ING Group

ESR Risk Framework:
Where such local legislation and regulations do not fully incorporate the Five Animal Freedoms, we encourage them to comply with the following standards:
a) Conduct animal management in line with the “Five Animal Freedoms”

Comments on score: The bank encourages, but does not require, companies to fully incorporate the five freedoms

(…) we encourage them (clients) to comply with the following standards:
c) Housing/husbandry/farming conditions: Housing systems must support animals’ natural behaviour and needs with respect to movement, rest and social habits. The housing system must protect the animals from injury and distress. All housed animals must have access to sufficient feed, water, air and darkness/light. Temperature has to be controlled at all times;

Comments on score: Clients are encouraged not to use cages, but they are not forbidden

ESR Risk Framework:
(…) we encourage them (clients) to comply with the following standards:
c) Housing/husbandry/farming conditions: Housing systems must support animals’ natural behaviour and needs with respect to movement, rest and social habits. The housing system must protect the animals from injury and distress. All housed animals must have access to sufficient feed, water, air and darkness/light. Temperature has to be controlled at all times;

Comments on score: Adequate environmental conditions are required, but little detail is provided about minimum requirements

ESR Risk Framework:
(…) we encourage them (clients) to comply with the following standards:
f) Stewardship: Entities owning or keeping animals must safeguard their welfare by preventing any unnecessary pain, suffering or injury;
g) Health and disease: Animals’ health must be assessed by a licensed veterinarian or professional with the requisite skills and authority;
(…)
ING encourages its clients to seek continuous improvement, certification (where applicable) and best practices in environmental, health and safety and animal welfare management. These best practices include the principles expressed in:
- The International Finance Corporation (IFC) Good Practice Note: Improving Animal Welfare in Livestock Operations.

Comments on score: The policy does not cover this criterion, but generally encourages alignment with the IFC Good Practice Note.

ESR Risk Framework:
h) Genetics and breed selection: Selection of breeds has to take into account animal welfare principles as well as production objectives;

Comments on score: The policy does not cover this explicitly, but it does encourage clients to follow best practices, including those described by the IFC good practice note, which covers this.

ESR Risk Framework:
(…) we encourage them (clients) to comply with the following standards:
d) Transportation: Animals shall be transported in an efficient manner that minimises distress. They shall not be transported over excessively long distances. During transport, animals must be fed and watered with appropriate frequency;

Comments on score: The policy does not limit transports to 8h

ESR Risk Framework:
(…) we encourage them (clients) to comply with the following standards:
j) Slaughtering: Animals must be handled and slaughtered in the least distressing and most pain-free manner possible.
(…)
Restricted activities:
- Use of dynamite or poison to catch marine and freshwater species and shellfish in the wild;
- Shark finning or commercial whaling;

Comments on score: covered

ESR Risk Framework:
ING encourages its clients to seek continuous improvement, certification (where applicable) and best practices in environmental, health and safety and animal welfare management. These best practices include the principles expressed in:
- The Access online: OIE - World Organisation for Animal Health of the World Organisation for Animal Health, including recommendations related to trade and logistics of animals (e.g. health requirements, veterinary certificates and vaccines, quarantine stations);
- The International Finance Corporation (IFC) Good Practice Note: Improving Animal Welfare in Livestock Operations.
- ISO 14000 and 14001 environmental management standards and OHSAS 18001, the occupational health and safety management system.
We recognise that standards might differ between regions, and that there might be local certification that is comparable to those mentioned above. Certificates and standards are considered to be strong by ING if they are:
- Internationally or regionally recognised;
- Independently reviewed; and
- Preferably, verified by a multi-stakeholder body.

Comments on score: Certification is encouraged, but not required. Certification can be, but is not always, a proxy for independently audited reports.

ESR Risk Framework:
(…) we encourage them (clients) to comply with the following standards:
h) Hormones and antibiotics: Use of hormones and antibiotics on animals must comply with all applicable national laws and specific requirements. Antibiotics meant for human purposes are not to be used for animals in food production;

Comments on score: The policy sets some restrictions for the use of antibiotics, but does not prohibit their use on healthy animals.

not covered

Comments on score: not covered

ESR Risk Framework:
Restricted activity:
- Use of endangered species or non-human primates for all testing/experimental purposes. Non-human primates are defined as animals with genetic proximity to human beings and highly developed social skills, such as apes (e.g. gorillas and chimpanzees) and monkeys;
- Animal testing for non-medical purposes. Cosmetic purposes relate to activities that aim for substances for beauty or hygienic purposes;

Comments on score: Testing for non medical purpoes is excluded from finance

ESR Risk Framework:
Restricted activity: Use of endangered species or non-human primates for all testing/experimental purposes. Non-human primates are defined as animals with genetic proximity to human beings and highly developed social skills, such as apes (e.g. gorillas and chimpanzees) and monkeys ;
(…)
(…) we encourage them (clients) to comply with the following standards:
b) Where animals are used in medical research laboratories for the advancement of human health, the principles of the 3Rs - Replacement, Reduction and Refinement, providing a framework for human research on animals - should be applied.
1) Replacement refers to methods of utilising cells, tissues or organs of animals (relative replacement and those that do not require the use of animals to achieve the scientific aims (absolute replacement);
2) Reduction refers to methods that enable researchers to obtain comparable levels of information from fewer animals or obtain more information from the same number of animals;
3) Refinement refers to methods that prevent, alleviate or minimise pain, suffering, distress or lasting harm and/or enhance welfare for the animals. Refinement includes the appropriate selection of relevant species with less structural and functional complexity in their nervous systems and a lesser apparent capacity for experiences that derive from this complexity.
i) Animal welfare when used in the laboratory for human health purposes: Animal experiments must only take place if there is no appropriate alternative method available that avoids the use of animals. Animals involved must be those with the lowest degree of neurophysiological sensitivity and consciousness consistent with experimental objectives;

Comments on score: The bank sets requirements for medical testing, including the 3Rs.

ESR Risk Framework:
Restricted Activity: Genetic engineering or genetic modification on animals for non-medical purposes. Selective breeding is not considered a form of genetic engineering

Comments on score: Genetic modification of animals is excluded for non-medical purposes

ESR Risk Framework:
Restricted activity:Fur farms, manufacturing or trade in fur products;

Comments on score: Activities relating to fur are excluded from finance. The policy does not explicitely address leather though.

ESR Risk Framework:
Restricted activities
- Trades involving endangered species for commercial purposes. Endangered species are listed in (i) the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) and (ii) the IUCN Red list of Threatened Species;

Comments on score: The policy excludes the trade in endangered animals , but does not exclude the trade in non threatened wild animals.

ESR Risk Framework:
Where such local legislation and regulations do not fully incorporate the Five Animal Freedoms, we encourage them to comply with the following standards:
a) Conduct animal management in line with the “Five Animal Freedoms”:

Comments on score: The policy does not cover this criterion specifically, but in general requires the five freedoms to be respected

ESR Risk Framework:
Restricted activity: Animal fights for entertainment;

Potential risks (…) include: Mistreatment: especially relating to animals kept in zoos or used in shows like circuses, rodeos, horse shows, dog shows, dolphinariums and aquatic parks (…)

Comments on score: The policy only restricts animal fights for entertainment, but not other activities involving animals

ESR Risk Framework:
(…) the following types of evaluation are encourages:
- The client’s primary supply base and countries of origin;
- A sourcing policy of the client that selects and maintains suppliers based on environmental, social and corporate governance (ESG) criteria relevant for the industry;

Comments on score: The policy states that the bank does assess the supplier policies of its clients, but it does not explicitly require them to include animal welfare criteria into them

ESR Risk Framework:
ING Bank procurement
All ING procurement activities are subject to the Global Procurement Bank’s (GPB) Procurement policy. The Procurement policy states that ING only engages with suppliers that have completed the Know Your Supplier/Supplier Qualification (SQ) process, which includes criteria aligned with the ESR Framework.

Comments on score: ING requires its suppliers to align with its ESR risk framework, which includes animal welfare criteria.

ESR Risk Framework:
If the ESR assessment outcome is “increased risk”, (…):
- additional environmental and social-related loan covenants may be conditioned to these clients.

Comments on score: ING does include conditions on loan covenants if clients are involved in animal welfare and the engagement process is not satisfactory.

Annual report apendixes
Annual Report Appendixes contain report on outcomes of engagement with clients on ESG issues, including animal welfare

Comments on score: ING does include conditions on loan covenants if clients are involved in animal welfare and the engagement process is not satisfactory.

That is why our responsibility is to use our financing, advisory products and services to actively support clients transition to new sustainable business models that will ensure their success in the future. As a financial institution, we can play a role by financing change, sharing knowledge and using our influence.

Comments on score: The bank does have transition finance products, however, food systems and animal welfare are not mentioned