ING RSE Reporte 2009

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Corporate Responsibility Report 2009

ING in Society


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ING Group at a glance

75/100ING scores 75 out o 100 in theDow Jones Sustainability Indexscoring structure

47,765mTotal income

It is our mission to help our customersmanage their fnancial uture. We have

more than an economic role to ulfl insociety and realise that how we do businesscan have a direct eect on the world aroundus. We thereore take into account a rangeo social, ethical and environmentalconsiderations. We want to do our part inpreserving our planet and its fnite resources

or generations to come. Together withpartnering organisations, we can invest ina better uture or people and communitiesaround the world.

Our our key pillars

In our ambition to be both a responsible company and a good

corporate citizen, we have identied our key ocus areas in whichresponsible behaviour should be refected at all times.

We oster an open, sae, inclusiveand stimulating working environmentor our employees. We endeavour torespect human rights in everythingwe do.

We provide high-quality, easy-to-access and understand nancialproducts and services that meet theexpectations o our customers,while doing no harm to people orthe environment.

We conduct our business in sucha way that negative impact on theenvironment is avoided and minimisedas much as possible and look or waysto stimulate sustainable innovation.

EnvironmentPeopleBusiness

Through our community programmeswe want to make a positivecontribution to society. Our globalemployee programme, ING Chancesor Children, aims to give children achance to secure a better uture.

Community


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100%ING is 100% carbon neutraland has been since 2007

107,575Number o children providedwith access to education through theING Chances or Children programme

107,000Number o people employedby ING Group

12.8%o our ING ManagementCouncil consists o women

+50Number o regions andcountries around the worldwith ING oces

2,524mSustainable assets under management

Where we are and what we doING is a global institution o Dutch origin, oering banking,investments, lie insurance and retirement services, to meet the

needs o a broad customer base. We describe our nancial andeconomic perormance (along with other inormation about ourcorporate strategy, governance and management remuneration)in more detail in our Annual Report.Please fnd our reports online at www.ing.com


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Report suiteThis report summarises our corporate responsibility

perormance during 2009. It is intended or

stakeholders with a particular interest in sustainability.

It looks at the main non-fnancial issues we have been

dealing with during the year, our ambition and

strategy, the viewpoints o some o our stakeholders

and the actions we have taken around the world, as

well as some key perormance data.

For a uller picture please visit the ING or Something

Better website, where you can fnd additional

inormation based on the G3 Sustainability Reporting

Guidelines o the Global Reporting Initiative (GRI) and

where we reer to the Millennium Development Goals

and the principles o the UN Global Compact.

www.ingorsomethingbetter.com/report

We need your opinionto take actionHow do we meet current and growing energy needs

while responding to the threat o climate change?

What would you do?

Work to adapt to the impacts o climate change

Increase investment in renewable energy

Increase investment in energy efciency

Mitigate the impacts o climate change by

planting trees

Have your say at:www.ingorsomethingbetter.com/poll


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01Corporate Responsibility Report 2009

Contents02 CEO Statement

04 ING Business Principles

06 Our strategy

08 Our our pillars

10 Business

22 People

30 Community

38 Environment

46 KPIs

47 Assurance report

48 Governance and compliance

49 Perormance data

55 Our approach to reporting

As a nancial services company, we enable economic andsocial change that infuences many peoples lives. That iswhy we want to be both protable and just. We can only

do well by doing right or all our stakeholders, and by notdamaging but strengthening the world around us. Ourbusiness revolves around people and trust. We take theresponsibility o being entrusted with other peoples moneyvery seriously; we listen to the needs, goals and expectations

o our customers and take notice when they tell us what wecan do better or dierently. It is our responsibility to learn,respond and be open and clear about what we do. In thisreport we will give you some examples o actions we havetaken in the past year, as well as how we have perormed in

some important areas.


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Corporate Responsibility Report 2009 03

2010 will be a year o transition as we worktowards the operational separation o our bankingand insurance companies, and prepare them ororging their own utures. We will continue toinvest in the enhancement o the nancialcapability o consumers o nancial services ingeneral and our own customers in particular. Wewant to improve the engagement o ouremployees, and we want to deliver on our targetto appoint more women in senior positions.

Our people were aected by the strategicdecisions we took in 2009, and they deserve agreat compliment or the way they have respondedto the changes that were necessary. Their eortswill propel us orward again in 2010. On behal othe Executive and Management Boards, I want tothank them deeply or their condence, support,commitment and dedication.

Moving orward, our goal remains to be acompany that takes its responsibilities towardssociety seriously, is easier to deal with orcustomers, motivational or employees andpredictable or shareholders. Ater all, our licenceto operate comes rom the trust our stakeholdershave in us.

Jan H.M. Hommenchairman o the Executive Board

institutions nance and investment decisions oncontroversial weapons. This led to an extension othe scope o our Deence Policy in 2009.

Environmental protection also remains one o ourpriority areas going orward. To ocus greaterattention on the nancing o, and investment in,sustainable energy, we are evaluating our portolioand assessing opportunities. One o our ambitionsor 2010 is to stimulate sustainable

entrepreneurship and urther increase ourportolio o green products and services.

We are integrating sustainability into the personalaccountability and perormance objectives o oursenior management. Also, we are in the processo developing a new leadership developmentprogramme with the aim o increasing theinvolvement o ING leaders in our global society.

As part o our eorts in the community, I amproud to say that the 2009 Global Challenge,an annual initiative eaturing employeevolunteering and undraising initiatives or ourING Chances or Children programme, was againa resounding success. Our employees collectedunds or children and education-related projectsand we saw a record participation o 16% o ourglobal workorce.

Our licence to operate comesrom the trust our stakeholdershave in us.


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06

Our strategy

Our strategy

Our vision on corporate responsibilityWe believe that we best contribute to societyby being good at what we do, by takingresponsibility or the impact our products andservices have on the world around us, and byinvesting in positive change.

It is our ambition to be a responsible nancialservice provider that oers high quality productsand services that meet the needs and expectationso our customers. We aim to do no harm.Thereore we have a clear vision on ethical, socialand environmental issues, or both our bankingand insurance operations. These are in line withinternational standards, such as the UniversalDeclaration o Human Rights and the principles othe UN Global Compact. Our Business Principlesand Environmental and Social Risk Policy

Framework help us avoid involvement in illegal,harmul or unethical practices.

Furthermore, we want to play our role inaddressing pressing social and environmentalissues, both in the communities in which weoperate and in upcoming markets. That is why weocus on developing products and services thathave sustainability at their core. Our communityinvestment initiatives ocus on promoting

(nancial) education and inclusion, and preservingthe environment. Through our global charityprogramme, ING Chances or Children, and byworking together with partners like UNICEF, wehope to give children a real chance o securing abetter uture by providing them with qualityeducation and other basic needs.

It is our conviction that to be a successulcompany, our business decisions must be in linewith the expectations and interests o ourstakeholders. To monitor global issues, understandsensitivities and receive eedback on the way weoperate, we engage with our stakeholders in anopen and honest dialogue and adapt our policies

when necessary. We urther believe that actingresponsibly results in better and morecomprehensive risk management, a higher degreeo employee pride and new business opportunities.

Setting goals and measuring perormanceWe have been tracking and monitoring oursustainability perormance since 1995. This hashelped us to continuously improve our track record.

ING has ormulated corporate responsibility

ambitions and priorities, combined with along-term plan and concrete targets. Thesetargets are also part o the perormance objectiveso our Executive and Management Boards. A ulloverview o our ambitions and targets is set outon pages 8 and 9 o this report.


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In 2009, we took an even more active approach toour stakeholder engagement activities. It was a

challenging year or nancial markets and or ING.Thereore we invited policymakers, investors,regulators, journalists, non-governmentalorganisations, academics and private andcorporate clients to meet with our CEO and seniormanagement. At this meeting, an open debatetook place about ING and the responsibility wehave in society.

The success o the dialogue has encouraged us tointensiy this process during 2010 and similar

meetings have taken place since. We have alsoincluded stakeholder voices in this report.

Stakeholder engagementINGs licence to operate relies on our stakeholders:

our customers, employees, shareholders, andbusiness partners, as well as governments,non-governmental organisations (NGOs) andsociety at large.

For us, stakeholder engagement is not merely amatter o accepting criticism or positive eedback:it is about acknowledging the important signallingand inormative unction our stakeholders have,proactively engaging with them and maintainingan open and honest dialogue. Such dialogue helpsus to understand sensitivities, prioritise issues, takeappropriate action and to make and/or adapt ourstrategy or policies where necessary.

For more inormation aboutstakeholder engagement,including a list o the issueswe have discussed with NGOs,please visit our websitewww.ingorsomethingbetter.com/stakeholders

We continuously keeptrack o the needs

and expectations oour stakeholders.

ING management in dialogue with stakeholders during one o the stakeholder discussion sessions.


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08 Our our pillars

Business We treat our customersairly

We do business responsibly We oer our customerssustainable products

Ambition

Instil a true customer eedback culture andmake inance easier

Become a leader in the area o environmentaland social risk management in the Europeanbanking sector

Become a preerred provider or sustainablebanking products and services among themainstream international inancial companies

Focus areas

Improvecustomersatisfactionthroughthetransactional net promoter score

Implementanewprogrammearoundproduct

and sales suitability Helpconsumerstounderstandtheirfinances

better through inancial education initiatives

EnvironmentalandSocialRiskPoliciestocoverall business lines

Globalimplementationandemployee

awareness o our Business Principles

Developsustainableproductsandservices

Improvemarketingofexistingsustainableproducts and services

Progress in 2009

Welaunchedapilotsystem,thetransactionalnet promoter score, in two o our businessesto measure what customers think o theproducts and services we oer them

WelaunchedarenewedversionofINGsBusiness Principles

Wehaveextendedthescopeofourpolicyoncontroversial weapons

Sustainableassetsundermanagementhaveincreased by 10% compared to 2008

Wehavedevelopedseveralnewsustainableproducts, such as the ING Green Focus Fund

Goals or 2010 and beyond

Rolloutthetransactionalnetpromoterscorein 15 countries (all other retail markets in 2011)

Developfinancialeducationvideos(availableon www.ing.com)

10%increaseinscoreontheBusinessPrinciples in the global employee engagementsurvey (absolute score o 90 in 2013)

Carryoutanenvironmentalandsocialriskscan on a yearly basis

DowJonesSustainabilityIndex:becomea Sector Leader in inancial services

5%growthofsustainableassetsundermanagement compared to total assets undermanagement (15% in 2013)

Developandmarketnewsustainableproductsor services

Our our pillars


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People Community Environment

We treat our employees airly We are active in the community We manage our impact onthe environment

Ambition

Be an employer o choice Outstanding reputation in communitydevelopment in terms o results, partnershipsand engagement

Become a leader in green procurement amonginancial institutions

Focus areas

Developandalignpeoplestrategiesforthebanking and insurance organisations

Increasethenumberofwomenin

leadership positions Implementthenewremunerationpolicyand

perormance management approach

Rolloutourcommunityinvestmentprogrammes in the area o educationand environment

Increaseemployeeinvolvementincommunityinvestment programmes

Increasegreenenergypurchase

Setspecifictargetsinenergyefficiencymeasures or business units to implement

Continuetodevelopaglobalenvironmentalprogramme or employees

Progress in 2009

ThepercentageofwomenintheINGManagement Council has increased rom11.8% to 12.8%

71%ofouremployeesareproudtoworkor ING

16.2%ofINGemployeesparticipatedintheING Global Challenge

INGChancesforChildrenprovided107,575children with access to education

INGpurchased330,582kWhofgreenelectricity, 1% less than in 2008. This is 62%o our total energy use

Goals or 2010 and beyond

15%womenintheINGManagementCouncil (33% in 2015)

IncreaseparticipationofemployeesintheGlobal Challenge to 20% (30% in 2013)

MonetaryvalueofINGsvoluntarysocialcontributions to equal the minimum o onechild provided with access to education perING employee through our UNICEFpartnership (30 EUR per child)

25%ofthebusinessunitstosettargetsinrelation to paper usage, electricity usage andbusiness travel

Developaprogrammetostimulatesustainableentrepreneurship


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10

Issue:Lack o trust innancial services

Customer view

Financial products are socomplicated. Can I still trust thenancial sec tor?

ING responseBeing entrusted with yourmoney is a responsibilitywe take seriously. We arecommitted to regaining thetrust o our customers bykeeping our promises, by

answering your questionsopenly and proessionally,and by acting with the highestdegree o integrity.

Introduction

We aim to earn our customers trust by delivering nancial productsand services as they would like us to: with exemplary service andconvenience at attractive prices. Our customers expect us to be therewhen needed, to give them a proper overview o their nancialsituation, respond to their questions quickly, explain our productsand services clearly and simply, provide them with objective andproessional advice and invest their money responsibly. We willcontinue to build our brand around a universal ideal o deliveringa great customer experience.

Business

More inormation www.ingorsomethingbetter.com/customers

Pauline EnthovenRetail customer,the Netherlands


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Corporate Responsibility Report 2009 11Corporate Responsibility Report 2009

More inormation about customer care go to page 13

Action:Building trustthrough dialogue

Stakeholder view

Its not just about transparencyon what the products are andhow they work, it is helpingclients to develop knowledgeabout themselves and theircircumstances so that theright products are sold tothe right people.

ING actions

Wesupportedcustomerswhowerebadlyaffectedbythenancial crisis. Weinvitedcustomersandclientstoaskourseniormanagement

their questions about the economic situation and its implications orthem personally.

Weenteredintodialoguewithdifferentstakeholdergroupsonhowwe can better serve our customers.

Weprovidemoreinformationonnancialmattersonwww.ing.com/ezonomics

WeaimtoimproveourcustomerservicebypilotinganITapproachwhere customers score us immediately ater a transaction.

Weinvestindevelopingtoolstomakenanceeasiertounderstand.

Henritte PrastProessor oPersonal Finance,Tilburg University


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12 Business continued

Business

Responsible and airproducts and servicesOur Business Principles guide us in our everydaybehaviour and business decisions.

Clarity about nancial strength, business models and products isessential, as is a clear customer ocus and transparency about theway we operate. We are now more than ever committed to providingsuch clarity and proessionalism.

Business perormance is not just about setting demanding targets.Sometimes it means reraining rom a certain business activity ortransaction that may confict with our policies or our ethicalstandards. It involves treating our customers well and airly, oeringthem accessible and easy-to-understand products and services.


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ING introduced a new corporate programmedesigned to stabilise, simpliy and strengthen ourcompany. A vital part o this is about what mattersmost to our customers, since our ultimate successdepends on them.

In light o this strategy to put the customer rst, wehave started several initiatives, such as theintroduction o the transactional net promoter scoreand a global project around product suitability. Thispath aims to create a corporate culture with the rightbalance between the interests o our customers andthose o other stakeholders. Questions addressedinclude or example: "Do INGs products and salesprocesses consistently meet the nancial needs o ourcustomers?" and "Do we oer air value to ourcustomers?"

Listening to customersDuring 2009, we launched a pilot system - thetransactional net promoter score (NPS) - in several oour businesses to measure what customers think othe products and services we oer them. The NPSasks customers to score their experience with INGimmediately ater they complete a transaction. Thiseedback helps us not only to solve individualcustomer problems directly, but also to make generalservice and product improvements. The success o thepilots has convinced us to start implementing thissystem in every ING market in the coming years.

Perormance highlight

69.1%Our customer satisaction level,measured using the ACSI approach

and modied or nancial servicesmarkets, is 69.1% in 2009 down0.5% rom last year

Customers


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Customer careOver the last two years we have worked hard behindthe scenes on a global customer suitabilityprogramme that strengthens the principle that INGconsistently puts customers rst. The programme isnot only principle-based but also incorporates bothrecent regulatory developments and best practicesrom ING units across the globe. It is an excellentexample o "Think global and act local". Thisprogramme will be continued in 2010.

We have supported customers who were badlyaected by the nancial crisis. Our Korean business,or example, reunded the premium payments o newlie insurance customers i they lost their job withinthe rst year. ING Netherlands allowed customerswho were struggling to make their monthly mortgagepayments to postpone payment, and provided themwith budgeting support.

Financial basicsIn light o the customers need or trustworthy andeasy-to-understand inormation and advice, we havebeen strengthening our capabilities in educating andempowering our clients on nancial basics. In theNetherlands, ING organised several nancialinormation evenings or customer questions.US websites like www.ingorlie.com and www.RetireMyWay.com provided guidance on nancial

decision making. ING also launched ezonomics.com,a website that makes day-to-day economic newsrelevant and easier to understand or everydayconsumers. Recently a series o animated videos waslaunched that explains the very basics o saving,investing, lie insurance, retirement planning andhome loans.

Another example is the ING Romanian nancialeducation initiative launched in 2009 in conjunction

with the Romanian nancial regulator. It is calledDecisions or Lie. The aim was to encourage a broadrange o consumers to get proper lie assurance. Themain ocus o the initiative is a series o 16 short TVepisodes on key lie insurance topics, supported byadditional materials. Over a million viewers tuned in orthe shows. The initiative will be expanded in 2010, tocover more media and educational support materials.

Apart rom our customers, there are many othergroups and communities that would benet romenhanced levels o nancial literacy. It is part o oursocial commitment to contribute to this specicallythrough youth education and promoting nancialliteracy in our home markets. See the Communitychapter or more inormation on these initiatives.

For more inormation about ourlocal fnancial education initiatives,please visitwww.ingorsomethingbetter.com/local

For more inormation and dataabout customer satisaction,customer complaints, consumerprotection and preventing social

exclusion, please visitwww.ingorsomethingbetter.com/customers


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15Corporate Responsibility Report 2009Corporate Responsibility Report 2009 15

An interview with:Henritte PrastProessor o Personal FinanceWe talked to Henritte Prast, Proessor o Personal Finance,University o Tilburg and member o the Scientic Council orGovernment Policy, about the approach o nancial institutionstowards customers.

What can ING do to improve its relations

with customers?I ING wants to help its customers, and in the end help itsel, itshould speak to them less in terms o risk and more in terms oimpact. Risk is an abstract concept to most people, and peoplegenerally think "it will never happen to me", or overestimatethemselves. They oten do not understand that the impact o atiny risk can still be huge. ING should try to make clear to itsclients not "What risk do you want to take?" but "What do younever want to lose?", and then base its advice and products onthis understanding. This goes beyond compliance with laws onnancial supervision as these oten only speak about risk.

So transparent communication on products is needed?Transparency alone is not the answer; we cant expect customersto become nancial experts. We dont expect people tounderstand how a washing machine, a car or medical technologyworks and the same should apply to nancial products. So its not

just about transparency in what the products are and how theywork, its helping clients to develop knowledge about themselvesand their circumstances so that they can choose the right products.

What should the approach o nancial services towards

nancial education be?In my opinion the issues are not usually related to a lack oinormation but to temptation. It should be less about educationin nancial products and more about changing the mindset andmaking people aware o things they never want to give up.

With all the products, technology and approaches to nancialproducts it is too much to teach everyone about all nancialproducts. Most o the rules on nancial advice are ocused onproduct inormation suggesting it is just about the product andits eatures and not about the match between the product and

the individual. For example, new pair o quality Italian high heelsmay be a desirable option or a middle aged woman, but thesame shoes or an older woman may not be so appropriate.


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Finance and investing policy

It is our business and responsibility to provide

great nancial products and services. As acommercial enterprise, we also want to make aprot. But the end does not justiy the means, justas doing well does not preclude doing good.Customers and other stakeholders are increasinglyinterested in the way we invest their and ourmoney. We acknowledge their need or moreinsight into how we work and reassurance that weare doing a good job. Which is why we haveadopted environmental and social risk policies that

help us make sound investment decisions.

We have a vision or how we approach businessethics, the environment, people and society. Byengaging in continuous dialogue with ourstakeholders we constantly evaluate our policiesand adjust them where necessary.

One area where we started to address changingstakeholder demands and expectations is ourDeence Policy.

WehaveextendedthescopeoftheDefencePolicy to include all our business activities:not just lending and proprietary assets but alsoING managed unds (index trackers excluded).

Wewillnotnancecompaniesthatareinvolvedin the production, maintenance or trade oanti-personnel landmines, cluster munitions,depleted uranium ammunition, biological orchemical weapons. ING will not invest itsproprietary assets in these companies and will,with the exception o discretionary mandatesand trackers (ETFs), and wherever legally

possible and independently enorceable by ING,ensure customer unds are not placed in suchcompanies through ING managed unds.

Wewillnotdobusinesswithcompanieswhenthere is evidence that they deliver arms tocountries that are under a weapons embargoor to terrorists and other non-governmentalarmed groups.

INGdoesnotnancethetradeofweaponstocountries where there is a clear risk that the

weapons can be used or internal repression,serious human rights violations or or provokingor aggravating tensions or confict.

Besides our Deence Policy, we have a wide rangeo other policies concerning the environmental andsocial aspects o our business engagements. Thesepolicies are integral to INGs mainstream nancialrisk management and compliance practices. Beorewe approve a transaction or engage with a client,we careully evaluate the environmental and socialrisks against our policies, which set benchmarks bylocal laws and regulations as well as internationaland social standards.

In 2009, we broadened the scope o ourenvironmental and social risk policies rom justCommercial Banking activities to include all o ourbusiness lines. To do this, we created a RestrictiveList o companies that are considered to be theworst oenders in all sensitive areas. These

companies are excluded rom all ING services.

For an overview o our

fnance and investmentpolicies, please visitwww.ingorsomethingbetter.com/fnancepolicies

Read more about howwe manage environmentaland social risks atwww.ingorsomethingbetter.com/esr

16


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Corporate Responsibility Review 2009 17

Governance process orenvironmental and social risk


Startpotentialengagement

Legal andComplianceRisk Filter

FinancialRisk Filter

Non-FinancialRisk Filter

- ING Business Principles- Natural resources- Forestry- Deence- Animal testing- etc

Assessment

Go orGo + conditions

No go

More inormationrequired

Nogo

Disengage

Go

Proceed


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Oxam is impressedwith INGs newDeence Policy.However, westill think someimprovementscould be made.

An interview with:

Peter RasOxam NovibSince its oundation in 1956,Oxam Novib has ought, romits base in the Netherlands, or a

just world without poverty. As amember o Oxam Internationalits reach is magnied within aconederation o 14 like-minded

organisations working togetherand with partners and alliesaround the world to bring aboutlasting change.

Oxam Novib has been in dialogue withING or a couple o years now. How wouldyou characterise the relationship?Most o the time, we nd engagement with ING tobe easy. For example, we had discussions aboutINGs Deence Policy, which stretched ourrelationship at times. But we are both pragmaticand understand that this is part o the game andthe dierent responsibilities we have. Oxam isimpressed with INGs new Deence Policy, launchedin September 2009. ING now excludes investmentsin companies selling arms to countries on ocial

(e.g. EU and UN) embargoes. And, not only directinvestments, but also third party investments arescreened. We dont see many banks doing this.However, we still think some improvements couldbe made, and we hope to discuss these issuesurther with ING.

Do you think ING is missing any majorissues within its approach to sustainability?In general, Im not negative about ING at all.Internationally, ING is doing quite a good job,

particularly in several sectors and policies. Impositive about the work done on human rights andlabour rights, including human rights impact

assessments. But ING could do more on its climatepolicy. One o its main priorities should be to avoidinvestments in opencast mining and coal mining,which contributes to CO2.

Another issue is the implementation oenvironmental and social risk policies. We nd itdicult to get inormation on how ING implementsthese polices. We would like to see, or example,how labour rights policies are implemented inthe garments industry. We understand INGwill never share client inormation but, in acondential meeting, Oxam would like toreceive generic inormation.

How do you rate sustainability in thenance sector as a whole?Overall theres a lack o vision and ambition.We have repeatedly told ING and other nancialinstitutions that there is an urgent need or astrong sustainability agenda because o the impacto climate change and the nancial crisis. We eelnancial institutions are at least partly responsibleor the 70 to 120 million people who will benegatively impacted by climate change in thedeveloping world.


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Key perormance indicator

2,524mINGs total sustainable assets undermanagement (in EUR)

We strive to meet the growing demand orenvironmentally and socially responsible products inaddition to generating a good return. To support ourcustomers in their aim to make a positive contributionto society and the environment, we oer variousproducts that have sustainability at their core.

Examples o sustainable productsTo make sure that the sustainable assets we managecontinue to grow, we invest in creating more

awareness about green and social products. We alsolook at developing new products and services thatmeet the expectations and needs o customers.

Carbon credits

The Emissions Products team within our CommercialBanking operations works with clients on projects toreduce greenhouse gas emissions, as per the KyotoProtocol. These projects make it possible to turnemission reductions achieved through green

technology initiatives into tradeable carbon credits.There is a global market or carbon credits, and theproceeds made by trading them can cover asubstantial portion o the investment costs o settingup the project.

Investing in sustainable solutions

We provide loans designed or environmentallyriendly projects, or example in renewable energy,nature development and biological agriculture. In

2009, we nanced the construction and operation othree 50 MW solar thermal generation plants or theSpanish utility company Acciona SA. They are thesecond largest renewable power company in the

Sustainable and socially responsibleproducts and services

For more about our sustainableproducts, please visitwww.ingorsomethingbetter.com/sustainableproducts

world, with over 6.4 GW o generation capacityinstalled. This nance scheme was awarded the 2009,European Renewables Deal o the Year by ProjectFinance International.

SRI products

We oer investors socially responsible investment(SRI) opportunities, such as the ING InvestmentManagement global sustainable equity unds. For SRIproducts, our und managers combine conventional

nancial analysis with an assessment oenvironmental and social policies and perormance.We market these unds through our business units inEurope, the US and Australia under local names.

A ast-growing number o private banking investorsare not only interested in nancial value, but alsowant to know how companies realise prots. Besidesreceiving the usual nancial inormation about acompany, they take environmental, social and ethical

criteria into account. ING in the Netherlands hasbeen gathering this additional inormation since1999 and oering it to investors, including charitiesand oundations.

Greener car leasing

In 2007, ING Car Lease introduced the EcoLeaseproduct. It includes the leasing o an energy-ecientcar, a training course or customers on how toimprove car saety and adopt a more ecient and

environmentally riendly driving style, and a CO2emission compensation service. In 2009 we rolledthis product out to all ING Car Lease units.


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20

How our sustainable products help our customersWe asked three ING customersmaking environmentallysustainable choices to tell usabout their experiences andexpectations o ING and thenancial services sector ingeneral. These interviews helpus understand the needs o

customers who want to makea positive contribution to theenvironment and society.

An interview with:

Philip CohnCool NRG

An interview with:

Wim van den BergMeteorologistWim van den Berg is a proessional meteorologistliving in Bennekom, the Netherlands. He has beenan ING private banking customer or over 20 years.

Why did you rst look at greennancial products?At rst I did not look at green nancial products.But last year my ING nancial advisor and Idiscussed my personal wish to invest my moneyin a responsible and green way. He pointed outthe option ING oers to bring part o myinvestments into a new sustainable prole andthat is what I did.

What do you want rom ethical and greennancial products?Its not the highest yield that is important to me,but I am looking or a sae prole with unds thatconsist o almost 100% sustainable companies.

How can ING better respond to yourinvestment needs and expectations?The more a large bank like ING supports the neweconomy, the more the world will change rombeing money-grabbing to becoming stewardso our planet. In the end, this will help to save

the planet rom shortages o ood, waterand resources.

How has your relationship with INGchanged over time?The relationship is becoming more personal and inthe meantime I am learning about taking even moreresponsible decisions regarding my investments.

How can ING improve on its services to you?By thinking and acting more green themselves.

Currently I receive two separate envelopes or asingle change on my account on the same day. Thiscould easily be combined in one envelope.


Philip Cohn is Head o CDM Projects or Cool NRG,an Australian company that uses carbon or energyeciency schemes to deliver large-scale energy

eciency projects around the world. Their pilotproject in Mexico involved distributing one millionlow energy light bulbs in the state o Puebla duringNovember 2009.

What was INGs role in the Mexico project?We needed nance to buy the light bulbs and payor the distribution. The challenge was that all thecosts are up ront, while the carbon credits wouldbe generated over a long time period up to 10years. So we approached ING to structure an

innovative carbon nancing product.What were you looking or rom investors?We were looking or one that understood carbonmarkets and the risks and could price themappropriately. We approached many nancialorganisations and in the end decided to go with ING.

How did the relationship develop?Because it was a new type o project, there waslearning on both sides. Going through thenegotiations was good or the project: we had to

back up our gures and assumptions. What isinteresting about ING is that its carbon marketsstrategy seems dierent rom other banks. INGdoesnt just speculatively trade carbon credits, butseems to want to nance the underlying projectsand deliver the credits, that can then be traded.

Whats next?The rst pilot went really well bringing togetherthe right partners, including ING, to make ithappen and were hoping to repeat that

perormance nationwide in Mexico. We now haveapproval rom the UN to roll out nationally andwere aiming to distribute 30 million light bulbs to7.5m households over the next two to three years.

For more about our sustainableproducts, please visitwww.ingorsomethingbetter.com/sustainableproducts


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21Corporate Responsibility Report 2009 21

There is anopportunity or

bankers to lobbyor more greenlabelled investmentto receive subsidies.

An interview with:

Marc GelingWind armerMark Geling has armed inZeewolde, the Netherlands, since1993. He has 140 hectares o

mixed vegetable and arable cropsas well as a personal investmentin wind turbines. He has been anING customer since 1992.

What made you choose ING to nanceyour wind turbine?I was a customer o ING already and I normallystart talking to my own bank rst. At the time INGwas doing a lot o wind turbine nancing and therewas the possibility o 100% nance or the windturbine on my arm. Because the project wascertied under the Dutch Fiscal Green Finance

scheme, ING was lending the money at a lowerrate a 1% discount. They saw my opportunityand supported it.

Later you wanted to invest in a localwind arm?My single turbine went very well and three yearsago I had the opportunity to invest in a wind arm,

which has 10 turbines. I needed to raise undsagain and ING wanted to invest again. This timeone-quarter o the investment was my own moneyand three-quarters came rom ING.

What is stopping customers rom choosinggreen and nancial products? What isneeded to encourage them to do so?

I think we need to look at the government here.They can stimulate green business by subsidising it.There is an opportunity or bankers, and in my casearmers, to lobby or more green-labelledinvestment to receive subsidies. We need a betterdenition o green economy as there is a lot moreto green initiatives than wind or solar: there is alsobiological (organic) arming or example.



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22

Auke de BoerING employee

More inormation www.ingorsomethingbetter.com/diversity

Introduction

Our customers want business partners who can understand andrelate to their background and experience. Ensuring that ouremployees are as diverse as our customers helps build the trustingcustomer relationships that are so vital to any global nancialinstitution. We harness the collective wisdom o our personnel bycreating an inclusive culture, one that embraces their dierences.Led by our senior management, we work continuously to promotediversity and banish discrimination and unair treatment.

Colleague view

How do we make the most oour dierences and talents inthe workplace?

ING responseOur culture is ounded ondiverse thinking, inclusiveness,equal opportunities and respector personal values andundamental human rights.We treat one another with

respect and take pride in thecontributions that come romthe diversity o individualsand ideas.

People

Issue:Stronger equalityin the workplace


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2424 People continued

In the challenging environment o 2009, we aligned our peoplestrategy with our programme to decrease costs, reduce risk, lowerleveraging and divestments, as well as our plan to separate ourbanking and insurance operations. We worked harder to engage ouremployees and we set up a new perormance approach or seniormanagement. To help increase the number o women in seniorpositions, we evaluated international compensation standards,

developed a new compensation policy and set diversity targets.

The reorganisation o our business led to a reduction in our workorce.Our Works Council provided advice throughout the process. Weremain committed to managing our people with respect and willsupport everyone aected by the reorganisation. Our mobility centresplayed a major role in helping employees nd alternative roles withinING, or new careers outside the company.

Divestments and reorganisations due to decreased business volumeresulted in a higher number o employees leaving the company thanwe originally orecast.

People

Our strength comes rom our diverse,talented and proessional people.

Respecting ourdierences


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business units set targets or women employeesand those o dierent ethnic backgrounds.

We are currently setting up a global leadershipprogramme to accelerate the career developmento our high-potential senior women executives.This programme will be run by our Business School.

Cultivating the right cultureOur most important objective is to build a healthyrelationship with our customers based on trust andintegrity. Our people strategy is strongly aligned tothis objective. We continuously work to create theright environment and strengthen our perormanceculture based on our Business Principles. To helpachieve this we have set up a number o

development and training programmes, run by ourBusiness School and other training academies.

DiversityWe believe that diversity is about creating aninclusive corporate culture that embraces thedierences o our employees. Despite achallenging business environment in which wehave reduced our overall number o employees,we have taken denite steps to improve our

employee diversity.

Our Global Diversity Council (GDC) plays animportant role in putting this s trategy into eect.The GDC is chaired by our CEO and supported bybusiness leaders rom each business line.

By working with our Global Diversity Oce (GDO),the GDC continues to coordinate the direction oINGs diversity strategy. ING is now helping

...diversity is aboutcreating an inclusivecorporate culturethat embraces thedierences o ouremployees.

Young ING talents working on a sustainable business challenge during a training course.


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26

Mariken Klaasen

Krista Baetens

People continued

What can ING do to promote genderdiversity both generally and also insenior management positions?Bridget: First o all, men need to be involved in theprocess o changing the corporate culture. It cant

just be the same bunch o squeaky wheels in the

workorce pushing or change. Furthermore, thereare several things we can do to make it easier orwomen to reach the top, such as more ormalmentoring and good diversity training to get at thesubconscious biases that many people still holdwithout even realising it. Finally, our internal andexternal recruiting should always require thatemale candidates be included on any slate

considered and the male and emale candidatesshould then be assessed by the same standards.

Krista: What could help is having more channels torecruit providing dierent graduates with dierentbackgrounds and hired by very dierent people.It should not only be about gender diversity. Itsalso about transparency and clear metric setting.Set metrics and achieve them thatll make theceiling disappear.

Mariken: I think ING should be looking or womenwho are doing their job well; strong women doinggreat stu or the company.

Personally do you eel you can take yourcareer as ar as you want in ING or is there aperceived glass ceiling?Bridget: I absolutely do believe I can take my careerwhere I want to at ING. There is, however, a perceivedglass ceiling, and there are perhaps some obstaclesparticular to women at ING, but thats also the same inmany companies.

Krista: I dont believe any position is really out o reach,as long as the decision makers are objective when

coming to their nal decision.Mariken: I believe there are things that may stopwomen, but these might not be things that are coming

Diverse views rom INGAn interview with:

Bridget Healy Member INGManagement CouncilKrista Baetens Senior ManagerMariken Klaasen Early career talent

We asked three women at dierent stages o theircareers to tell us about their experiences andexpectations o diversity at ING and the nancialservices sector.


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Bridget Healy

Thinking more widely than ING, whatis your eeling about nancial servicesand gender?Bridget: The nancial services industry is perceivedas a tough place or women to succeed in. Thatsironic, given that, in the US at least, women inmost amilies make many o the important nancialdecisions and, by the end o their lives, control a loto the wealth.

Krista: I really liked and support this quote rom arecent newspaper: Appointing women to seniormanagement ensures more ethical decisionmaking, more creativity and innovation, betterbusiness perormance and better employeeretention and engagement.

Mariken: Its my view that a mixed employee base,

whether on the work foor or in the boardroom,will lead to more balanced outcomes and results.

What would be your advice or ambitiouswomen working towards a topmanagement position within ING?Bridget: It takes courage and perseverance, agood sense o humour and enormous resilience.You cant let yoursel be discouraged. Watch theseasons change, not the weather, because therewill be inevitable setbacks. Build relationships. Early

in your career, get the best training and takeadvantage o every opportunity put in ront o you.And take charge o your own career.

Krista: Do the best you can do, be positive,passionate and above all remain true to your valuesand character at all times. Dont become a man justbecause you are in a mans world.

Mariken: I have only just started my career, soI will denitely take the above advice o mycolleagues to heart. And, I hope that in the uture

I will be able to contribute to the careers o thewomen that will come ater me.

rom within ING. For me, ambition will make mewant to ull personal long-term goals within ING.But, I nd other things in lie important too.

What support have you received as awoman working in ING?Bridget: Im not given any support that is

particular to me as a woman. Im given supportas a senior leader in the company, that is equallyavailable to my male colleagues. I hope at thispoint that I dont need particular support justbecause I am emale.

Krista: None Ive received a lot o support but notspecically as a woman. With ING, we have a bit oroom or improvement on how we support stacareer development but thats not a gender issue.

Mariken: The same kind o support my male

colleagues receive. And, I like it that way.

Early in your career, get the best

training and take advantage o everyopportunity put in ront o you.


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28 People continued

Keeping employees engaged is hard enough ingood economic times. The uncertainty caused bythe nancial downturn has made it even harder. Atthe same time, our customers need to be able totrust that our sta are proessional, condent andengaged. This means that loyalty, commitmentand going the extra mile are more important to usthan ever.

We continue to benchmark employee engagementacross the organisation. Since 2008, all INGemployees have participated in our annual survey.In September 2009, a record 78,000 employees(74% o our workorce) completed the survey. Asmight be expected, given our restructuring andmarket circumstances, overall employeeengagement decreased by 6% to 65%.

While the survey highlighted the challengesemployees aced, it also threw up some positivendings. Many employees said that ING provides astimulating work environment, and that they wereproud o the company. Areas or improvementinclude leadership engagement and opportunitiesor career development.

Diversity was comprehensively integratedinto the employee survey. It measured perceptionsaround diversity, and compared engagementamong dierent segments o the employee base.

Each manager has received the survey resultsor their own business unit. The human resourcesdepartment is helping them interpret the results,understand the core issues and develop anaction plan.

Employee opinions matter

Key perormance indicator:

71%o employees agreed with thestatement "I am proud to workor ING"

Our customers need to beable to trust that our staare proessional, confdentand engaged.


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Hundreds o ING employees took part in our WHAMM or WhatMatters Most Campaign by sending images o their orangehandprints. These prints tell us what our employees care aboutmost in lie and business. They help ING to set principles or uturecommunity and sustainability projects.


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30

More inormation www.ingorsomethingbetter.com/community

Community

Issue:

Too many children do notreceive education

Colleague view

How can I use my advantages to

boost educational opportunitiesor all?

ING responseOver the past years, thecommitment and eorts o ouremployees has had a hugeimpact on the lives o manychildren. Through the INGChances or Children

programme, our colleagues canmake a dierence by donatingtheir time, money and skills toeducational programmes.

Introduction

Now, more than ever, we need to strengthen the communities around

us. We seek to contribute to positive change by supporting good causes.Together with partnering organisations, we invest in sustainabledevelopment and in the communities in which we live and work. Theyare home to our company, customers and employees and thereore anessential component o our long-term success.

Bianca van OijenING employee


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More inormation aboutcommunity developmentgo to page 34

NGO view

ING wants to make a dierence

and provide employees witheedback on what happens withtheir donations. Thereore, aclear ocus is needed. Together,we have chosen education, andspecically nancial education,as our main ocus.

Action:

Increasing access to educationto improve chances in lie

ING actions

WecontinuedtojoinforceswithUNICEFasapartofourglobalcharity

programme, ING Chances or Children. Wecontributedtothedevelopmentofeducationalprogrammesin

developing countries thereby supporting the Millennium DevelopmentGoals o the UN.

Weinvestedinnancialeducationasawaytoshareourcorecompetenciesand skills.

Weputsubstantialemphasisoneducatingyoungpeopleaboutnancialissues. Weincreasededucationopportunitiesinlessdevelopedcountriesthrough

initiatives such as the Women in Business Challenge.

107,575 children were given access toeducation through the ING Chancesor Children programme in 2009.

Jan Bouke WijbrandiExecutive DirectorUNICEF theNetherlands

32

32 C i i d


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3232 Community continued

Contributing topositive change

Education is a undamental building block or communitydevelopment and thereore it is the core o our communityinvestment programmes. However, or children to optimallybenet rom education, their basic needs will need to be met.We thereore broadened the scope o our ING Chances orChildren programme to include the provision o clean waterand health care.

To raise internal awareness o all the community investmentactivities within our company, we launched an employee platormcalled ING or Something Better. We also set up the ING or

Community

Something Better Foundation (IFSBF) and the employee donationswebsite tool, to better acilitate overall charitable giving withinING Group. In 2010, ING or Something Better will be urtherdeveloped to build employee engagement within our companyand invite them to get involved. In 2009, we launched the INGDisaster Relie Fund and joined orces with the Red Cross. It is ouraim to nancially respond to severe disasters anywhere in the

world within 72 hours, and align the response initiatives taken byour businesses around the world.

Working hard to strengthen the many communities

around us.



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ING Global ChallengeEmployees are crucial to the success o ourcommunity investment programmes. Ourprogrammes depend on their generousdonations o money and their commitment togetting involved in voluntary work and makinga dierence.

On 20 November 2009 the United NationsInternational Day o the Child we organisedour second annual ING Chances or ChildrenGlobal Challenge. It was a great success, with33 countries and 17,000 employees (16.2% oour global workorce) participated. In nextyears Global Challenge, we are aiming or 20%o our workorce to participate.

Our programmes depend on thecommitment o our employees togetting involved in voluntary workand making a dierence.

17,000employees participated in GlobalChallenge 2009, equalling 16.2%o INGs global workorce

35,551hours o volunteering carried out byING employees globally

33countries participated in theGlobal Challenge

992,801raised or UNICEF projects duringthe ING Global Challenge

Global Challenge perormance highlights

An ING employee in India in action at a volunteering day during the Global Challenge.



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ING Chances or ChildrenING Chances or Children, our global charityprogramme, gives children the chance o a betteruture through meeting their basic needs andproviding them with quality education. Since thelaunch o ING Chances or Children in 2005,employees across the organisation have donated

time and money to support child education intheir own communities and in disadvantagedparts o the world. We organise donations,undraising and volunteering activities to engageour employees, and more and more, we involveour customers in the programme as well. As oneo UNICEFs international corporate partners,ING has contributed to the development oeducational programmes in Ethiopia, Zambia,Brazil and India.

Every year, our joint objective is to give as manychildren access to education as we haveemployees. In 2009, ING Chances or Childrenprovided 107,575 children with access toeducation, a reduction o 3% rom 2008.

Local programmes and campaignsNext to global community initiatives there are

numerous local programmes and campaigns.Despite the dicult economic circumstances,our businesses and employees have continuedtheir support. During the 2009 US EmployeeGiving Campaign the pledge o US $500,000(matched by INGs US Foundation) wasexhausted in two days and the US Foundationdecided to double the pledged matching undsamount to $1 million. The 2009 ING VysyaCampaign in India, I believe I can fy, raised

As one o UNICEFs biggestcorporate partners, ING hascontributed to educationalprogrammes in Ethiopia,Zambia, Brazil and India.

ING Chances or Children

EUR 96,000 or local charities. ING Direct inGermany supports a research competitionand BaskidBall, a basketball project involvingmentoring at schools. ING Belgium willintroduce a Solidarity Prize enabling itsemployees to apply or a grant to support aproject o a non-prot organisation where theyare active as volunteers.

Key perormance indicator:

107,575In 2009, ING Chances or Childrenprovided 107,575 children withaccess to education

For inormation on ING Chances or Childrenplease visitwww.ingorsomethingbetter.com/cc




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35Corporate Responsibility Report 2009Corporate Responsibility Report 2009 35

Like ING, we want to

work with organisationsthat share our visionand values, and takesustainability seriously.

An interview with:

Jan Bouke WijbrandiUNICEFWe interviewed Jan Bouke Wijbrandi, Executive Director oUNICEF the Netherlands, to get his views on the partnershipbetween UNICEF and ING.

Why did you choose ING as a corporate partner?O course, or us, it is all about childrens rights. We can only und andpromote our activities i partners in society participate. We want to workwith organisations that have matching values and vision, and take

sustainability seriously. Issues like extreme poverty, gender inequality,climate change; they are all interrelated and have a strong eect onvulnerable groups like children. We eel ING meets these requirements.

What happens to the money ING employees donate to UNICEF?ING wants to provide employees with eedback on what happenswith their donations. Together, we have chosen education, and morespecically nancial education, as our main ocus. Financial illiteracy iswidespread in the world and children need education to counter thisproblem. There are our countries where ING supports UNICEFsactivities. In Ethiopia and Zambia, we build schools, train teachers and

provide other basic needs to children. In Brazil we help to improve thequality o education by improving the school management and theeducational programmes. In India we involve ING employees in our

activities. And, some ING businesses have developed local activitieswith UNICEF.

How are you able to push ING on issues that worry you whenthey are a key partner?First o all, in our understanding o a partnership both partners shouldbe able to address issues related to their respective missions and wayso working. In that context, it is our style to use the quality o ourarguments to convince in order to achieve the changes we would liketo see. We are interested in a continuous and rank dialogue. In sucha process, trust and transparency are key words. Our screening criteriaor companies are embedded in our partnership agreement. This givesboth UNICEF and ING the opportunity to discuss issues proactively.

Can you give an example o an issue you have discussed?ING has strong policies in place with regard to, or example,controversial weapons. But, i we have additional questions, we askthem. This model o open dialogue creates a sustainable partnershipor both parties involved. The most important thing to me is that thisis a partnership between riends.

What more could ING and UNICEF do together?Concepts such as micronance or nancial education come to mind.These are topics we do not yet cooperate on extensively, but rom myperspective, this would be something to look at in the uture.Furthermore, we could look at the position o women in developingcountries. Also, the programme is now ocussing on ING employees, butwe hope to be able to expand our partnership urther to ING customers.



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stepped up taking class-groups to the MoneyMuseum and teaching entrepreneurship toteenagers. In 2010 we intend to increase oureorts in this area in the Netherlands.

Following a template used in the USA, INGDIRECT Canada has launched its own version oan educational website designed to teach our-to ten-year-olds about nancial issues in a un,interactive way. These issues include the valueo money, setting a budget, and buildingsavings goals or the uture. You can visit thewebsite at www.planetorange.ca

In October 2009, we launched the Women inBusiness Challenge together with the Businessin Development (BiD) Network and thedevelopment organisation ICCO. The aim o thechallenge is to support women entrepreneurs,

particularly in Asia, Arica and Latin America,

Our community investment initiatives in nancialeducation and entrepreneurship aim to helppeople become nancially sel-sucient. Theseinitiatives are aimed at children, women andmicro- and small business entrepreneurs.

Part o our social commitment is to promotewider nancial literacy in our home marketssuch as Italy, the USA, Canada andthe Netherlands.

Coltiva il tuo sogno (Grow your dream) is anING Direct Italy campaign to encourage childrenbetween six and ten to develop the habit osaving. This is saving in its broadest sense notjust money, but also saving environmentalresources and time. The campaign has been

rolled out in 1,200 primary schools in ve Italianregions. The success o Coltiva il tuo sognowas recognised by the 2009 Child GuardianAwards, where it was named the bestadvertising campaign.

In the US, we work with partners such as JuniorAchievement, ING-Girls Inc. InvestmentChallenge and Operation Hope to ull along-term commitment to invest in nancialeducation. Among its many projects, OperationHope arranges or business leaders to visitinner-city schools and educate students aboutthe importance o money management.

In the Netherlands we introduced the Youth &Money Guide, an online tool to support parentsin the nancial education o their children bygiving them useul insights and advice.

Furthermore, ING employees have again

Broadening nancial literacy



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p p y p

by providing them with the assistance,templates, contacts and nancial advice theyneed to get their business started.

The Women in Business Challenge asks emaleentrepreneurs to submit a retail business plan.Everyone who takes part will receive eedbackto improve their business plan, and INGvolunteers are on hand to help them write it.The best plans win a prize and the nalistswill get the opportunity to present their plansto investors.

For inormation about other local fnancialeducation initiatives, please visitwww.ingorsomethingbetter.com/local

Our community investmentinitiatives in fnancial education

and entrepreneurship aim tohelp people become fnanciallysel-sufcient.

38 Environment


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Customer view

How can ING help me take

better environmental care?

ING responseMany o our customers want totake an active role in tacklingclimate change. So we arehelping them to chooseproducts with carbon reductionbuilt in, such as carbon-neutralcar leasing and sustainable

equity unds.

Introduction

The eects o climate change reach ar beyond the environment

alone. They also aect ood security, public health, economic growthand, thus, poverty reduction targets in the poorest areas o theworld. With this in mind, we believe it is part o our responsibility toexpress our opinion on these matters and seek ways to enhance ourunderstanding o the issues at stake in order to best address them.We aim to contribute to the decarbonisation o the economy byreducing the carbon dioxide emissions rom our own operations, andby seeking ways to incorporate the latest insights on climate changeinto our business model rom employee awareness to productdevelopment and risk management.

Issue:

Protecting the environmentneeds collective action

Mark GelingSustainable armer

More inormation www.ingorsomethingbetter.com/environment



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NGO view

It is important that ING makes

strategic decisions on policychoices. It would be nice tosee ING position itsel as aleader in environmentalresponsibility; I would likeING to become a rontrunnerto lower its ootprint.

ING actions

Wehavebeenoperatingcarbonneutralsince2007.

Wehaveintegratedprinciplesofsustainabledevelopmentintoourbusiness decisions and processes.

Wearedevelopingdisclosureapproachesonpotentialnancialimpacts o climate change in our nancing and investment activities.

Weco-signedstatementsinsupportoftheCOP15climateconferencein Copenhagen to reach a strong climate agreement.

Wedevelopproductsandservicesthathelpcustomersreducetheirown carbon ootprint.

Weworkwithourpartnerstointegrateclimatechangemeasuresintoour community investment activities.

Action:

Investing in alow carbon uture

62% o our electricity comesrom wind, solar or water power

AnnemarieGoedmakersMilieudeensie(Friends o theEarth Netherlands)

More inormation aboutING and the environment

go to page 40

40 Environment continued40


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Environmental protection is one o the dening challenges acing ourworld today. ING has operated 100% carbon neutral since 2007. Bylowering our energy consumption, using green energy and osettingcarbon emissions by investing in certied projects, we have zero netCO2 emissions.

Much o the electricity we purchase worldwide (62%) comes romwind, solar and water power. We encourage our employees to use

Environment

Creating opportunities by integrating theenvironment into our products and services.

Its not businessas usual

public transport or commuting. We also promote video conerencingto reduce business travel by air, and make energy ecient carsavailable to those o our employees entitled to a company car.

We continue to take on the environmental challenge in the waywe manage our operations. In 2009, 60% o our business units tookaction to reduce their own energy usage as part o our ongoingcommitment to increasing energy eciency.



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ramework o the Equator Principles, or example,we are searching or more ways to incorporatecarbon-related issues into our nancing activitiesand to calculate the carbon dioxide emissions oour customers. You can see some examples o oursustainable products on page 19 o this report.

We believe it is part o our corporate responsibilityto contribute to the wider decarbonisation o theeconomy. That is why, as well as working at manylevels to reduce our direct impact, we also work tobetter understand our indirect impact.

At a global level, we signed the CopenhagenCommuniqu and Investor Statement that

appealed to the participants o the 2009 COP15climate conerence in Copenhagen to adopt astrong global climate agreement. Together withother Dutch banks, we called on the Dutchgovernment to create avourable conditions or aswit transition to sustainable energy sources.

Closer to home, we are integrating climate changeinto an increasing number o aspects o ourbusiness model, rom product development to riskmanagement. Recent dialogue with sustainable

entrepreneurs have made us realise that we candrive our sustainable development strategy urtherby supporting environmentally responsiblebusiness concepts. In 2010, we will develop aprogramme to urther stimulate sustainableentrepreneurship and sustainable innovation.

We are building a repository o knowledge anddeveloping new approaches to disclosing thepotential nancial impacts o climate change in our

nancing and investment activities. Within the

Reducing our direct CO2 ootprint and

understanding our indirect impacts willcontinue to be a top priority in the years ahead.

Perormance highlights

100%ING is the rst major Dutch nancialinstitution to be 100% carbonneutral, since 2007

62%o the electricity we purchase isderived rom wind, solar orwater power

60%o our business units took additionalenergy reduction measures in 2009

10%decrease in INGs CO2 ootprint(extrapolated gures) comparedto 2008

42 Environment continued


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Perormance highlight

16%decrease in oce paperconsumption per FTE

ING Goes Green

The ING Plant a Tree Campaign and the ING GoesGreen programme encourage employees to maketheir own workplace greener with tips orpreserving biodiversity and creating a cleanerenvironment. It also helps them to betterunderstand how they can limit their environmentalootprint at home.

The programmes promote awareness andcommunity involvement by encouragingemployees to plant trees, donate to zoologicalgardens, clean beaches and preserve a widerange o other ecologically important areas.Many business units have started localenvironmental initiatives.

Lights out in IndiaIn 2009, ING Vysya in India switched o all lightsand illuminated signs or Earth Hour. They also

asked their suppliers, their 2,000,000 customersand thousands o employees to join them insupport o the energy-saving campaign. Theyconvinced some o the main shopping streets inBangalore to take part, and organised a seminaron clean technology or the local communityaround its head oce.

Tree planting or a better climateMany o INGs Central and South American

operations are keen local supporters o the UnitedNations Programme or the Environments (UNEP)One Billion Trees Campaign. In August 2009, INGChile volunteers planted 80 native trees quillayes,peumos and maitenes in the hills o SantiagosRenca neighbourhood as part o Planta un rbol, acountry-based programme that aims to bring onemillion new trees to Chile. ING volunteers rom allareas in Santiago, including senior executives,

worked together with local non-governmentalorganisation Cultiva, which provided thetechnical support.

At ING Mexico, employees were involved inreorestation as part o the Mexican Siembra unrbol programme. At the Arican Zoological ParkSaari in Puebla State, 150 volunteers planted1,000 trees, while a urther 1,800 were sown inthe parks surroundings. Forty volunteers also

assisted with maintenance at the Brotantes Springecological reserve.

This summer, ING Peru organised a childrensdrawing contest to celebrate world tropicalrainorests day. Over 6,000 children rom Limaparticipated and a total o 300 drawings weredisplayed in INGs oce in Lima.

More inormation on ING and the environment www.ingorsomethingbetter.com/environment



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ING should set cleartargets perhaps

more investment inrenewable energy.

An interview with:Annemarie GoedmakersMilieudeensieAnnemarie Goedmakers is President o Milieudeensie (Friends o theEarth Netherlands), one o the largest environmental NGOs in theNetherlands. She combines this role with her work in renewableenergy and chimpanzee conservation.

What do you eel are the strongest points o INGsapproach to sustainability?

ING has made good progress on its approach to controversialweapons and transparency, although there is still room orimprovement. But at least we see positive progress.

Thinking about INGs environment policy, what doesMilieudeensie eel are the weakest points?Well, INGs climate policy is rather vague and with climate changeissues ING is lagging behind our expectations. We would like to seeclear signs that ING will take its share in tackling the enormous task tolower global CO2 emissions.

What more can ING do to promote an improvedenvironment? Is ING grasping this opportunity atthe moment?ING could choose to become an example o an environmentallyresponsible nancial institution to the rest o the world and set thedirection or others to ollow. These decisions could, or example,involve a certain level o responsibility or the CO2 emissions o itscustomers or setting examples on how to lower carbon emissions andmanage climate impacts through investments.

With such a commitment, it will be possible or ING to set targetsaccordingly perhaps or lower-than-average CO

2emissions caused

by its activities and investment in renewable energy.

Furthermore, I would like to see ING taking a clear position in thediscussions around climate change. For example in its communicationsto customers.

Where can nancial services in general makea positive impact?Climate change is a very broad issue and the need or investments innew sources o energy is enormous. In this respect, banks can help tobring about the solutions we need. It is ironic that the Netherlands

built its development on wind in the Golden Age, yet now investorsare saying there isnt enough wind or that investing in it is too risky.How do we change this perception o risk? We need to look at theacts and the bigger picture.

44 Environment continued


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ING Real Estate Development integratessustainability into its projectsING Real Estate Development (ING RED) is aleading pan-European developer ocusing onretail-based, mixed-use projects. ING RED sees agrowing demand or sustainable buildings and hasdeveloped an integrated approach to sustainabilityelements in its real estate developments.

In November 2009, ING RED opened the ullyleased-out Allee retail and leisure centre inBudapest, Hungary. The Allee Shopping Centreencapsulates the ING RED approach to sustainablereal estate and includes sustainability elementssuch as LED lighting systems, green roos andwater management systems.

Renovation o ING Tower pays o orthe environmentDuring 2008 and 2009, the ING Tower in Seoul,Korea, underwent a major acelit. As a result ithas become much more energy ecient andenvironmentally riendly. Improvements includedwater acilities and automatic power/lightingcontrols that have reduced water and energy use.

Upgrades to the building ventilation systems haveimproved indoor air quality and better lit routinghas increased operational speeds and reducedwaiting time by 15%.

As a result o the renovations and operationalchanges, ING Tower is expected to achieve a20 35% saving in its energy use, equivalent to350 tonnes less carbon. Non-recyclable wasteand natural gas usage are also expected to allby 73% and 60% respectively.

The building is the rst in Korea to receive the USGreen Building Councils Leadership in Energy andEnvironmental Design Existing Building (LEED-EB)standard or a renovation project.

ING sponsors environmental educationin IndiaAs part o our eorts in environmental protection,we educate kids around the world about

environmental care. One example is Impact, ascience and environment teaching programmeunded by the ING Vysya Foundation in India thatis set to begin in 2010. The two Impact mobile labswill teach 3,000 out-o-school girls in Rajasthanand Uttar Pradesh. As well as improving the girlseducation, the programme aims to increase theircondence and participation in their communities.

For more about our environmentaleorts, please visitwww.ingorsomethingbetter.com/environment



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An interview with:

George PollockCH2M HILLGeorge Pollock is Design Operations Manageror consulting engineers, CH2M HILL. In 2009 hewas involved in an international project to designa new green data centre or ING to be built inthe Netherlands.

Can you outline the basics o the ING project?ING wanted an state-o-the-art data centre with aminimum 20-year liespan.

Three important aspects o the brie were:fexibility, scalability, modularity, with a ocus onmaximising the power eciency o the data centre.Due to the nature o INGs business, thespecication also required the absolute top level o

robustness and high reliability so that the datacentre is always available supporting the INGcustomers. Only government acilities or militarysystems have a higher specication.

What in particular is green aboutthe approach?One thing we have done rom a green perspectivethat is really innovative, is to maximise the use ooutside air or cooling, or ree cooling. Because othe climate in the Netherlands, 86% o the time we

can use ree cooling. For the other 14%, we cantake cool water rom 500 1000m down in thelocal aquier which makes the data centre veryenergy ecient. As a result we have designed asystem that ar exceeds current best practicestandards or energy eciency in data centres.Weve also designed in a two-way system tomaintain the aquiers thermal balance over the year.

How supportive was ING in using theseinnovative approaches?

This is where ING has been a great client. You needto have a client that will put their money wheretheir mouth is. Great credit goes to ING or actively

striving and challenging us to push theenvironmental angle orward. It has raised thebenchmark or data centres.

Was it more expensive?One o the real benets is that the design or the

innovative cooling system is no more expensivethan old systems. ING is getting a huge energy andcarbon dioxide benet rom a system that does notcost them much more. Furthermore the return oninvestment is signicantly improved.

For more inormation on our policies towardssuppliers, please visitwww.ingorsomethingbetter.com/suppliers

46 Key perormance indicators


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Key perormance indicators (1)

Year end 2009 Year end 2008

Equator Principles (number o projects reviewed) 77 135

Sustainable assets under management (1)(in EUR million) 2,524 2,295

Customer Satisaction Index (2) 69.1% 69.6%

Economic value generated (in EUR million)

Total assets 1,163,643 1,331,663

Capital and reserves 33.863 17.334

Total income 47.765 66.291

Result beore tax -1,525 -1,487

Net result -935 -729Personnel expenses: salaries 5.075 5.885

Personnel expenses: other 2.263 2.879

Employee engagement index (3) 71% 83%

Diversity % o women in the ING Management Council 12.8% 11.8%

ING Chances or Children Number o children provided with accessto education 107.575 111.409

Green energy kWh (in thousands) o electricity purchased by INGderived rom wind, solar or water power 330.582 344.448

Dow Jones Sustainability index 75 71

FTSE4Good Included Included

(1) For a detailed overview see page 49.

(2) Satisaction scores are based on the American Customer Satisac tion Index (ACSI) methodology, adapted or the nancial services market and based on a combination o questionsrelated to overall satisaction, customer delight and ideal provider.

This score is not weighted by market. The selection o countries changes every year mainly due to strategic decisions o ING (e.g. investments and divestments). However this doesnot have a signicant impact on the overall customer satisaction index score.

The customer satisaction scores o ING Direct are not included. ING Direct has a dierent way o measuring customer satisaction.

(3) The ING engagement index is the percentage o ING employees who have indicated that they are proud to work or ING. The research was carried out by Kenexa.

We report on 10 key perormance indicators (KPIs). All o the KPIsrelate directly to INGs strategy on corporate responsibility and arecrucial in measuring our perormance. We have asked the audit rmo Ernst & Young to give reasonable assurance over these KPIs.



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Assurance report

To the management o ING Groep N.V.

Engagement and criteria

We have perormed an assurance engagement in accordance withStandard 3000 Assurance Engagements Other Than Audits or Reviewso Historical Financial Inormation aimed to provide reasonableassurance that in the Corporate Responsibility Report 2009 o ING GroepN.V. (CR report): thetenKeyPerformanceIndicators(KPIs)asdenedonpage46

are, in all material respects, reliable; and thedescriptiononpage55and56accuratelyreectsthereporting

processes within ING Groep N.V. (ING) in accordance with thereporting principles in the G3 Sustainability Reporting Guidelines oGlobal Reporting Initiative (GRI) and the documented reportingpolicy o ING.

Limitations o our assurance engagement

We have not audited the reliability o the inormation in INGsCR report 2009 other than the KPIs mentioned above.

Concerning the Equator Principles we audited the accuracy regarding

announcements, accepting and category determination o the projectsreviewed. We have not audited the completeness o the number oprojects o the Equator Principles.

The managements responsibility

Management is responsible or the preparation o the report and theinormation therein in accordance with the Global Reporting Initiative(GRI) principles and the documented reporting policy o ING. Thisresponsibility includes designing, implementing and maintaining internalcontrol relevant to the preparation o a CR report that is ree o materialmisstatements, selecting and applying appropriate reporting policies thatinclude the GRI reporting principles and using measurement methodsand estimates that are reasonable in the circumstances. The choicesmade by management, the scope o this report and the reporting policy,including any inherent limitations that could aect the reliability oinormation, are set out on page 55 and 56 o the report.

The auditors responsibility

We perormed our procedures in accordance with Dutch law. This lawrequires, among other things, that we comply with ethical requirements,including requirements relating to independence. Our responsibility is to

express at the request o INGs management a conclusion on the itemsdescribed above in the section engagement and criteria. Ourresponsibility in perorming our assurance procedures is to the

management o ING only. We have perormed the procedures deemednecessary to provide a basis or our conclusions.

Our main procedures were: determining the method used by ING in its reporting process the

reporting principles in the G3 Sustainability Reporting Guidelines oGlobal Reporting Initiative;

evaluating the acceptability and consistent application o the reportingprinciples used in preparing the CR report 2009;

evaluating the reliability o the ten KPIs by: obtaining an understanding o the design and operation o the

systems and methods used to collect and process the reportedKPIs, including the consolidation process;

identiying inherent risks relating to the reliability o the KPIsand investigating the extent to which these risks are limited byinternal controls;

assessing the related internal controls or their operatingeectiveness, insoar as this was relevant or our assuranceengagement;

perorming based on a risk analysis additional procedures relatedto the KPIs, by a combination o:

interviews with relevant sta at corporate and business unit levelto substantiate the related descriptive inormation in the report;

quantitative analyses at corporate and business unit level toassess the quantitative data;

reconciliations with audited nancial statements; detailed review o the data on a test basis at the group and business

unit level, using internal and external sources o inormation tosubstantiate the reliability o the inormation provided.

Conclusions

Based on the procedures perormed and considering the choices made byING as refected in the reporting policy, we believe that in the CR report2009 o ING: the ten KPIs as dened on page 46 are in all material respects reliable; the description on pages 55 and 56 accurately refects the

reporting processes within ING in accordance with the reportingprinciples in the G3 Sustainability Reporting Guidelines o GlobalReporting Initiative and the documented reporting policy o ING.

Amsterdam, 1 April 2010or Ernst & Young Accountants LLPsigned C.B. Boogaart

48 Governance and compliance


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Governance and compliance

We believe good governance and compliance are importantoundations or responsible business practice. They are also in thebest interests o our customers, shareholders and sta.

We aim to always comply with laws, regulations, and ethical,environmental and social standards. However, achieving the bareminimum o compliance risk management is not enough. In order topreserve our reputation, we want our people to go beyondcompliance, acting with complete integrity at all times.

PoliciesWe embed clear, practical policies and procedures in our businessprocesses in all o our Business Lines. We have systems in place tohelp management track current and emerging compliance risk issues,communicate these to internal and external stakeholders, and drivecontinuous improvement. We know that good compliance riskmanagement involves understanding and delivering on theexpectations o customers and other stakeholders, therebystrengthening the quality o key relationships.

Non-nancial risk policies and procedures include: The ING Group Charter and Framework Insider regulations Whistleblower procedure Financial Economic Crime policies

Group Corporate Responsibility DepartmentThe Corporate Responsibility Department (CR team) is ultimately theresponsibility o our CEO. The role o the team is to:

develop strategy and policies on CR-related issues

engage in dialogue with civil society groups and otherstakeholders

coordinate perormance reporting and produce the annualCR report

provide inormation to sustainable investors and ratings agencies participate in thought leadership orums develop internal training programmes on CR topics set up internal community development and environmental

awareness programmes monitor good practices

draw attention to, and advise on, potential trends andemerging issues

The CR team develops our CR strategy. This is then applied to allbusiness units worldwide. Business units may develop their ownadditional policies to suit their specic strategic ocus andachievements. It is the responsibility o each business unit to adhereto the policies set at Group level.

In addition to the Group CR team, various other departments, eachwith their specic expertise, ensure that policy commitments aremet. The

ING RSE Reporte 2009

Documents

Transcript of ING RSE Reporte 2009