19/11/2017 INGs response to the admissibility of a complaint to the National Contact Point | ING

INGs response to the admissibility

of a complaint to the National
Contact Point
4 min read Listen

14 November 2017

The National Contact Point (NCP) today announced that the

complaint by Greenpeace, BankTrack, Milieudefensie (Friends of the
Earth Netherlands) and Oxfam against ING merits further
investigation. In accordance with its procedures, the Dutch NCP has
oered to facilitate a dialogue between ING and Oxfam Novib,
Greenpeace, BankTrack and Milieudefensie. ING has accepted the
NCPs oer to take part in that dialogue.

The climate is of course a hugely important subject in which banks also have a role to
play and on which we naturally want to enter into dialogue. And we are already doing
so. Like the parties which submitted the complaint to the NCP, ING would also like to be
able to identify and then publish its indirect greenhouse gas emissions. Unfortunately,
this is not so easy in practice; there is currently no international standard on reliable
and comparable data for calculating CO2 emissions. The absence of information on
emissions by our global customers and the lack of international methodology to
attribute nanced emissions to a climate scenario mean it is impossible for ING to
meet the wishes of the complainants. No international bank can. We are involved in
numerous initiatives to change this. Our response to the initial complaint, which
explains this, is shown below and it was also published by NCP today.

Summary of INGs initial response

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19/11/2017 INGs response to the admissibility of a complaint to the National Contact Point | ING

ING agrees completely that climate change is a tremendous challenge for the world
and it is one in which banks, including ING, have a role to play. ING and the
complainants have held several extensive discussions on the subject of the complaint
and the related challenges and continue to discuss them. The complainants claim that
ING is not doing enough and falls seriously short in its climate policy compared with
other nancial service providers. They point mainly to the environmental policies of
investment institutions (which face dierent challenges from banks) that they say go
further in some areas than INGs policy. Investment institutions such as pension funds
invest in companies listed on the stock exchange. Information on CO2 data of listed
companies is available through the CDP and research bureaus such as TruCost. Such
data is often not available to banks as they have many non-listed companies in their
portfolios.

That ING subscribes to the importance of measuring nanced CO2 and the

development of a methodology is also shown by the fact that as early as May 2015
ING committed to the methodology to be developed by the Science-based Target
Initiative (an initiative of the WWF, World Resources Institute, Ecofys and others).

ING osets all of its own CO2 emissions and so has been a climate-neutral organisation

since 2007.

ING also takes climate reporting seriously and has been included once again with the
highest possible score in the CDPs Climate A list, comprising 193 businesses which are
climate-change leaders. ING also received a Euronext/CDP Leadership Award for its
excellent environmental reporting.

In other areas, INGs policy and actions in fact go far further than those of its peers. For
example, BankTrack, which it should be noted is one of the complainants, says ING is
the only bank in the world that publishes its nancing of mining of thermal coal, thus
clarifying the reduction of this in its portfolio (down 26% in 2016). See BankTrack et al:
The eectiveness of existing coal mining policies at major banks remains clouded in
uncertainty due to a dearth of reporting. To date, the only bank to have provided
detailed reporting is ING.

In addition, the universally respected 2C scenario of the International Energy Agency

(IEA 450 Scenario) assumes that some 60% of all energy will still come from fossil fuels
in 2040. See Global trends, p. 206 World Energy Outlook 2016 (OECD/IEA 2016).
Consequently, no conclusions can be drawn from the mere fact that ING nances fossil
fuels.

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19/11/2017 INGs response to the admissibility of a complaint to the National Contact Point | ING

The complainants are asking ING to identify and publish its indirect greenhouse gas
emissions. ING is keen to announce that it would like to do this. As explained in its
annual report, ING is running pilots to measure its indirect climate footprint. ING also
supports the Science-based Target Initiative referred to above that is developing a clear
methodology to translate banks climate footprint into targets. There is no lack of
willingness on INGs part but what the complainants are asking for is currently not
technically possible. There is currently no international standard on reliable and
comparable data for calculating CO2 emissions. The absence of information on
emissions by our global customers and the lack of international methodology to
attribute nanced emissions to a climate scenario mean it is impossible for ING to
meet the wishes of the complainants. No international bank can.

The complainants are also asking ING to set targets and to work towards bringing its
indirect greenhouse gas emissions in line with a 1.5C scenario. This demand is out of
line with the international communitys 2C scenario. At the request of UNFCCC/parties
to the Paris Accord, the United Nations climate agency (IPCC) is currently examining
the feasibility of a 1.5C scenario. The outcome of that research is expected at the end
of 2018. Governments may take the results of the IPCC report into account when
assessing their plans to remain within the 2C standard. Since the IPCC report on the
feasibility of a 1.5C scenario will not be ready before the end of 2018, it is impractical
to demand that ING commits to a 1.5C scenario on 1 September 2017. This is
completely separate from the fact that ING is actually working to make its portfolio
greener and has already taken several steps on this (see
https://www.ing.com/Newsroom/All-news/Reaction-to-National-Contact-Point-
complaint-about-ING-by-Greenpeace-BankTrack-Milieudefensie-and-Oxfam.htm for
several examples) but it is currently impossible to relate this to a 1.5C or 2C scenario.

In view of all this, ING believes that the complaint is i) impractical, ii) unnecessary and
iii) groundless.

i) Impractical, partly because at the moment the complainants request in the

complaint is technically simply impossible and partly because the implications and
feasibility of a 1.5C scenario are currently being examined by the international
community and the results are not expected before the end of 2018.
ii) Unnecessary, since the parties talk to each other regularly and at every level in
bilateral forums. There is no need to call in the good oces of the NCP.
iii) Groundless, given that in our opinion there is no breach of OECD guidelines as
explained in detail in INGs written response to the complaint submitted on 11
September 2017.

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