Defence

As a major European bank, ING finances today's society. We support and meet funding needs of the defence industry – provided they are aimed at supporting and increasing the resilience of Europe.

It is our policy not to fund controversial weapons and we carefully screen defence industry companies that request financing or other banking services. In all cases we expect our clients to comply with laws and international agreements governing the defence industry.

Controversial weapons

ING does not seek to be involved in any way with the development, production, maintenance or trade of cluster munitions, anti-personnel mines, biological weapons or chemical weapons. We do not seek to provide any services whatsoever to companies that produce those weapons.

Nuclear weapons, depleted uranium and white phosphorus munitions

ING does not finance the development, production, maintenance or trade of nuclear weapons, depleted uranium and white phosphorus munitions. It is however possible that we finance other activities of companies involved with these specific weapons.

We carefully consider our engagements with these companies. When companies are involved in nuclear deterrence, we only finance their non-nuclear activities and only so when these companies are headquartered in a country whose government has signed the so-called ‘non-proliferation treaty’. This treaty’s objective is to prevent the proliferation of nuclear weapons and weapons technology; to promote cooperation on the peaceful uses of nuclear energy; and to further the goal of achieving nuclear disarmament and general and complete disarmament. We balance our resolve to not be involved in nuclear weapons with our role as a financier and investor in the economy.

Sensitive issues:

Dual-use goods

In some cases, we are asked to finance goods that can be used for either military or civilian purposes. As part of screening our engagements with clients in the defence industry, we ascertain if goods do indeed have a dual purpose.

We do this by following the ‘Wassenaar Arrangement’ on export controls for military goods. Participating countries seek to ensure that transfers of military-used goods don’t contribute to the development or enhancement of military capabilities that undermine those goals. The aim is also to prevent terrorists from acquiring military goods.

ING entities have controls in place within transaction due diligence to manage risks related to export trade controls and proliferation financing.

Corruption

To avoid financing transactions of military goods involving countries that are sensitive to corruption, we have thorough due diligence processes in place before we consider providing other financial services as well.

For example, we have an extensive country and territory risk list in place, which categorises countries into low, medium, high to ultra-high-risk. This list contains some 250 countries and territories and is used during on-boarding of customers as well as during ING’s ongoing ‘know your client’ process.

The combination of ongoing ‘know your client’ and transaction due diligence established a control framework aimed to mitigate the risk of doing business with certain parties that are considered to have a high(er) inherent level of corruption due to e.g. geography or political instability. More information is available in our FEC statement as well as ING’s annual report. ING’s Wolfsberg Questionnaire (i.e. the Correspondent Banking Due Diligence Questionnaire) is available on the SWIFT KYC Registry.