•
product initiatives implemented under PARP comply with the provisions
of commonly applicable laws and internal regulations,
•
the target client group for the products/services is clearly identified and
defined on the basis of commercial and risk assessment criteria and (if
applicable) in terms of sustainability preferences,
•
information about the product, target client groups, functionalities,
pricing, sustainability aspects, pilots, risks and exclusions is clearly
communicated and is clear to clients,
•
the bank does not use loopholes in the law to circumvent financial
reporting regulations or to avoid tax burdens, either for the bank or the
client – the bank’s products do not support the client in potential tax
evasion,
•
the bank does not use clauses considered to be abusive in its regulations
and agreements concluded with clients,
•
information is provided to clients in a fair, clear and comprehensive
manner, presenting all product features of relevance, in particular the
conditions of use and the related costs and potential financial risks for
the client,
•
the bank complies with the requirements set out in the Golden Rules of
Client Service,
•
the bank does not infringe the principles of fair competition, in particular
by using unreliable or misleading advertising,
•
the bank subjects the products offered to periodic reviews.
Golden Rules of Client Service
The Golden Rules of Client Service are a set of overarching principles that
guide our dealings with our clients, i.e.:
•
we offer products and services that are suitable for clients throughout
the life cycle of the relationship,
•
we offer products and services at a fair price taking into account the
market situation, costs and risks,
•
we provide information on products and services in a clear and not
misleading manner,
•
we provide services and trusted advice (where consultancy is provided)
through professional staff with the necessary knowledge,
•
we take into account the Environmental, Social and Governance (ESG)
risks and impacts of our products and services.
Guidelines for setting fair prices
In addition, we have set fair pricing guidelines to support our pricing
decisions:
•
price levels are considered fair if they are consistent with client
expectations and market practice,
•
price levels may vary depending on the client’s relationship with the
bank, taking into account risk, costs and profitability,
•
discounts are allowed if the conditions are transparent and applied in a
consistent manner,
•
campaign promotional prices should avoid undesirable effects on price
positioning for the ING brand.
The role of management bodies in responsible product offering
The implementation of a new product or significant changes is carried out
following a mandatory decision by the relevant standing product
committee appointed by the Bank Management Board.
Those are:
•
Retail Product Committee,
•
Corporate Products and Financial Markets Committee, and
•
Credit Policy Committee for credit products.
In terms of price changes, decisions are made:
•
Retail Price Committee,
•
Pricing Committee for Business Clients.
The primary objective of the product committee, as a decision-making body
in the PARP process, is to create an optimal portfolio of retail and corporate
banking products (including bancassurance products) and financial markets
products.
The tasks of such a committee include:
•
making, while ensuring compliance with the Golden Rules for clients,
decisions on:
•
the implementation of a new product, including a new activity,
including a new distribution channel related to a new or existing
product,
•
a significant change to a process and/or system, product-related
platform, including:
•
the implementation of a new process or a significant change in
the redesign of an existing process/product resulting in an
increase in risk, including operational, legal, compliance risks,
•
the implementation of a new or substantial modification of an IT
resource, including in the case of an external provider of such an
IT resource or service, related to new/altered products or
new/altered activities,
•
the introduction of new regulations, binding on the client and the
bank, e.g. regulations, contracts,
•
the liquidation of the product or its withdrawal from the offer,