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Stakeholder engagement and dialogue

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ING recognises the importance of regular and meaningful engagement and dialogue with its many and diverse stakeholders. Our engagement approach is informed by the standards of the Global Reporting Initiative (GRI) and the Sustainability Accounting Standards Board (SASB), and aims to adhere to the best practice provision of section 1.1.5 of the Dutch Corporate Governance Code. We engage in dialogue in a risk-based manner, also taking into account the outcomes of our saliency assessment. In all the stakeholder dialogues we engage in, ING is committed to adhering to its relevant legal obligations relating to confidentiality.

Stakeholders

ING considers its stakeholders to be groups and individuals who, directly or indirectly, influence – or are, or may be, influenced by – the attainment of the Company’s objectives. These stakeholders encompass our employees , shareholders and other investors, suppliers, customers, labour unions, civil society organisations, political groups, regulators and policy-makers. Our stakeholder view also includes sustainable research and ratings agencies plus the peer banks and standard-setters we strive to collaborate with, as well as the think tanks, academics and others with potentially relevant knowledge that we seek to learn from.

These many different stakeholders all expect different things from us. When determining ING’s position and how we attempt to meet those different expectations, we weigh the interests of ING and all stakeholders involved and seek to strike the right balance between different and sometimes opposing viewpoints. In our engagement efforts we strive to earn the trust and support of our stakeholders, and in so doing aim to protect and strengthen our reputation.

The different groups of stakeholders we engage with are not static and may be adjusted depending on the topics of the dialogue and the development of those topics over time. Similarly, stakeholder dialogue is context-sensitive and the participants in such dialogues should be determined on a case-by-case basis depending on the topic(s). We therefore regularly review who we consider our stakeholders to be and our engagement approach towards them to ensure our policy remains relevant and effective in balancing the needs and expectations of ING and its many stakeholders.

Key and material topics

As a large financial institution, ING has a direct impact on the economy, environment and people, as well as an indirect impact through its lending and investment activities. We seek to engage on the key topics that matter to and have material impact on our stakeholders. Sustainability is a strategic priority for ING, and we strive to put it at the heart of what we do by embedding it in risk and business decision-making and processes. Our engagement and dialogue approach helps us align our business interests with the needs and expectations of relevant stakeholder groups. Our approach is based on internal policies such as our environmental and social risk (ESR) management framework, and we strive to comply with applicable laws and regulations, and apply international standards like the Equator Principles. We are open to feedback on our approach and the related topics, and consider these discussions as valuable input for strategy development, decision-making and our sustainability- and ESG-related publications, reporting and disclosures.

For materiality assessments we consult stakeholder groups in a qualitative and quantitative manner. An annual materiality assessment helps us identify which economic, social and environmental topics we should prioritise to further improve the way we do business and drive sustainable progress in society. Our material topics guide our strategic decision-making, stakeholder engagement and reporting.

Dialogue

We recognise that meaningful dialogue is dependent on clear, two-way communication in good faith. Our approach to stakeholder dialogue is characterised by continuous listening, collaboration and transparency. Our discussions take into account ING’s corporate tone-of-voice which is to be clear, easy and accessible, and not overly formal while always being polite.

Rather than just having one-off consultations on specific topics, we aim to have an ongoing dialogue about our role in society, our impact, our business conduct and other topics. This is done at both expert level within our group functions and business units and at senior management and Board level, using relevant methods and channels as explained below. For sustainability-related topics, within our Global Sustainability department our dedicated Stakeholder Engagement and Business Ethics teams act as expert advisors, decision-partners and action-takers (in collaboration with ING’s business experts) when engaging with internal and external stakeholders.

Our dialogue with stakeholders takes many forms and includes: day-to-day interaction and regular feedback sessions with customers on our products and services; organisational health surveys and other dialogue with colleagues; meetings with (potential) shareholders, other investors and industry analysts; and regular contact with regulatory bodies, policy makers and government agencies. We also engage via the partnerships and expert working groups we participate in (related to platforms like the UN Environmental Programme Finance Initiative - UNEP FI).

ING’s Dutch employee council consists of the central works council plus five divisional works councils (Staff, Retail and Business Banking, COO, Tech, Wholesale Banking). This employee council has a sustainability sub-committee, which in 2023 gathered input from employees on the sustainability-related topics that should receive ongoing attention from the works council. These topics, which include exploring how to integrate sustainability-related goals into ING's performance management process, were then discussed with senior management. Employee council members have also initiated an employee network in the Netherlands for colleagues with an interest in sustainability and ING’s approach to it. In the Netherlands, in addition, there is an ING young professionals network (YPN) that has a sustainability sounding-board, set up to provide advice on emerging sustainability topics from the perspective of ING’s future leaders. In all these cases – the sustainability committee of the employee council, the employee network, and the YPN – there is regular interaction with the Stakeholder Engagement team of ING’s Global Sustainability department.

The dialogue on the sustainability priority that’s part of our business strategy also takes place as part of regular (or dedicated) meetings between the ING Executive Board, Management Board Banking, and Supervisory Board. For more on our ESG governance approach, please see our 2023 Climate Report (from page 14) and our upcoming Annual Report (to be published 7 March 2024).

In addition, we have regular and ongoing discussions with national and global non-governmental organisations, and other pressure groups and activists. These stakeholder groups play an important role in society to keep sustainability at the forefront of people's minds. ING’s Business Ethics team has a role to explain what we're doing, why we're doing it, and the progress we're making, while concurrently learning from the external insights shared by our discussion partners. An example of the latter is our ongoing dialogue on ING’s climate action. As part of our dialogue we explain that our climate approach is based on facts and science, and that we focus our efforts on how ING can best translate climate facts into banking practice. We are also transparent about the dilemmas we face when acting on climate, as 'going green isn’t always black and white'. We seek to learn from stakeholders how to best balance the different interests affected under these dilemmas.

The ongoing dialogue with stakeholders can help to drive internal change at ING, including by enhancing our environmental and social risk (ESR) management policy and improving awareness of the wider impact of our business conduct. Equally, ING can drive change and contribute to standard-setting by sharing subject-matter expertise with external expert platforms and think tanks such as the RMI Center for Climate-Aligned Finance, and working groups related to bodies like UNEP FI and the Net-Zero Banking Alliance (NZBA).

We report on our stakeholder dialogue in our Annual Report.

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