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. Governments have the duty to protect individuals against human rights abuses. The UN Guiding Principles for Business and Human Rights also outline the corporate responsibility to respect human rights. Beyond this, 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 people’s rights and procuring goods in a responsible manner.
As a bank, we make a substantial contribution to human rights as financier, employer, service provider 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
In ING’s Human Rights Review 2021/2022 we disclose the most severe human rights issues in our Retail Banking operations and provide updates on the management of our most severe human rights issues in our own operations and the client engagement tool. We disclose our progress, governance, policies, due diligence cases, engagements, and actual adverse impacts we’re linked to. We do this to create a platform for our stakeholders to reach us and to invite other banks on our journey to shape sector practice . In our 2020 update, we addressed the changing external landscape, our responses to Covid-19, and a tool for client engagement that was in its testing phase. In 2019, we focused on our role as a corporate lender through a pilot where we took a pre-emptive approach by engaging with 29 clients on human rights. In 2018 Human Rights Report, we disclosed our human rights management approach, our policies on human rights, the most severe human rights issues impacting our business, our human rights engagements, and our priorities.
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.
Everyone working at ING is expected to adhere to ING’s global code of conduct. It builds on our Orange Code – the values and behaviours that underpin our way of working – and is based on the policies and guidelines we follow in our daily business.
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).
In our 2018 Human Rights Report we found work stress and discrimination to be salient risks for ING. You can read more on how we manage these issues in our latest human rights disclosure.
Human rights and our customers
Financial health and inclusion are important to us. We have various local policies in place that aim to protect our customers from human rights risks such as discrimination, financial distress and the misuse of their data. In all our product development and sales activities we apply the ING Customer Golden Rules, which seek to put our customers’ best interests, protection and needs central. These rules apply to all our business lines and customer types and are embedded in ING’s product approval and review process.
We are proactive in making sure customers have access to banking products and services. In certain countries we have voice-activated ATMs that make it easier for people with a visual impairment to withdraw money and bank cards with a notch on top so they can insert them correctly. Customers with speech or hearing difficulties in some countries can do their phone banking via the national relay service or use a sign language service.
Human rights in our supply chain
We have implemented a global ‘know your supplier’ (KYS) process that helps us determine the level of social, environmental and financial risk associated with a supplier.
A completed KYS assessment is required for before supplier onboarding. Additionally, suppliers are screened against environmental, social and sustainability risk in the course of a supplier relationship. Suppliers falling in the enhanced due diligence category are required to agree to ING’s sustainability risk policies and confirm that they operate in line with the principles of the UN Global Compact. These principles encompass human rights, forced and child labour, fair labour conditions, environmental protection and anti-corruption.
Human rights and doing business
Environmental and social risks are an important factor when deciding whether to engage with clients and potential clients, as well as when deciding what to finance.
Our Environmental and Social Risk (ESR) policy framework guides us here. While these policies are global and apply to all customers and clients, it’s our corporate clients that often have more significant potential environmental and social impacts. These clients account for about 30% of our total lending portfolio.
Human rights are a key aspect of ING’s overall ESR framework. Our stance is outlined in a specific human rights policy, as well as in our policies for sectors known to be sensitive to human-rights related issues, including agriculture, mining and manufacturing.
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 projects, international standards like the Equator Principles (EP) add criteria that transactions and clients must meet. The EP are applied in project finance in countries without robust environmental and social governance, legislation systems and institutional capacity. In those projects we require clients to demonstrate that they, for example, 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 the environmental and social risks associated with the project.
Projects financed under the EP framework may also require the ‘free prior and inform consent’ (FPIC) of affected communities if the project has impacts 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 local communities.
Other types of financing that don’t fall under the 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 performance. When a client is involved in activities on our ESR framework’s exclusions 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 risk. For example, ING doesn’t engage clients based in countries with a track record of human rights violations, such as Sudan.
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 leaders in their sectors, as well as the projects we finance that advance sustainability. We call this business responsible finance. By focusing on these clients and projects, we strive for a healthy portfolio and contribute to a more sustainable economy.
A dedicated sustainable finance team drives and promotes sustainable business opportunities. Our Responsible Finance portfolio of deals includes deals with positive social and human rights impacts. 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 have an important role in facilitating 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 continues to advance its understanding 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. A UN Global Compact signatory since 2006, ING has committed to supporting the Sustainable Development Goals.
ING was a signatory and active member of the Dutch Banking Sector Agreement on Human Rights from 2016-2019. The agreement was concluded with all deliverables completed by the parties. The sector is working on a follow up responsible business conduct agreement, where a smart mix of implementation measures will be discussed and ING looks forward to using our leverage with others in this collective initiative.
Shift is a leading centre of expertise on the UN Guiding Principles for Business and Human Rights. In 2020, we joined its dedicated learning platforms, such as the Financial Institutions Practitioners Circle and Business Learning Programme.
See a full list of endorsements and memberships here