A company can show its best side in its policy, resulting in a good Nfi sustainability score. But experience shows that words and actions do not always match. If there are activities or behaviours that have a negative effect on people, the environment, or society, we look at how serious these effects are. For the purposes of our activities we distinguish between four levels of sustainability integration in companies: Traditional, Responsible, Sustainable and Impact. Violations of legal frameworks (such as the production of landmines or discrimination) always lead to exclusion. In the table below you can see which activities are excluded at each level of sustainability integration.
| Traditional (Traditioneel) | The legal restrictions on controversial weapons |
|---|---|
| Responsible (Verantwoord) | No controversial weapons, tobacco, or coal |
| Sustainable (Duurzaam) | No weapons, tobacco, coal, oil, non‑conventional gas, nuclear energy, alcohol, gambling, pornography or fur. |
| Impact | No weapons, tobacco, coal, oil, non‑conventional gas, nuclear energy, alcohol, gambling, pornography or fur. |
For other behavioural controversies (such as pollution or labour rights), it depends on how serious the controversy is. To assess the seriousness of this, we use the analyses from data provider Sustainalytics. Their scale runs from 0 to 5, where 5 is the score with the highest level of controversy. For our Responsible investment approach, we exclude companies with a controversy in the fifth category. For our Sustainable and Impact investment approaches, we also exclude companies that fall into category 4.
"}},{"componentType":"sectionTitle","title":"What you won't find in our strategies"},{"componentType":"paragraph","richBody":{"value":"In practical terms, this means that we exclude companies with structural violations of important laws and codes related to working conditions. This includes child labour, a ban on the right to form a trade union, forced labour, unfair pay or forced overtime, and the absence of decent working conditions. Exclusions may also apply in cases of discrimination and other fundamental human rights, as described in the Universal Declaration of Human Rights of the United Nations.
Because there is a real chance that companies active in countries with many human rights violations also become involved in these violations themselves, we exclude these companies in advance. Environmental pollution, convictions for corruption and animal cruelty also lead to exclusion, as do improper marketing methods, fraud, money laundering and cartel formation.
"}},{"componentType":"sectionTitle","title":"We look at the supply chain"},{"componentType":"paragraph","richBody":{"value":"Because many companies outsource work to other companies, Sustainalytics looks at the production chain for us. If controversies appear there, we hold the commissioning company responsible. In the clothing industry especially, there are examples of companies benefiting from child labour and poor working conditions by outsourcing production cheaply. In our view, a company is therefore also responsible for the behaviour of its suppliers. And this also applies to the behaviour of any subsidiaries and joint ventures.
"}},{"componentType":"sectionTitle","title":"Funds are not exempt"},{"componentType":"paragraph","richBody":{"value":"In addition to companies, we also assess investment funds on how much importance they give to people, the environment and society. Other fund managers often use different methods when they want to include sustainability factors in their investment choices. We aim to select funds that integrate sustainability in a way that is similar to our own approach.
"}},{"componentType":"sectionTitle","title":"Measure, the measure again"},{"componentType":"paragraph","richBody":{"value":"Because company policies can change and controversies can arise, we continue to assess companies on their policies, activities and behaviour to see whether they are still suitable for inclusion in our portfolios. We do this at least once a year, but of course we also follow the news and can react quickly. If a company no longer meets our standards, we remove it from our portfolios.
"}},{"componentType":"sectionTitle","title":"Encouraging improvement"},{"componentType":"paragraph","richBody":{"value":"Of course, we give companies the chance to improve their behaviour by themselves — we even prefer that. If no new controversies appear within three years and enough measures have been taken to prevent this from happening again, the exclusion can be reversed.
"}},{"componentType":"sectionTitle","title":"Read more"},{"componentType":"paragraph","richBody":{"value":"> Sustainable investing and SFDR: how does it work?
> ING's sustainable investment policy
Investing involves risks and costs. You may (partially) lose your investment amount. Read more about the risks of investing and how to limit them.
Visit ing.nl/ESG to see exactly how ING includes sustainability.
*This translation is intended for the customer’s convenience only. In the event of any inconsistency between the English translation and the original Dutch version, the original Dutch version shall prevail.
"}}]}}}