ING & supervision and Regulation
To strategise, develop and coordinate the company’s positions on important public affairs issues, ING is actively involved in public policy and regulatory developments in its relevant constituencies. It does so with the objective of enhancing (implementation of) financial regulation and supervision that support the interests of ING’s stakeholders.
The task is predominantly fulfilled by the company’s Public and Government Affairs department and involves, a.o., analysing impending legislation and policy developments and conducting business impact assessments, particularly at European and Dutch level. The team also advises ING’s businesses to develop strategic objectives and policy positions.
ING’s positions on various regulatory and policy developments
For detailed information on ING’s stance on various regulatory and supervisory issues, please refer to the ING Group Annual Report on pages 12-15
Code of conduct
ING is registered in the Transparency Register and therefore adheres to the code of conduct of the EU for organizations and self-employed individuals engaged in EU policy-making and policy implementation.
In the relations with the EU institutions and their Members, officials and other staff, ING shall adhere to the following code of conduct:
- always identify themselves by name and by the entity or entities they work for or represent; declare the interests, objectives or aims promoted and, where applicable, specify the clients or members whom they represent;
- not obtain or try to obtain information, or any decision, dishonestly, or by use of undue pressure or inappropriate behaviour;
- not claim any formal relationship with the EU or any of its institutions in their dealings with third parties, nor misrepresent the effect of registration in such a way as to mislead third parties or officials or other staff of the EU;
- ensure that, to the best of their knowledge, information which they provide upon registration and subsequently in the framework of their activities within the scope of the register is complete, up-to-date and not misleading;
- not sell to third parties copies of documents obtained from any EU institution;
- not induce Members of the EU institutions, officials or other staff of the EU, or assistants or trainees of those Members, to contravene the rules and standards of behaviour applicable to them;
- if employing former officials or other staff of the EU or assistants or trainees of Members of the EU institutions, respect the obligation of such employees to abide by the rules and confidentiality requirements which apply to them;
- observe any rules laid down on the rights and responsibilities of former Members of the European Parliament and the European Commission;
- inform whomever they represent of their obligations towards the EU institutions;
Individuals representing or working for entities which have registered with the European Parliament with a view to being issued with a personal, non-transferable badge affording access to the European Parliament’s premises shall:
- comply strictly with the provisions of Rule 9 of, and Annex X and the second paragraph of Article 2 of Annex I to, the European Parliament’s Rules of Procedure;
- satisfy themselves that any assistance provided in the context of Article 2 of Annex I to the European Parliament's Rules of Procedure is declared in the appropriate register;
- in order to avoid possible conflicts of interest, obtain the prior consent of the Member or Members of the European Parliament concerned as regards any contractual relationship with or employment of a Member's assistant, and subsequently declare this in the register.
Apart from the fact that ING is a signatory to the EU Transparency Register, ING public affairs professionals are, on a personal title, members of the Society of European Affairs Professionals SEAP.
SEAP advocates self-regulation as the most effective way of supervising public affairs professionals. The SEAP code of conduct is based upon this principle. The code itself lists the various ethical rules which its signatories must abide by. SEAP’s aim is to have a code that is clear and concise, setting out the general principles that govern our profession.
Within The Netherlands ING is registered in the lobbying register of the House of Representatives and is a member of the Dutch Association for Public Affairs.
ING’s contribution, as well as the contributions of other stakeholders, to the consultation of the committee on the structure of Dutch banks (“Wijffels-committee”) is to be found on a dedicated section (Dutch only) on the website of the Dutch State ”.
Recent Public Contributions
(some publications are only available in Dutch)
"ING contribution to public consultation regarding Dutch legislation of remuneration policies financial industry” (Dutch only) - ING Inbreng consultative wet beloningsbeleid financiele ondernemingen
"Letter to Dutch parliament with regard to round table on future of the banking sector" (Dutch only) - ING brief aan vaste commissie Financiën van de Tweede Kamer i.v.m. rondetafel kabinetsvisie bankensector
ING response to the EC Green paper on long term financing
ING feedback on the EBA-ESMA Consultation document on financial benchmarks
ING Letter Liikanen
ING response to ESMA draft Technical Standards for the Regulation on OTC Derivatives, CCPs and Trade Repositories
ING response to the EC Consultation on the Regulation of Indices
ING response to EC consultation on bank accounts
ING response to EC Green Paper on card, internet and e-payments
ING response to ESMA paper on non-cleared trades
ING publication on ring-fencing retail and investment banks