Statement on Human Rights
Conflict, instability, displacement, discrimination, climate change—the world faces major social challenges around human development and human rights. These issues inspire global efforts to secure a truly sustainable and prosperous future for all.
Human rights are universal. This means that every person around the world deserves to be treated with dignity and have their interests considered equally. While governments have the duty to protect individuals against human rights abuses, businesses are increasingly recognising their own moral, legal, and commercial responsibility. The OECD Guidelines for Multinational Enterprises and the UN Guiding Principles for Business and Human Rights form the basis for what businesses should adhere to.
On the one hand, businesses can hinder human rights, as evidenced by reports around the world of unsafe working conditions, migrant worker exploitation, and harm done to communities. On the other hand, businesses can help advance human rights by offering access to decent work, creating higher living standards, protecting children’s rights and procuring goods in a responsible manner.
As a bank, we make a substantial contribution to human rights as financier, employer, taxpayer and driver of progress and prosperity . Our impact is on different levels:
- Our workplace
- Our supply chain
- How we do business and who we do business with
- Partnering and sharing knowledge
Human rights and the workplace
Our business centres around trust, as we can only maintain our stakeholders’ confidence and preserve our company’s reputation by acting with professionalism and integrity. This, and more, is all outlined in our Orange Code – our ING set of values and behaviours.
We value our employees and seek to be a good employer. We promote the personal and professional growth of our employees by providing excellent primary and secondary benefits and development opportunities. This creates an environment where our people not only do well but can also do good.
We provide a healthy and safe workplace where mutual respect is key and discrimination isn’t tolerated. Our whistleblower policy allows employees to safely and confidentially air any concerns, should they arise.
We involve employees when dealing with complex human resources policy issues, ensuring their point of view is taken into account. This also enhances communication between management and staff, and supports a culture of shared responsibility. The way employees are consulted depends on local legislation and culture.
Having a workforce that reflects the diversity of our customer base and a working environment in which a diverse workforce can feel comfortable being themselves are important priorities for ING. Our employees should be unafraid to voice different opinions.
The human rights we consider fundamental and universal for our workforce include the right to freedom of association, the right to collective bargaining, and freedom from discrimination based on race, colour, sex, religion, political opinion and national and social origin. ING supports eliminating all forms of forced labour and child labour.
ING has had a Human Rights Statement for employees since 2006, expressing our commitment to support international labour rights standards. More detail can be found in our detailed Human rights and the workplace statement (PDF 184KB).
ING is determined to make inroads into improving gender balance, which was recognised by our inclusion in Bloomberg’s first gender equality index in 2016. We launched a diversity manifesto in 2016 and developed a comprehensive action plan with senior leaders globally including specific activities for each country and business line.
This plan includes attendance at ‘unconscious bias’ workshops, gender equality in trainee programmes, more gender-mixed selection panels and having at least one woman shortlisted for senior positions. Promotion of flexi-working within the organisation is also beneficial for employees looking to balance work and family.
Human rights in our supply chain
ING spends billions of euros per year on procuring external goods and services. We can make a difference by making sure that money goes to suppliers that see sustainability the way we do—those that protect human rights, don’t use forced or child labour, don’t discriminate, and work against bribery and corruption. They must have solid governance in place and show they can act responsibly.
ING’s Procurement Sustainability Standards, based on the UN Global Compact Principles, are global and outline how we expect our suppliers to treat sustainability. We ask every supplier to commit to these standards before we sign a contractual agreement.
If a supplier meets our standards, we use an external specialist to further assess its sustainability performance. If we enter into agreement with a supplier and they breach our standards, they must take action to fix it or we’re entitled to terminate all agreements with them.
Human rights and doing business
Environmental and Social RiskHuman rights is an important factor when deciding whether to engage with clients and potential clients, as well as when deciding what to finance.
As a bank, our financing choices can help society transition to becoming more sustainable. Every single corporate client and every single transaction is assessed, monitored and evaluated against the requirements of ING’s Environmental and Social Risk (ESR) framework.
We want to ensure each one is compliant and limit any negative impact our business or our customers’ business may have on the environment and communities. This means that social issues and environmental impact are taken into account each and every time we make financing decisions.
Human rights are a key aspect of ING’s overall ESR framework. Our standpoint is also outlined in a specific human rights policy, as well as in our policies for specific sectors known to be sensitive to human-rights related issues, including agriculture, mining, and manufacturing, among others.
We’re guided by the standards established in the Universal Declaration of Human Rights; the eight Fundamental International Labour Organisation Conventions (‘ILO Conventions’); the Corporate Responsibility to Respect Human Rights under the UN Guiding Principles on Business and Human Rights; the OECD Guidelines for Multinational Enterprises and the UN Global Compact.
When financing specific projects, policies like the Equator Principles (EP) add criteria that transactions and clients must meet. For example, in those projects we require clients to demonstrate that they effectively and regularly engage with affected communities in a structured and culturally appropriate manner. These projects require clients to establish a ‘grievance mechanism’ to receive and help resolve concerns about that project’s environmental and social performance.
Projects financed under EP also trigger ‘free prior and inform consent’ (FPIC) if the project has impact on ancestral land or uses resources within an indigenous population's territory. This is a tool for preventing and managing tensions between a corporation and a community.
Other types of financing that don’t fall under EP are assessed under sector ESR policies, which also consider the environmental and social standards applied by the company as well as their track record.
In some cases we choose not to engage with potential clients, such as when severe human rights violations are found and the client’s performance isn’t satisfactory, and they aren’t willing to improve their environmental and social performance. When a client does an activity that’s on our ESR framework’s excluded activity list, ING won’t provide financial services for those activities.
Our lists of low-risk to ultra-high-risk countries help us identify country-specific human rights issues, among other things. For example, ING doesn’t engage with clients based in countries subject to continuous human rights violations, such as Sudan.
We believe that our ESR policies and the way we’ve embedded them into our business, specifically the human rights policy, contributes to protecting human rights worldwide.
From risk to opportunity
Besides mitigating risks related to human rights, we also pursue opportunities to advance them.
We measure the business we do with clients that are environmental and social trendsetters in their sectors, as well as the projects we finance that advance sustainability. We call this measurement sustainable transitions financed (STF). By focusing on these clients and projects, we strive for a healthy portfolio and contribute to a more sustainable economy.
Part of our STF business is carried out by our Sustainable Finance team, which drives and promotes sustainable business opportunities within ING. We recently expanded our approach to also include social impact (as well as environmental impact) when determining whether a transaction is sustainable. The themes to identify positive social impact are aligned with the Sustainable Development Goals, to ensure ING is contributing to the world’s most critical challenges.
Partnering and sharing knowledge on human rights
Banks in general have an important role in helping to effect positive change for society. We at ING know we can’t do it alone, so we engage with clients, business partners, financial institutions, government organisations and other stakeholders. Our goal is ultimately to advance our collective thinking—and actions—on issues including human rights.
ING and the Thun Group
ING is a member of the Thun Group of Banks. Named after the Swiss city it meets in, the Thun Group is an informal group that’s been discussing the meaning of the UN’s Protect, Respect and Remedy framework and the UN Guiding Principles on Business and Human Rights, both in regards to banks.
The Group published a discussion paper in January 2017 on banks’ due diligence in terms of potential human rights violations. This builds on the first discussion paper (PDF) and group statement (PDF) published in 2013 on the implications of the guiding principles for banks in the areas of retail and private banking; corporate and investment banking; and asset management. The Group has had various discussions with stakeholders such as NGO’s and human rights specialist John Ruggie about the January version and after thorough consideration decided to revise and republish their January discussion paper.
The Group continues discussions on how to effectively embed human rights due diligence in the financial sector.
OECD Advisory Group
In 2015, ING was formally invited to participate in the Advisory Group to the OECD project on ‘Responsible Business Conduct in the Financial Sector’. The group is formed by 40 individuals representing governments, industry players, market makers (e.g. Nasdaq), international organisations, trade unions and NGOs.
As part of this advisory group we provide guidance for the correct interpretation and application of the OECD guidelines for the financial industry (and the UN Guiding Principles referred to within the guidelines).
Documents issued by the OECD are applied globally and therefore are critical to move the industry collectively in the same direction. This is the second time we’ve been asked to participate in the OECD Advisory Group. The first time was in 2013 when we supported the OECD in developing the ‘Environmental and Social Risk Due Diligence in the Financial Sector’ (PDF), which was funded by the Dutch government.
ING has also joined the Business and Industry Advisory Committee (BIAC), which formally represents all business associations at the OECD. BIAC is providing feedback on the new developments for the ‘Due Diligence Guidance for Responsible Business Conduct’.
This is particularly important, as it gives ING the opportunity to hear other corporate views, opportunities and concerns related to applying the OECD Guidelines for Multinational Enterprises in all sectors.
ING is part of the steering committee for the Equator Principles, a framework adopted by financial institutions to assess and manage environmental and social risk in project (related corporate) finance.
We are also an active member of the EP Social Working Group, which discusses social and human rights challenges when applying the EP by member associates (currently more than 80 financial institutions).
The United Nations plays a key role in encouraging sustainable progress. ING has partnered with the UN since we signed the UN Global Compact in 2006. We were committed to the former Millennium Development Goals and are now also supporting the current Sustainable Development Goals.
Respecting and supporting children’s rights requires business to both prevent harm as well as advocate for children’s interests. The Children’s Rights and Business Principles (CRBPs) were developed by UNICEF, Save the Children and the United Nations Global Compact in close cooperation with the business community and children. ING was the only bank involved in the consultation process and hosted the launch of the Children’s Rights & Business Principles (CRBPs) (PDF 1,104 KB) in the Netherlands.
ING and UNICEF have a long history of working together to empower the next generation. There are 1.2 billion adolescents (aged 10–19) worldwide, nearly 90 percent of which live in developing countries. With the Power for Youth programme, ING and UNICEF aim to give these kids the social and financial skills they need to improve their future and the future of those around them.
See a full list of endorsements and memberships here (scroll down).
We also share our knowledge and experience by conducting research and writing reports with a human rights angle. One example is our extensive research paper on microfinance titled ‘A Billion to Gain’, which was developed together with the Dutch sector representative NpM, Platform for Inclusive Finance.
About 2.5 billion people worldwide have no access to financial services. Of this group, 1.2 billion live on less than one euro per day. Microfinance provides an important contribution to poverty alleviation by setting up financial structures and improving accessibility.
Some 250 million people worldwide currently make use of microfinance. Our research shows that access to financial services has a positive effect on the lives of the poor; and helps women feel more empowered in decision-making both at home and outside the household.
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