ESG management in ING Bank Śląski S.A.
Sustainability management within the ING Bank Śląski Group involves the Bank’s Management Board, the Supervisory Board, as well as senior management. In addition, dedicated committees and teams have been established to further develop this area and to implement sustainability principles across the entire capital group.
Organizational management structure in the area of sustainability
The Supervisory Board and the Management Board approve the business strategy objectives, which incorporate sustainability goals.
Within the Bank’s organizational structure, two committees operate: the ESG Council and the ESG Risk Committee.
These committees have decision‑making authority over all organizational units of the Bank, as well as an advisory role to the Management Board in matters requiring its approval.
ESG Risk Management
The Management Board of our bank, the Supervisory Board and the management staff emphasize the issue of risk and opportunity identification and ESG risk management in the bank.
To advance the ESG Priorities, we have established the ESG Programme and the ESG Data Model.
A range of organisational units across the bank are engaged in the implementation of the ESG Priorities.
Sustainability Panel
From Q4 2024 the Sustainability Panel operates at the Supervisory Board level, which has a consulting and advisory function as part of supervisory activities. The purpose of the Panel meetings is to provide regular updates, inspire and initiate discussion at the Supervisory Board level on various ESG areas, including but not limited to the following:
- ESG strategy – the sustainability goals and priorities, including the monitoring of progress in their implementation.
- ESG matters management.
- Promoting engagement in ESG matters (development of ESG culture in the organisation); embedding ESG in the business strategy and operational activities.
- Sustainability disclosures and reporting and ensuring compliance with the applicable laws.
ESG Council
The Committee oversees the progress and consistency of ESG- and sustainability-related activities and communication across the organisation.
The Committee’s responsibilities include, but are not limited to, the following:
- approval of the ESG Strategy as well as activities and measures of the implementation of strategic goals,
- monitoring the progress of actions and the achievement of ESG Strategy objectives, including work carried out under the ESG Program.
The ESG Council is chaired by the President of ING Bank Śląski, and its members include the entire Management Board as well as the leads/directors of areas that have the greatest impact on the implementation of ESG objectives.
The ESG Council meetings are held approximately once every quarter.
ESG Risk Committee
The main tasks of the ESG Risk Committee include: developing the ESG risk management policy; approving the ESG risk management methodology; approving the tools used for the ESG risk assessment; defining the standards of ESG risk credit analysis and of the process of ESG risk assessment and monitoring, as well as the rules for taking ESG risk into account in collateral valuation.
ESG Risk Management
In accordance with the approach presented in the ECB Guide on climate-related and environmental risks 2020 and the EBA Report on management and supervision of ESG risks for credit institutions and investment firms 2021, our bank does not treat ESG risk as a separate risk category, but as a factor reinforcing basic risk categories (credit risk, market risk, liquidity risk and financing risk, as well as non-financial risk).
We define ESG risk as the risk of a negative financial impact on the bank arising from ESG factors - either directly or indirectly (indirectly through their impact on the bank’s clients and counterparties).
We manage ESG risk by integrating mechanisms for its identification, measurement, assessment, mitigation, monitoring and reporting into standard processes within credit risk, market risk, liquidity and funding risk, and non‑financial risk management.
Given the unique nature of this risk - including the expectation that its materiality will increase over time - the bank has adjusted its organisational structure to ensure effective management, oversight, and adequate intensity of work related to the implementation of ESG risk management mechanisms.
The ESG Risk Management Policy
The ESG Risk Management Policy (ESG Policy) is a comprehensive framework designed to define how the bank manages ESG risk within the services we provide - at portfolio and sub‑portfolio levels, as well as at the level of individual clients and transactions. The Policy applies to the Retail Clients, Business Banking and Wholesale Banking areas, covering both credit and non‑credit products and services.
In addition, the ESG Policy:
- defines how the ESG risk management process is embedded within the existing frameworks for credit risk, market risk, liquidity and funding risk, and non‑financial risk;
- describes how ESG risk information generated through the risk management process is reported and used as a basis for decision‑making at all organisational levels of the bank.
The scope of the ESG Policy includes, among other elements, key ESG risk definitions, the nature and characteristics of ESG risk, ESG risk factors and transmission channels, and their impact on traditional risk types. The document also outlines the ESG risk governance structure, specifying the roles of the bank’s governing bodies and organisational units. It describes ESG risk management, including physical and transition risks:
- At portfolio level: processes for identifying, assessing, monitoring and reporting ESG risk, key metrics, targets and the ESG risk appetite, methods, standards, tools and data used for ESG risk management within credit risk.
- At client and transaction level: within the KYC (Know Your Customer) process and the credit process.
The document also explains how ESG risk is managed within market risk, liquidity and funding risk, operational risk and compliance risk, and outlines the relevant ESG risk control objectives.
ESG Transformation Program
The Programme members include individuals from various units (representatives of key areas, including business lines, risk, finance, HR, operations, compliance and subsidiaries) who are involved in the implementation of strategic ESG priorities.
The Steering Committee of the ESG Programme controls the status of the goals set as part of the individual priorities. The outcomes of the activities taken as part of the ESG Programme are reported to the ESG Council.