Human rights

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 role. 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:

In our human rights report 2022/2023 we detail the reassessment of the most severe human rights issues with regards to our workforce and Wholesale Banking activities and our first assessment of salient human rights issues in our role as a procurer of goods and services. 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. 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.

Additionally, we also provide modern slavery statements in line with the UK Modern Slavery Act 2015. You can download the most recent statements - UK Modern Slavery Act statement 2023 and UK Modern Slavery Act statement 2022. Archive statements can be requested from sustainability@ing.com

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 good primary and secondary benefits and development opportunities. This creates an environment where our people not only do well but can also do good.

It is important for us to 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 harmful 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 most recent human rights report we found work stress, discrimination and harassment to be salient human right issues for ING. You can read more on how we manage these issues in our human rights report.

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 privacy breaches. 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

ING suppliers must go through our supplier qualification process – Know Your Supplier (KYS) – which helps us determine, among other things, the level of social, environmental and financial risk associated with a supplier. Employees conducting supplier due diligence are trained to apply internal policies and guidance. Suppliers that successfully complete the KYS process and attain ‘Qualified’ status have the potential to become an ING supplier. The KYS assessment is conducted based on external data information as well as information directly provided by the supplier that addresses questions on how they manage potential human rights impacts. The KYS assessment is periodically repeated for our supplier base.

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.

We are guided by our Environmental and Social Risk (ESR) policy framework, which we update regularly. We want the framework to reflect changing social norms and regulation relating to sustainability, and to challenge our own increasingly strong commitments on the topics of human rights and climate change.

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.

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 guide us.

When financing projects under the EP framework, 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, it is ING policy not to 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. 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.

Other involvement

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).

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.