As a signatory of the Principles for Responsible Investment (PRI), the ING group is intent on positioning itself as a key player in the sphere of sustainable investment products. We are aware that financial services play an important role in creating a responsible and sustainable world, and we want to contribute to this at ING Luxembourg with our investment solutions.

Since March 2021, the SFDR [1] has required financial institutions to provide investors with very precise information on the “sustainable” nature of their products to prevent all types of investments from being wrongly classified as “green” or “sustainable” (greenwashing).

[1] Regulation of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector

In this context, ING distinguishes betwen four invesment approaches:

  • the “traditional” approach: in principle, this does not incorporate or promote ESG (Environment, Social, Governance) criteria.
  • the “responsible” approach: with the objective of promoting certain ESG criteria by setting minimum standards that selected products or companies must comply with in terms of adverse effects on the environment and society.
  • the “sustainable” approach: with the objective of promoting investment in companies with certain sustainable commitments and which do not provide products and services that can have a significant adverse impact on the environment and society.
  • the “Impact” approach: with the objective of mitigating adverse effects and contributing positively to the environment and society, by investing in companies with sustainable activities or products with a sustainable investment objective.

ESG criteria: definition

The majority of funds that incorporate an ESG strategy seek to contribute to the achievement of the 17 sustainable development goals defined by the United Nations:

To achieve these goals, sustainability strategies base their investment process on an analysis of the extra-financial variables below, in addition to traditional financial svariables (valuations, cmpany balance sheet quality, etc.):


  • Air, water and ground pollution
  • Greenhouse gases emissions
  • Energy use and efficiency
  • Raw materials consumption
  • Transportation
  • Water and waste management
  • Biodiversity and its protection
  • Lifecycle impacts


  • Net social utility
  • Working conditions, health & safety
  • Diversity programmes
  • Retention
  • Human righty
  • Relationships with stakeholders (unions, NGOs, communities, etc.)
  • Supply chain management
  • Materials sourcing
  • Product safety and quality
  • Customer relationships


  • Culture and ethics
  • Shareholder rights
  • Audit and accounting
  • Corruption and bribery
  • Board and Board Commitee characteristics
  • Board member competence
  • Independance
  • Compensation
  • Risk management
  • Transparency
  • Regulatory capture

Adverse Impact

In addition to the incorporation of ESG criteria, ING also takes into account the adverse impacts that certain financial products or companies may have on the environment and society. These products or companies may be excluded from our universes or our investment recommendations because they are considered counterproductive to the desired objective.

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