CASE STUDY 2 ING ING is integrating nature aspects into its sustainability strategy, with the aim of complementing the existing Terra approach, which quantifies and sets science-based targets for key sectors in line with its climate goals. This environmental approach also considers social aspects, with the aim of working holistically across these interdependent factors. ING’s nature approach is aligned with its climate approach, with the aim to contribute to halting and reversing nature loss through: –Managing nature risks and impacts –Steering the portfolio and engaging with clients to halt and reverse nature loss –Promoting nature mainstreaming internally and externally Scoping: The first steps in ING’s approach included the assessment and scoping of the most material nature aspects within its portfolio. This assessment resulted in a list of industries with an expected high impact on nature in their operations and supply chains, high dependency on nature in their operations or high likelihood of having operations in countries with high significance to nature. Based on these insights, ING is first focusing on the most material sectors: farming and fishing, food and beverage processing, mining, and upstream oil and gas. Sector-specific assessment: ING engages with clients in high-impact sectors based on an analysis of key environmental factors affecting their sector. This includes assessing carbon emissions, land-use change (deforestation and conversion), water use, pollution and biodiversity/ ecosystems. To initiate client-level nature assessments, ING aims to collect publicly available data of clients in material sectors and assess a company’s baseline, ambition, targets, governance and implementation of mitigation actions towards nature. Building on the framework of its climate assessment approach, ING aims to use these nature assessments to strengthen client dialogue, identify and manage long-term risks and support clients in nature transition. Accountability: ING’s due diligence is applied through the Environmental and Social Risk (ESR) framework, which includes a standalone, cross-sectoral human rights policy. Additionally, ING takes a risk-based approach to assess the relevant deforestation and ecosystem conversion risks, based on a set of criteria as further detailed in its deforestation stance. These criteria aim to influence and encourage 1) no-deforestation and no-ecosystem conversion commitments, and 2) targets towards full traceability in supply chains. Additionally, through its ESR framework, ING also conducts relevant checks in its transactions to determine whether free, prior and informed consent (FPIC) has been obtained and labour rights respected. Measurement and monitoring: To quantify and monitor how ING’s financing activities impact and rely on ecosystem services, the bank applies varying levels of data granularity. Asset-level financing is subject to the Equator Principles, which prescribe detailed ecosystem and social analyses for transactions in scope. To link ING’s knowledge of monitoring ecosystems and drive best practice across all nature-related assessments, the bank is working closely with the Equator Principles and United Nations Environment Programme Finance Initiative (UNEP FI) through a range of initiatives. Scientific pathways and target setting: ING is developing knowledge on scientific pathways for key nature-related aspects, such as land-use change and water. Drawing on the work of the GBF, National Biodiversity Strategies and Action Plans (NBSAPs), Science Based Targets Network (SBTN), and Planetary Boundaries, ING is identifying sector-level nature pathways, which it is testing at a sector level. This will support how the bank steers its loan book in line with global goals for nature and guides the next steps in setting targets for nature. Nature Positive: Corporate Assessment Guide for Financial Institutions 22

Nature Positive Corporate Assessment Guide for Financial Institutions 2025