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At ING Luxembourg, we do not confine ourselves to ING funds. There is therefore no obstacle to subscribing to another financial institution's funds.

ING Luxembourg’s advisory management is ideal for you. Whether via Advisory Portfolio Management (APM) or the Financial Advisory Account (FAA), our specialists contact you to let you know the best market opportunities, while you make the decision to follow our advice or not.

The Sustainable Finance Disclosure Regulation (SFDR) is a European law that sets the definition of what sustainable investments are. This definition is given to avoid greenwashing in the financial industry and ensure that investors can adequately compare financial products (funds, portfolios etc.).

ESG is the acronym for Environmental, Social, and Governance that refers to the three key factors used to measure the sustainability and ethical impact of an investment, such as, but not limited to, climate change risks and impacts, biodiversity, human rights, anti-bribery and corruption.

The Taxonomy Regulation is a European law that basically serves as a “nomenclature” to define environmentally sustainable activities. This regulation was created to ensure that companies and investors speak the same language when talking about activities or investments that are “environmentally sustainable”.

As of 1^st January 2022, the SFDR definition of sustainable investments includes both social and environmentally sustainable investments (e.g., investments in a company that is involved in building schools in developing countries), while sustainable investments under the Taxonomy include only environmentally sustainable investments, which are defined in a stricter and more granular way. For example, the production of electricity through wind turbines can be a Taxonomy-aligned activity, provided that this production contributes to one environmental objective of the Taxonomy and does not harm any of the others (e.g., the wind turbines are not placed in a marine area where they could be interfering with the local biodiversity). The EU commission is currently working on the additional components of the Taxonomy to also include a definition of socially sustainable activities.

Principal Adverse Impacts are the negative impacts of a business activity on the environment or society. For example, a clothing company that uses chemicals to dye t-shirts and then releases the water used in the dying process in a river nearby, will cause the fishes in the river to absorb those chemicals, having a negative effect on their well-being. PAIs can be considered when investing (e.g., excluding certain harmful activities that have a negative impact on the environment and society).

The purpose of the ESG section of the investor profile’s questionnaire is to determine your sustainability (ESG) preferences, including Principal Adverse Impacts, Sustainable Investments and Taxonomy alignment to match these preferences with the characteristics of the products or instruments offered by the Bank. We will determine your initial sustainability preferences (or sustainability profile) through the answers given in the questionnaire, and we will store this information for current and future reference.

Our product offering (portfolios, funds and securities) is classified based on its sustainability level, which reflects our way of integrating ESG in our investment decisions. We have 4 different categories of products:

• Traditional: this category does not take into consideration ESG
• Responsible: this category takes into consideration ESG in a moderate way
• Sustainable: this category largely takes into consideration ESG
• Impact: This category has ESG as its main investment objective

Similarly, when answering the questionnaire, your sustainability preferences will be translated into TRSI profiles, based on their sustainability level.

We will use ESG data sourced from data providers (i.e., Morningstar and Sustainalytics) to assess the characteristics of the products we are offering to you. The data is used to classify products in the TRSI internal classification, based on internally set criteria. The TRSI products are then matched to your TRSI profile, which will be assigned to you based on a scoring methodology.

Yes. For some specific needs, you may find difficult to find a product matching your ESG preferences (government bonds, hedging products, classical trackers). In such a case, if you are a client benefitting from portfolio management or investment advisory services, we will analyse your portfolio globally to determine if it matches your ESG preferences (for more information see “What happens if there is no product that matches ma preferences?”). For instance, a Responsible portfolio can include up to 40% of traditional instruments.

When your sustainability preferences do not match with any product that we can offer, we will inform you and you will be able to discuss the available options with your advisor. This applies if you are a client benefitting from portfolio management or investment advisory services.

In order to classify our portfolios and instruments, we apply exclusions and best-in-class criteria (you can find all the details in our Responsible Investment Guidelines). Through this approach, we try to include, into the widest extent possible, sustainability in our investment approach and we screen companies and sectors that have a negative impact on the environment and society. Therefore, while some sectors with a negative impact could appear in our classification, we make sure that their impact remains marginal for instruments classified by us as Responsible or Sustainable. For example, you will not find a company that is heavily active in the coal sector in a Responsible or Sustainable mandate, but you could find a company that produces single use plastic.

Your investor profile will be reviewed and updated at least every 2 years. But, in case of mismatch, you will be able to review your preferences directly in the “Fiche Profile” to accept a contract (discretionary or advisory mandate) which is not aligned with your preferences. You will also be able to review your sustainability preferences whenever you want before the date of expiration of your investor profile. Please note that if this is the case, and you are benefitting from portfolio management or advisory services, we will have to review your mandate.

All the investment funds and ETFs will be analyzed thanks to an algorithm set-up by the Bank and based on MorningStar data. For equities or bonds, only the companies that are well-known to us and that we deal with on a regular basis will be classified into TRSI according to our methodology. All the other companies will automatically be classified as Traditional.

Yes, we have several policies related to ESG:

• Our Sustainability Risk Policy, which defines how we integrate sustainability risks in our investment decisions
• Our Principal Adverse Impact Statement, which defines the way we include Principal Adverse Impacts on sustainability factors in our investment decisions 
• Our Responsible investment Guidelines, which define the way we integrate sustainability in the management of our products and defines the internal TRSI classification criteria for portfolios

Your advisor is all able to guide you and suggest the most suitable product/mandate in case you are benefitting from portfolio management or investment advisory services.