ING Groep NV

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	ING Groep NV provides a relatively detailed window into its climate-policy advocacy. The bank names several concrete legislative files it works on – including the EU Taxonomy, the EU sustainable-finance transparency rules (SFDR, CSRD and CSDDD), the EU Green Bond Standard and the Energy Performance of Buildings Directive – making clear which public-policy measures it seeks to influence. It also describes how it engages, noting that it “responds to public consultations from the European Commission either individually or via trade associations ING is a member of,” and that it speaks with “banking regulators, supervisors, officials and politicians – as well as NGOs, industry associations, think tanks, academics and our stakeholders.” Additional examples, such as signing the Dutch Climate Agreement in the presence of the Dutch Minister of Finance and preparing proposals for lawmakers drafting national climate legislation, show the use of more than one direct mechanism even if most are outlined only briefly. On substance, ING sets out a series of specific outcomes it is pressing for, including phasing out fossil-fuel subsidies, introducing CO₂ levies for maritime transport, tightening regulation of sustainable carbon sources for the chemicals sector, smoothing permitting for carbon-capture and storage projects, and creating incentives to increase aluminium recycling. Together, these disclosures demonstrate strong transparency on the policies it lobbies and the changes it wants to see, though descriptions of the full range of engagement methods remain less comprehensive.	3

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	ING discloses a general process for ensuring its external public policy advocacy aligns with its climate commitments, stating that “Regular internal alignment with key internal stakeholders and senior management consultations ensures that our external engagement activities is consistent with our climate commitments and/or climate transition plan” and that “in developing ING Group’s external advocacy, we seek to align our business and our strategy with the expectations of our stakeholders and society as a whole.” However, beyond noting that sustainability and climate topics are “a regular item on the Management Board Banking’s agenda” and that an “ESG Sounding Board” guides ESG strategy development, the company does not identify a specific individual or formal body responsible for reviewing its lobbying alignment, nor does it disclose monitoring procedures for indirect engagement through industry associations. We found no evidence of a dedicated climate-focused lobbying audit or criteria for reassessing association memberships whose positions might conflict with ING’s climate goals.	2