Stewardship at ING’s 2025 AGM: Climate Commitments, Biodiversity Challenges, and Activist Disruptions

On April 22, 2025, PGGM participated in the Annual General Meeting (AGM) of ING Groep N.V. During the meeting, we raised questions on ING’s climate and biodiversity strategies and the bank’s positioning within sectoral alliances such as the Net-Zero Banking Alliance (NZBA).

Linking climate ambition to remuneration
As part of our first question, we welcomed ING’s achievement of Science-Based Targets initiative (SBTi) validation for its Scope 1, 2, and 3 climate targets. This is a material milestone demonstrating that ING's ambitions are in line with a 1.5°C pathway. However, we questioned why ING has not yet established a direct link between its Scope 3 or total CO₂ reduction targets and variable executive remuneration. Incorporating such targets into remuneration frameworks is an essential mechanism to embed climate ambition into the bank’s strategic and operational core.

In response, ING’s CEO indicated that climate considerations are already embedded in variable pay structures, particularly through the objective of supporting the transition of wholesale banking activities — where most scope 3 emissions originate. Nonetheless, the formulation remains relatively high-level and qualitative. More explicit and measurable integration of Scope 3 targets into executive remuneration would send a stronger and clearer signal to the market regarding strategic alignment and accountability.

ING’s positioning following changes in the NZBA
Given recent developments within the Net-Zero Banking Alliance, including the softening of the overarching ambition from strict 1.5°C alignment to “well below 2°C,” we asked ING to clarify its own position.

The CEO confirmed that ING remains fully committed to its independently validated 1.5°C targets, irrespective of changes within the alliance. He emphasized that while the NZBA initially served as a platform to foster Paris-aligned commitments, ING now steers its course based on its own targets, viewing the alliance primarily as a forum for best practice sharing rather than for target setting.

We welcome this clarification. In the current landscape, where reputational risks around "net-zero" claims are growing, adherence to a 1.5°C pathway is vital for maintaining stakeholder trust.

Advancing ING’s biodiversity approach
Biodiversity was another key topic we addressed. ING’s 2024 double materiality assessment recognizes biodiversity as a material issue. Nonetheless, at present, no quantitative biodiversity targets have been established, with the CEO noting that suitable sector-wide methodologies are still under development.

While we appreciate the complexity of biodiversity measurement for financial institutions, we stressed the importance of progressing beyond recognition toward action. Setting preliminary indicators, even amid evolving standards, would demonstrate leadership and allow for more structured engagement with clients on nature-related risks and dependencies.

We note positively that ING is working with peers to co-develop frameworks. However, we continue to encourage the bank to pursue interim steps that can enhance transparency and guide future target-setting efforts.

Activism at the AGM
The AGM was interrupted several times by climate activist groups, whose protests focused on ING’s fossil fuel financing and its broader role in the energy transition.

Although such disruptions can be challenging during formal shareholder meetings, they highlight the intensifying public scrutiny of financial institutions' environmental and social impacts.

From PGGM’s perspective, this underscores the importance of credible, science-based sustainability strategies and transparent reporting. Societal expectations are rapidly evolving, and constructive engagement between shareholders and companies remains crucial in navigating these dynamics.