ING Bank N.V. (2025)

Applying the Equator Principles (EP)
As an Equator Principles Financial Institution (EPFI), we implement the EPs in our internal environmental and social policies, procedures and standards. We do not provide project finance or project-related corporate loans to clients that are unable, or choose not, to comply with the principles. All EP transactions are reviewed at least annually, at which time covenant compliance is typically affirmed.

The EP are embedded in ING’s ESR Framework, which is publicly available. Assessment and approval for any transaction potentially falling under the scope of EP requires involvement of the following three banking areas:

• Front Office:  The primary responsibility for the application of the ESR Framework lies with Front Office (FO) and deal FO departments originate transactions and have direct contact with the client or project sponsors. FO must evidence compliance with the applicable ESR sector policy to the satisfaction of the Approval Authority. FO is responsible for: verifying whether the client and transaction are in-scope of the ESR Framework; completing the ESR screening; applying mandatory evaluation as stipulated by the relevant ESR sector policy and/or Equator Principles; actively monitoring clients’ actions and timelines to assure compliance with the applicable ESR sector policy; acting on and monitoring client’s compliance with conditions.
• Risk Managers: Credit Risk Management (CRM) provides the 2nd Line of Defense control function for FO and as such verifies compliance of a transaction with the ESR Framework to the satisfaction of the Approval. The CRM function is performed by either the Local Risk Manager (LRM) or a Sector or Product Senior Credit Officer(SCO). In the context of EP, CRM provides control over Front Office activities and generally sign off on the environmental and social impacts for ’Low Risk’ or ‘Medium Risk’ EP deals, which refer to Category C projects or Category A and B in designated countries.
• Environmental and Social Risk (ESR): The ESR department must verify compliance with the applicable policy to the satisfaction of Approval.  The ESR department sits within risk management and is fully dedicated to assessing environmental and social impacts associated with ‘High Risk’ transactions, which in the context of EP generally refer to Category A and B projects in designated and non-designated countries. Negative advice from the ESR Desk can only be waived by ING’s highest Credit Committee or the Executive Board. In practice such waivers are exceptional.

As our risk assessment processes are decentralized, each front-office team must be highly familiar with ING’s Environmental and Social Risk framework and in particular, the Equator Principles 4 (EP4). Hence, ING makes significant investment in internal training programs to help front office and risk management staff in assessing the environmental and social risk under EP4. ING’s ESR team also provides training (both in-person and via webinars) to hundreds of colleagues around the world every year in risk, front-office, KYC and compliance teams, so that ESR knowledge, and knowledge on the Equator Principles, is built on and spread.  ING has incorporated both modules of the Equator Principles “e-Learning Tool” in our own internal learning platform.

ING remains an active member and strong supporter of the Equator Principles. ING was elected to the EP Steering Committee in 2022 for a minimum 2-year term and we remain active within the Equator Principles Association by participating as a member of several working groups, including those on social risks, climate change and scope – and co-leading the capacity building and training working group.

For further information please refer to:

ING Group Annual Report 2025
https://www.ing.com/Investors/Financial-performance/Annual-reports.htm

ING Environmental and Social Risk Framework
https://ing.com/sustainability/sustainable-business/environmental-and-social-risk

ING’s Sustainability Approach
https://www.ing.com/web/file?uuid=5e17fa01-ad5d-403a-9884-e61e18ab53ba&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=33981

ING’s 2025 Climate Report
https://ing.com/binaries/content/assets/documents/sustainability/climate-update-2025.pdf2025

ING’s 2022/2023 Human Rights Report
https://www.ing.com/Sustainability/Sustainable-business/Human-rights.htm