Thank you for the engagement letter sent by the BHRRC and for your continued work in monitoring the global business and human rights landscape. The ‘Digging in the Shadows’ report highlights some serious concerns across extractives projects in Eastern Europe and Central Asia. The research is much appreciated.

On a note of policy, ING is guided by our Environmental and Social Risk (ESR) Framework. Within this framework, the overarching Human Rights Policy, the Climate Policy and the Sector Specific Polices apply to clients and projects we finance. One example of an expectation under the ESR Framework is that all energy sector or mining sector clients should have policies or certification in place to address their unique sector risks, including human rights and environmental risks...

As per our due diligence trajectory, if we do not gain satisfactory information or comfort from engagement with clients, we then decide a course of action. You can read more about our engagement trajectory on page 72 of our first ING Human Rights Report. We are not able to disclose the nature of the specific dialogues with clients, but please be informed that we take client controversies seriously and engage and take action where needed. We do disclose case studies regularly to share with our stakeholders in our annual reports and dedicated human rights reports...

• Lydian Armenia: ING has had ongoing engagement with the client since we began our relationship. We have engaged on environmental and social risks, as well as issues raised by civil society. ING made sure we were comfortable with financing the client by following our own due diligence process, for example by reviewing impact assessments; engaging independent consultants; and asking the client specific questions on risks found...
• KazMunaiGas: KazMunaiGas JSC is no longer a client of ING. We therefore have very limited leverage with this entity.
• Tengizchevroil: INGs relationship with this client began in 2016, where we conducted our due diligence by relying on information available in environmental and social action plans and monitoring reports. Many of the public allegations with this client date years before ING involvement...