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 2019 Annual Report and subject to reasonable assurance, 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 matrix below. All topics shown in the top right corner of the chart are considered material and high priority.

Our approach and performance on each material topic can be found in ING's Annual Report 2019. The outcomes of our materiality analysis help us review our management approach and assess where we can improve. Please refer to our disclosures on management approach for material non-financial topics, available here

2019 Materiality

Topic definition

Letter Topic name Topic definition
a Customer privacy & information security Protecting customer and confidential information and ensuring information is treated with integrity and is available when needed
b IT systems & platforms Securing the stability of IT systems and platforms, such as payment services, internet banking, data centres and apps
c Innovation Embedding trends in product development, innovating business models
e Digitalisation & interconnectivity Transforming business activities around digital trends and technologies, increasing connectivity with third parties and enhancing functionalities via application programming interfaces (APIs)
f Culture, ethics & integrity Conducting business with the highest level of integrity and compliance with all applicable laws, regulations and standards, with the Orange Code and Orange Values as our foundation. ING has a zero-tolerance approach to bribery and corruption and will strive to detect any such in our business dealings.
g Cyber resilience Threats from cyber-attacks or malware and wrongful exploitation of private or official data
h Climate change Enacting effective measures to mitigate climate change and help businesses affected by climate change to adapt
i Usability & accessibility of our products Making banking personal, instant, seamless, relevant and accessible to enhance the customer experience
j Financial performance Being a financially healthy and stable company

How ING approached the materiality analysis in 2019

We conducted an extensive assessment back in 2018, consisting of global peer, media, trend and regulatory analyses, combined with surveys across seven external stakeholder groups and engagements with ING’s senior management and subject-matter experts. The process was aligned with the guidelines and standards of the Global Reporting Initiative (GRI) and the Sustainability Accounting Standards Board (SASB) and resulted in a list of material topics.

The 2018 materiality analysis outcomes served as the basis for our 2019 analysis. The core of 2019’s process was a validation using internal and external data sources while ensuring the principles of completeness, accuracy and relevance. The process included the following input:

  • Internal and external stakeholder perspectives
  • The results of an internal risk assessment conducted in 2019
  • ING’s Think Forward strategy
  • Industry trend reports from think-tanks and thought leaders
  • Regulatory developments

The aggregation of this input resulted in preliminary results that were validated in a peer and media analysis. The process received reasonable assurance from audit firm KPMG.

In 2018, we complemented our quantitative (survey-based) approach with data-driven analysis. We also integrated the non-financial materiality analysis process with similar analyses conducted by our Risk and Strategy functions and we included two dynamic elements – an assessment of a topic’s velocity and stage of development – to assess the maturity and speed of the topic’s development.

The materiality analysis process (PDF 0,09 MB) is reflected in the following flowchart.

Materiality analysis process

Our global stakeholders

We operate in over 40 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 here.

We engaged the following stakeholder groups in our 2018 materiality analysis:

  • wholesale clients from across ING markets
  • retail customers from the Netherlands, Belgium, Germany, Spain, Poland and Turkey
  • small and medium-sized enterprises (SME) and mid-corporate (MC) clients from the Netherlands, Belgium, Poland and Turkey
  • investors, including shareholders
  • civil society organisations
  • employees
  • government and public policy professionals
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