ING

ING Bank is a global financial service company of Dutch origin.[i] ING serves over 32 million private, corporate and institutional customers from more than 40 countries.[ii] The European Commission has required ING Group to separate its banking (ING Bank) and insurance (Nationale Nederlanden) divisions. The separation will be concluded in 2016.[iii]

ING’s nuclear weapons policy states that companies that mainly focus on defence-related businesses and that are involved in the development, manufacture, maintenance and trading of nuclear weapons or specifically designed delivery systems are excluded. However, ING may finance or invest in nuclear weapon producers with largely non-defence related businesses if those companies indicate that ING funds will not be used for nuclear weapons related activities.[iv]

ING considers these weapons controversial due to their indiscriminate effect and the likelihood of civilians being injured. However, because nuclear weapons are not fully banned by the international community and many high tech companies are involved in various ways in the nuclear armaments programs of their respective governments, ING excludes only the nuclear weapons related activities of a company, not the company as a whole, if those companies indicate that ING funds will not be used for nuclear weapons related activities.[v]

The policy applies to ING’s commercial banking and investment banking, as well as to the investments made on its own accounts and internally and externally actively managed funds .[vi] ING makes a number exceptions to the exclusion policy. The policy does not apply to investments made on behalf of clients in the U.S., where ING claims it cannot enforce its own policy and for investments made within the boundaries of an explicit customer mandate. For its own passively managed funds, ING does not offer index funds which contain over 5% of shares of nuclear weapons producers.[vii] ING requires that its external asset managers apply the exclusion policy to their discretionary mandates.[viii]

ING’s exclusion list, which is based on information from NGOs, customer screening and Sustainalytics, is not publicly available.[ix]

We commend ING for adopting a public policy on nuclear weapons. We recommend ING exclude all activities of nuclear weapons producing companies, regardless of the relative proportion of nuclear weapons related activities of the company. ING should apply its exclusion policy comprehensively to all its markets, including in the US and to all its financial products, including funds following an index. We look forward to engaging with ING, so a strong and comprehensively applied policy may be listed in the Hall of Fame in a future update of this report.

 

ING’s policy on nuclear weapons is leaky; send them a message and tell them to fix it!

To send ING a message, please go to this contact form:
https://www.ing.nl/particulier/klantenservice/contact/u-heeft-een-vraag-of-klacht/u-heeft-een-vraag-of-klacht.html

Send this email!
You can write your own message, or copy this message into the contact form.

Congratulations ING. I saw on www.dontbankonthebomb.com that you have a policy limiting investments in nuclear weapons. I think it’s really important that you share my concern about these weapons, and I appreciate that there is a public policy.

However, the policy does have some loopholes and the Don’t Bank on the Bomb report shows how you still might invest in nuclear weapons producers. I am concerned about this, because ING also invests my money and I don’t want to be associated in any way with the production of these inhumane weapons.

It would be great if ING made the following changes to make the policy airtight:
• Exclude all activities of nuclear weapons producing companies, regardless of the relative proportion of nuclear weapons related activities of the company;
• Apply the exclusion policy comprehensively to all its markets, including in the US, and to all its financial products, including funds following an index.

With kind regards,

Or :

Tweet: Even @ING_News knows investing in #nuclear weapons should be restricted. Strengthen the policy & say #goodbyenukes! http://ctt.ec/Ya5lR+

 

Website: Twitter: Facebook:
http://www.ing.com/ @ING_News https://www.facebook.com/ING

 

 

 [i]           ING, “Profile”, website ING (http://www.ing.com/About-us/Profile-Fast-facts/Profile.htm), viewed 27 May 2015.

[ii]           ING, “ING Group Fact Sheet 1Q2015”, website ING (http://www.ing.com/web/file?uuid=becf30f0-0f47-4ac5-95f4-bfad4bda8e28&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=14083), viewed 27 May 2015.

[iii]          Elsevier, “ING moet splitsen en brengt Nationale-Nederlanden snel naar beurs”, 5 June 2014, available at http://www.elsevier.nl/Economie/nieuws/2014/6/ING-moet-splitsen-en-brengt-Nationale-Nederlanden-naar-beurs-1536303W/, viewed 27 May 2015; ING, “ING Group Fact Sheet 1Q2015”, website ING (http://www.ing.com/web/file?uuid=becf30f0-0f47-4ac5-95f4-bfad4bda8e28&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=14083), viewed 27 May 2015.

[iv]          ING, written response to PAX dated 18 May 2015.

[v]           ING, written response to PAX dated 18 May 2015.

[vi]          ING, “Environmental and Social Risk Framework”, website ING (http://www.ing.com/web/file?uuid=30799935-4b6e-4f56-88ad-23f89508d651&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=33461), viewed 27 May 2015; ING, written response to Profundo dated 27 May 2014.

[vii]          ING, “Environmental and Social Risk Framework”, ING website (http://www.ing.com/web/file?uuid=30799935-4b6e-4f56-88ad-23f89508d651&owner=b03bc017-e0db-4b5d-abbf-003b12934429&contentid=33461), viewed 27 May 2015.

[viii]         ING, written response to Profundo dated 27 May 2014.

[ix]          ING, written response to Profundo dated 27 May 2014.

Who divests?

Policy Research

The financial institutions presented all have publicly available policies – or summaries thereof – excluding investments in nuclear weapons producing companies. Since the banking group usually sets the investment policy and since the group directly or indirectly supervises its subsidiaries, we research the group policy only.

The Hall of Fame section highlights financial institutions that have comprehensive policies preventing investments in nuclear weapon producers. These policies meet all of the criteria.
The Runners-Up provides information on existing policies and makes recommendations for how to strengthen them.

Criteria:

Hall of Fame finanical institution policies policy must:

1. Exclude all nuclear weapon associated companies

The policy excludes:

  • whole companies not only nuclear weapons related projects
  • companies associated with nuclear weapons including through joint ventures
  • companies regardless of their country of origin
  • companies regardless their country of operation

2. Exclude all nuclear weapon associated activities

The policy excludes companies associated with:

  • development, testing, production, maintenance or trade of nuclear weapons related technology, parts, products or services, and;
  • delivery systems such as missiles, that are specifically developed for nuclear tasks. This includes technology that is designed for ‘dual use’ (military and civilian) but excludes technology that is not designed for, but can be used in nuclear warfare. It does not include delivery platforms such as bombers and submarines.

3. Apply to all the institution’s products and services

The institution applies the policy:

  • for the entire Group, including subsidiaries
  • in all markets
  • to all asset management classes – passive and active, internal and external.
  • to all existing and future investments.

The financial institutions in the Hall of Fame have not engaged in any financial relationships with any of the nuclear weapon associated companies listed in this report. The policies of over 80 financial institutions were analysed for this report.

Runners-Up are financial institutions whose nuclear weapons policy does not meet all of the above criteria .

Methodology

To identify financial institutions with a policy on nuclear weapons, we research a variety of sources: NGO reports, screening-agency information, financial institution reports and websites, information from campaigners and other public sources. For practical reasons, the scope of this report is limited to those financial institutions that have an investment policy or a summary of that policy in English. The list of institutions in the Hall of Fame is not exhaustive. We welcome additions from those able to provide them.

For the purposes of this report, nuclear weapon producers are defined as companies that produce key components to test, develop, maintain, modernise and deploy nuclear weapons. There are countless companies involved in the broad nuclear weapons complex, and this report only details those most heavily involved in the production and maintenance of nuclear warheads and their delivery systems (such as missiles and launch tubes). The report does not include companies involved in the production of delivery platforms (such as nuclear capable bombers and submarines).

In advance of this report, all financial institutions were asked to fill in a standardised questionnaire with detailed questions on the scope and content of their policies. Financial institutions that did not respond are not included. Of the thirteen financial institutions listed in the Hall of Fame, six publish a list of companies that they exclude from their investment universe. The companies excluded are listed in the profiles of the financial institutions as a resource. Three other financial institutions in the Hall of Fame work with an inclusion list rather than an exclusion list. The remaining four do not make their lists public.

Each financial institution profile in the Hall of Fame includes a brief description of the institution, a summary of key policy elements, and the exclusion list if applicable. We researched investments in companies on our producers list for each of the financial institutions listed in the Hall of Fame. None of the financial institutions listed in the Hall of Fame invest in any of the 26 identified nuclear weapon producers.