Materiality: focusing on what matters most

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To improve as an organisation we need to identify, understand and closely manage our performance on the most important topics for our stakeholders, balancing their interest whenever we make decisions.

ING has been regularly conducting a materiality analysis since 2011. This provides insights into trends, business risks and opportunities that influence our ability to create value.

The most recent materiality analysis process and results are disclosed in ING’s 2022 Annual Report and are subject to reasonable assurance by our non-financial auditor KPMG, the highest level of assurance for non-financial topics.

Overview of material topics and how we manage them

The topics with the highest priority for stakeholders and the biggest estimated impact on our business or on society appear in the visual below. All topics shown in the top right corner of the circle are considered material and high priority.

Our approach and performance on each material topic can be found in ING's 2022 Annual Report. The outcomes of our materiality analysis help us review our management approach and assess where we can improve.

2022 Materiality Matrix

Topic definition

# Topic Definition
1 Environmental and social due diligence Including social and environmental risks in our client screening and engagement to ensure that the companies we finance have a minimal negative social and/or environmental impact, for example in relation to human rights, biodiversity, climate change and tax.
2 Sustainable Finance Financing clients who are driving social and environmental progress, for example by financing climate-resilient, low-carbon and circular solutions.
3 Ethics & Compliance Ensuring safe, secure and compliant banking and countering financial economic crime (e.g., money laundering, bribery, corruption) by performing customer due diligence and monitoring transactions.
4 Risk management Using our integrated risk management framework to manage all relevant financial and non-financial risks, including but not limited to top and emerging risks such as pandemics, climate risks, financial economic crime and geopolitical risks.
5 Data privacy and security Protecting customers' confidential information and managing threats from cyber-attacks or malware and wrongful exploitation of private or official data.
6 Fair & transparent products Providing fair and transparent information about the products and services that we offer and supporting customers with the right knowledge and tools to make informed decisions.
7 Financial performance Being a financially healthy, stable, resilient, and competitive company.
8 Financial inclusion Ensuring accessibility and equality of opportunities to access financial services for all possible customers.
9 Diversity, inclusion and equity Creating an inclusive work culture with diverse teams, in which people can be themselves and are treated equally.
10 Customer experience Making banking personal, instant, seamless, relevant and accessible to enhance the customer experience.
11 Digitalization Developing digital products and technologies and creating end-to-end digitalized products and processes to better serve our clients.
12 Political (in)stability Adapting to political instability with a focus on ensuring the health & safety of our employees and ensuring continuous business delivery and operation.
13 Energy Transition The process of shifting the global energy system from fossil-fuel based energy production to low carbon and renewable energy production, in which we support our clients to make this.

How ING approached the materiality analysis in 2022

Every three years we carry out a more extensive materiality analysis to address new trends and changing stakeholder concerns and interests. This analysis was conducted in 2021 and included a stakeholder dialogue event and interviews with senior management, as well as internal and external surveys. In both the interview sessions and the surveys, the question was asked to our stakeholders to identify actual and potential, negative and positive impacts that ING has on the economy, environment and people. Among the internal and external stakeholder groups we consulted were Retail Banking customers, WB clients, investors, NGOs, regulators and employees, including senior managers. The outcomes of these materiality surveys were complemented by global peer, trend and regulatory analyses resulting in the material topics we intend to report on for the next period, in line with our three-year materiality cycle. These topics are reviewed and approved by the MBB.

The results of the 2022 materiality analysis, which built on our extensive analysis of last year, are reflected in our strategic business decisions and highlighted throughout this report. The most prominent themes this year include (but are not limited to): climate change ('energy transition', 'environmental and social due diligence' and 'sustainable finance'), 'ethics and compliance', 'data privacy and security', 'diversity, inclusion and equity' and 'digitalisation'.

Prioritisation of material topics comes from a materiality analysis and this list of material topics was our starting point for constructing the Annual Report 2022 governance. The topic ‘political (in)stability, currently number 21 on the list, was not fully assessed/ranked as we cannot claim to have an ‘inside-out’ impact. We are only impacted by it (customers and employees). As a result, we put it at the very end of the material topic list. Also new on the list, when compared to 2021, is the topic of ‘energy transition’, which corresponds with our sustainability strategy in which we aim to steer our clients to enable energy transition targets. All other material topics were already included in the 2021 matrix, but the order has changed.

Materiality process

Our global stakeholders

We serve customers in over 39 countries and have a great number of stakeholders, each with different expectations. We have a proactive stakeholder engagement approach. Read more on our integrated approach to stakeholder engagement.

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