amount of 54 signatories henceforth committed to make a substantial contribution to the implementation of the Paris Agreement and the Dutch Climate Agreement. Concretely: they will measure the CO2 content of their relevant loans and investments and report on this from 2020 onwards and they will publish action plans by 2022 at the latest, including reduction targets for 2030 for all their relevant loans and investments.

Criticism on this commitment:

• This commitment is without obligation. There are no requirements set for the action plans to be published in 2022. Only 19% of signatories had an action plan in line with the Paris Climate Agreement by 2020. In addition, the commitment does not specify the relevant financing and/or investments on which the institutions must report. In 2020, only 9 out of 54 financial institutions report on all relevant asset classes.
• The pace of implementation of this commitment is too slow. Financial institutions such as ABN AMRO, Aegon, ING and Rabobank already committed themselves to the Spitsbergen ambition in 2018, in which they promised to combat climate change. In 2020, almost half of the institutions did not yet have a climate plan.

ING and the think-tank for the financial sector ‘'2° Investing Initiative’’ published PACTA for banks, an open-source methodology to measure and monitor climate goals. In August 2021, ING joined the Net-Zero Banking Alliance, committing to steer its portfolio towards net-zero greenhouse gas emissions by 2050. ING published its first ‘’Terra Report’’ in 2019 and its first integrated climate report in 2021.

ING has decreased its exposure to thermal coal mining by more than 90 percent from 317 million in 2017 to 30 million in 2020.

Financial Results since 2015

In this table, the financial situation of the company since 2015 is shown.

Financial situation

Year	Revenue	Profit	Dividend
2015	16.9 billion EUR	4 billion EUR	2.5 billion EUR
2016	17.5 billion EUR	4.6 billion EUR	2.6 billion EUR
2017	17.8 billion EUR	4.9 billion EUR	2.6 billion EUR
2018	18.2 billion EUR	4.8 billion EUR	2.7 billion EUR
2019	18.3 billion EUR	4.9 billion EUR	2.7 billion EUR
2020	17.6 billion EUR	2.6 billion EUR	468 million EUR
2021	18.5 billion EUR	4.9 billion EUR	2,37 billion EUR

Fossil and Agricultural investments

This table shows ING's fossil and agricultural investments with high CO₂ emission intensity. Numbers are in billions.

ING's fossil and agricultural investments with high CO2 emission intensity (billion euro)

Investments, outstanding amounts	year-end 2020	Percentage of total	year-end 2021	Percentage of total
Production of electricity (fossil part)	4.15	0.47%	5.3	0.59%
Manufacture of refined petroleum products	2.92	0,33%	3.12	0.34%
Extraction of crude petroleum	4.78	0.54%	4.62	0.51%
Extraction of natural gas	1.85	0.21%	1.89	0.21%
Mining of hard coal	0.33	0.04%	0.31	0.03%
Support activities for petroleum and natural gas extraction	3.46	0.4%	3.86	0.42%
Wholesale of solid, liquid and gaseous fuels and related products	14.8	1.67%	19.81	2.18%
Raising of dairy cattle	1.03	0.12%	1.07	0.12%
Raising of swine/pigs	0.19	0.02%	0.21	0.02%
Raising of poultry	0.38	0.04%	0.38	0.04%

Except for extraction of crude petroleum and hard coal, which show a slight decrease, there is not really a sign of moving out of fossil.

Current Emissions

ING estimates emissions of 42 megaton of CO2 eq. in their loan book. Their scope 1, 2 and 3 (from business travel) account for 0.025 mtCO2e. ING neglects to report on other downstream scope 3 emissions.

ING’s Terra approach means to align ING’s lending portfolio with Paris Agreement goals in nine sectors most responsible for climate change. The report’s Climate Alignment Dashboard tracks the performance, showing the CO2 intensity per sector of ING’s portfolio compared to the market and the relevant climate scenario. The first Terra Report was published in 2019. A second report was published in 2020, and in 2021 ING published an integrated climate report for the first time.

ING claims to align itself to either PACTA or B2DS Scenario. However, in three of the nine sectors, the convergence pathway of ING is until 2050 above the B2DS Scenario or the PACTA scenario. For all sectors reported on, CO₂ intensity is given. For oil and gas, ING shows the absolute portfolio reduction trend in line with the relative climate scenario with their 2019 upstream portfolio as a base year for reduction. For shipping, ING shows the average alignment delta: the difference between actual and required annual efficiency ratio per vessel. These different measures reduce comparability of emissions in hard numbers.

• 1. Power generation: convergence path is in line with Net Zero Emissions reference. ING outperforms both the market and reference scenario. This makes the 2030 target less impressive.
• 2. Upstream oil and gas: ING does not have emission reduction targets. There is a financing reduction goal of 69 percent in 2050. Thermal coal mining will be completely phased out in 2025.
• 3. Commercial real estate: ING is nearly on track to reach zero emissions by 2040. This is ten years earlier than the planned trajectory.
• 4. Residential real estate portfolio: ING want to become energy-positive by 2050. However, their trajectory pathway until 2050 is (far) above the B2DS scenario.
• 5. Cement portfolio: ING’s plans are in line with the B2DS scenario. However, current performance is not in line with neither the convergence path nor B2DS scenario. The 2050 target is not zero.
• 6. Steel sector: ING has not yet decided their convergence path and follows market developments.
• 7. Automotive sector: ING’s convergence path is above the B2DS scenario until 2050. The ING reduction target for the automotive sector is only focused on zero tailpipe emissions.
• 8. The climate scenario for the aviation sector has no zero targets for 2050. The B2DS scenario’s target is 20 gr. CO₂/passenger KM. Until 2050, ING’s convergence pathway is above the target.
• 9. The international shipping sector is not part of the Paris Agreement. The International Maritime organization however has proposed the goal reducing total GHG emissions by at least 50% by 2050, compared to 2008. ING is committed to this ambition. The reporting however lacks a clear target and emission numbers.

Total reported emissions since 2015 (in kiloton CO2-eq.), ING Group

Year	Scope 1	Scope 2	Scope 3	Total
2015	22	32	29	82
2016	20	14	29	63
2017	16	10	30	55
2018	14	7	30	50
2019	12	7	23	42
2020	12	4	8	24
2021	9	4	6	20

In the data given above, scope 3 emissions only include emissions from business travel by air and car.

Emissions through their leading and investments (scope 3, category 15) are reported in their annual Terra progress reports starting 2021. Prior to this, ING stated that despite scope 3, category 15 emissions being material to ING’s indirect emissions footprint, they were unable measure and disclose this figure due to measurement complexity and lack of quality data. This is why hardly any data is available in this period before 2021.

Since 2020, ING measures their scope 3 emissions through their Terra Progress Reports. The Terra Progress report encompasses 75% of ING’s outstanding loan book. However, only emission intensity is given and outstanding investments are mentioned, but no total mission number is given per sector. Based on the information given, it is also not possible to calculate an emission number for scope 3. ING makes an estimate, so the underlying data is there. ING chooses not to report this data.

Climate Policies and Plans

ING has increased its ambition to align its loan book with a net zero future by 2050 or sooner. ING will now evolve its Terra approach to steer their loan book towards keeping the rise in global temperatures to a maximum of 1.5 °C, rather than well below 2 °C. ING plans to reduce emissions in scope 1 & 2 by 90 percent in 2030. As the emissions table shows, this hardly makes a difference as by far most of the emissions of ING are in scope 3.

ING’s priorities are as follows:

• Reaching Net Zero in own operations
• Steering portfolio towards net zero by 2050 or sooner
• Finance and advise clients in line with a net zero economy
• Manage climate and environmental risks

In 2019, ING Group signed the climate commitment for the financial sector. All 54 financial institutions that signed this commitment commit to taking their responsibility in the execution of the Paris Agreement as well as the Dutch Climate Agreement. This means that these institutions need to measure and reduce the emissions from their relevant investments, report about those from 2020 onwards and before 2022 publish a plan of action including reduction measures for 2030 for all relevant investments, shares and guarantees.

However, this commitment is not enough. This climate commitment is not binding. There are hardly any conditions to the plans that should be published in 2022. Only 19% of the signees had a climate plan in accordance with the Paris Agreement in 2020. Also, the commitment did not mention any definitions with regard to relevant investments. In 2020 only 9 of the 54 signees reported on all classes of activa. Next to that, the pace of execution is too slow. For example, in 2018 ING committed to the Spitsbergen ambition where it promised to tackle climate change. Yet, in 2020, there was still no Paris Proof climate plan.

Hopeful news is that ING announced that it would stop financing the exploration of new oil and gas fields. It will still be involved in the supply chain of oil and gas, but is planning to reduce this involvement and make no new investments. Instead, ING want to sharply increase its investments in renewable energy.

It is important to give some context to this decision. Current projects are still being financed. The decision only concerns upstream projects. Midstream and downstream projects can still be financed. ING only speaks of projects. It can still finance companies that are in the expansion business. Between 2016 - 2020, the invested number in expansion companies was 5.9 billion USD.

In its 2021 report, ING is aware of the fact that its business and operations are "exposed to physical risks, including as a direct result of climate change". Some examples are heatwaves, droughts, flooding, storms, rising sea levels, other extreme weather events or natural disasters, and the risks arising from environmental degradation such as a loss of biodiversity. Such risks could all disrupt ING's business continuity and operations, and their investment portfolio.

Out of the nine sectors in which ING Bank invests, five are on track with the climate alignment pathways. The other three are close, and one is not on track, the latter being the aviation sector.

NewClimate Institute (NCI) Report

ING Group scores reasonably on transparency and low on integrity.

ING disclosed 69% of its portfolio's emission levels, which accounts for 42MtCO2. It hence covers all the emissions from its lending portfolio and investments but does not yet include all financial services. Nor has it further broken down its emissions level in the separate categories. Additionally, ING's Terra Approach does not take into consideration all the emission sectors, and it omits sectors such as the agricultural one. ING is also unclear regarding its engagement with clients active in the appointed Terra sectors. Furthermore, ING should expand its targets to all the financial services beyond just its loan book.

ING's exclusion policy and its engagement policy score high on transparency. This is because it excludes a large number of climate relevant activities from its portfolio. However, NCI notes that there are potential exceptions and loopholes, which explains its moderate rating for integrity. For instance, despite having oil trading and the mining of gas on its exclusion list ING does continue to finance "clients active in keeping oil and gas flowing", and it remains the 28th largest global finance provider for companies that participate in the fossil fuel industry. ING also states it would quit financing new coal-fired power plants, with the exception of a plant in Indonesia, for which no plans are made. NCI argues that ING should focus on aiding companies in developing plans to phase out coal, as opposed to focusing on financing non-coal energy projects instead. ING also aims to procure 100% renewable electricity for all ING buildings worldwide, but remains unclear on the kind of renewable power, and whether or not all of its office spaces are in control of ING's management. The bank has made progress with regard to its framing of its offset purchases, and they are now willing to compensate. However, there are certain criticisms to be made. One, ING could go further and frame it as a contribution instead of a compensation and secondly, its forestry projects do not represent a credible compensation measure in the first place.

Due Diligence

Due Diligence

Dodgy deals

BankTrack, an international tracking, campaigning and civil society support organization, which has linked ING to multiple "Dodgy Deals". For instance, ING Bank has financed a multitude of oil and extraction projects, as well as pipeline and mining projects. Between 2016 and 2021, ING has financed 12.59 billion euros in upstream oil & gas expanders, with the top three companies on the receiving end being Eni, Harbour Energy and Aker BP.

ING Bank funds deforestation

ING's portfolio includes the financing of tropical deforestation and land degradation in Southeast Asia, Brazil and Central and West Africa. They have invested over half a billion in the Brazilian company Suzano, Brazil's paper giant known for its environmentally detrimental paper mills. Regarding ING's Amazon risk exposure, and Amazon's risk management, ING scores a B-, as it continue to be engaged in financing oil traders active in the Amazon, including acting as the agent and lead bank for nine revolving credit facilities. In total, ING alongside Rabobank and AB AMRO, spent a total of 3.1 billion euro on loans with 'deforestation risks'.

ING and climate change

According to research conducted by de Eerlijke Bankwijzer in their report 'Fossil fuel versus renewable financing by financial institutions active in the Netherlands (2021)', ING turns out the biggest Dutch credit-provider for fossil fuels. Despite being committed to bring their financing portfolio in line with the Paris Agreement, they haven't expanded the same commitment to their shareholding portfolio. Additionally, the reduction goals set for the oil- and gas sector present in their portfolio is enough to limit global warming to 1.5 degrees.

On top of that, ING Group has invested a total of 5.30 billion dollars, either in loans or underwritings, in coal extraction companies.

Money laundering

In 2020, ING was once more suspected to have been involved in money laundering. This time around, they were believed to have moved money out of Russia toward the West. These speculations were based on American documents covering state secrets. Two years prior, in 2018, ING faced similar charged. They were called out for not having adequate internal measures against and control on money laundering.

Scandals and controversies

Milieudefensie vs. ING Bank

In 2019, Milieudefensie filed a complaint against ING Group at the Dutch Contant Point (NCP) at the Organization of Economic Co-operation and Development (OECD). Milieudefensie did this with Friends of the Eart Indonesia (WALHI) and Friends of the Earth Liberia (SDI). The complaint encompassed the financing of ING of three palm oil companies involved in deforestation of rainforest (Noblé Group), land grabbing (Bolloré Group/Sofin) and child labour (Wilmar).

The OESO took the complaint into consideration and started a procedure in 2020. At the time, ING had already been aware of the controversies and elements of abuse in the palm-oil industry. Alongside Milieudefensie and its partners, ING collaborated in finding a solution. However, in 2022, ING decided unilaterally to end the conversation and retract from this procedure. It is critical to note that during the procedure, the allegations were recognized and were not a point of discussion amongst the parties.

This decision makes very clear that although ING recognized its wrongdoings, it walks away from its responsibilities without any consequences. This is a prime example why a climate duty for companies needs to be added into law.

Conclusion

ING is a major financial player, essential to the financial system. With the enormous revenue and profits ING makes, it is their moral responsibility to be a leader in fighting climate change. Leadership salaries at ING are very high, as is remuneration for the supervisory board.

The ambitions of ING are in line with the 2050 goals of the Paris Agreement. ING is committed to steering their portfolio in line with the well-below two degrees scenario. Through the different collaborations with banks and governments, ING shows its goodwill. However, ING's reports show relative numbers instead of hard emissions data. It is not possible to calculate emission numbers from this data. This makes comparing performances difficult. Until 2020, ING deemed reporting their scope 3 emissions too complex.

Throughout the report, ING downplays their own responsibility by referring to lacking regulatory guidelines and the possibility of ‘’portfolio leak’’ multiple times. Not setting targets on difficult to change markets is not very committed either. ING seems to be following market developments and is reactive instead of proactive in the energy transition. In a number of sectors, the goals of ING are above the threshold and will only be in line with the respective scenario by 2050. That is not enough. ING is on the right track with the disclosure of 75% of their outstanding portfolio, but should release the underlying data to be able to make an assessment of the total impact of the ING loan book. A more transparent and proactive stance in setting goals and working towards them may be expected from a player like ING.