ING Bank is a global financial service company with Dutch roots.[1] ING serves over 37 million customers from more than 40 countries.[2] ING Group held €845 billion total assets as of the end of 2016.[3]
ING’s policy on nuclear weapons states that ING will not provide financial services that directly refer to: “The production, maintenance or trade of anti-personnel landmines, cluster munitions, depleted uranium ammunition, or nuclear, biological and chemical weapons; Nuclear weapon companies domiciled in countries that are not a party to the Treaty on the Non-Proliferation of Nuclear Weapons”.[4]
ING’s nuclear weapons policy states that companies that mainly focus on defence-related businesses and that are involved in the development, manufacture, maintenance and trading of nuclear weapons or specifically designed delivery systems are excluded. However, ING may finance or invest in companies with largely non-defence related businesses if those companies indicate that ING funds will not be used for nuclear weapons related activities.[5]
ING considers these weapons controversial due to their indiscriminate effect and the likelihood of civilians being injured. However, because ING does not yet consider nuclear weapons to be fully banned by the international community and many high tech companies are involved in various ways in the nuclear armaments programs of their respective governments, ING excludes only the nuclear weapons related activities of a company, not the company as a whole, if those companies indicate that ING funds will not be used for nuclear weapons related activities.[6]
The policy applies to ING’s commercial banking and investment banking, as well as to the investments made on its own accounts and internally and externally actively managed funds.[7] ING makes several exceptions to the exclusion policy. The policy does not apply to investments made on behalf of third party asset managers, or to clients in countries where ING claims it cannot enforce the policy and for investments made within the boundaries of an explicit customer mandate. For its own passively managed funds, ING does not offer index funds which contain over 5% of shares of nuclear weapons producers. Discretionary mandates are also exempt from this policy.[8]
ING’s exclusion list, which is based on information from NGOs, customer screening and Sustainalytics, is not publicly available.[9]
ING was found to have investments in several nuclear weapon producers identified by this report, details can be found in the Hall of Shame.
We commend ING for adopting a public policy on nuclear weapons. We recommend ING exclude all nuclear weapon producers regardless of their location. It should also exclude all activities of nuclear weapons producing companies, regardless of the relative proportion of nuclear weapons related activities of the company. ING should apply its exclusion policy comprehensively to all its markets, and to all its financial products, including funds following an index. We look forward to engaging with ING, so a strong and comprehensively applied policy may be listed in the Hall of Fame in a future update of this report.
[1] ING, “The History of ING”, website ING (http://www.ing.com/About-us/Profile-Fast-facts/History-of-ING.htm), viewed 23 January 2018.
[2] ING, “ING Profile 4Q2017”, 31 January 2018, page 2, website ING (http://www.ing.com/web/file?uuid=c4a974e9-2bd9-4d93-afdd-6edb82d1845d&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=29753), viewed 23 January 2018.
[3] ING, “ING Group Annual Report 2016.”, page 3, available: https://www.ing.com/web/file?uuid=bbbb6628-52ea-4469-8232-2a0d0d60f099&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=39230&elementid=1880975, viewed 23 January 2018.
[4] ING, “ING Environmental And Social Risk Framework”, page 7, website ING (https://www.ing.com/web/file?uuid=5a9af88a-b6a3-4e8a-ae8d-d192e7f8d7c9&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=42010), viewed 23 January 2018.
[5] ING, written response to PAX dated 18 May 2015.
[6] ING, “ING Environmental And Social Risk Framework”, page 8, website ING (https://www.ing.com/web/file?uuid=5a9af88a-b6a3-4e8a-ae8d-d192e7f8d7c9&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=42010), viewed 23 January 2018; ING, written response to PAX dated 18 May 2015.
[7] ING, “Environmental and Social Risk Framework”, website ING (https://www.ing.com/web/file?uuid=5a9af88a-b6a3-4e8a-ae8d-d192e7f8d7c9&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=42010), viewed 23 January 2018; ING, written response to Profundo dated 27 May 2014.
[8] ING, “ING Environmental And Social Risk Framework”, page 18, available at: https://www.ing.com/web/file?uuid=5a9af88a-b6a3-4e8a-ae8d-d192e7f8d7c9&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=42010, viewed 23 January 2018; ING written response to PAX dated 17 August 2016.
[9] ING, written response to Profundo dated 27 May 2014.
Last updated March 2018