Executive Summary
ING Group’s €1.1 billion share buyback programme, announced in October 2025, represents a significant capital allocation decision by one of Europe’s leading financial institutions. As of December 19, 2025, the programme is 31.35% complete, with over €344 million deployed to repurchase approximately 15.4 million shares. This case study examines the strategic rationale, execution methodology, market implications, and specific impact on Singapore’s financial ecosystem.
Case Study: Strategic Context and Execution
Background and Strategic Rationale
ING Group, a global financial institution with over 60,000 employees serving customers in more than 100 countries, initiated this share buyback as part of a broader capital management strategy. The decision reflects several key considerations. First, the bank likely determined it has excess capital beyond regulatory requirements and operational needs, making share repurchases an efficient way to return value to shareholders. Second, with the shares trading at prices management may view as undervalued, the buyback serves as a signal of confidence in the bank’s intrinsic worth. Third, by reducing share count, the programme enhances earnings per share metrics, potentially making the stock more attractive to investors even if absolute earnings remain constant.
The timing of this announcement in October 2025 suggests ING’s management believes the bank has reached a stable operational footing with predictable cash flows, allowing it to commit substantial capital to shareholder returns rather than retaining it for growth investments or risk buffers. The substantial size of €1.1 billion indicates this is a material strategic initiative rather than a token gesture.
Execution Methodology and Progress
The programme demonstrates disciplined execution. During the week of December 15-19, 2025, ING repurchased 1,974,051 shares at an average price of €23.54, spending approximately €46.5 million. This weekly purchase volume represents roughly 0.13% of the total programme value, suggesting a measured approach designed to avoid artificially inflating share prices through aggressive buying.
Notably, the recent average purchase price of €23.54 exceeds the programme-to-date average of €22.43, indicating a 4.95% price appreciation since the buyback commenced. This price increase could reflect multiple factors: general market appreciation, positive investor sentiment about the buyback itself, or improved fundamental performance by ING during this period. The willingness to continue purchases at higher prices demonstrates management’s conviction in the programme’s value proposition.
The completion rate of 31.35% after approximately seven weeks suggests ING is on track to complete the full programme over a six to seven month period, though the pace may vary based on market conditions, regulatory trading windows, and internal assessments of optimal pricing.
Financial Impact on ING
The share buyback creates several quantifiable effects on ING’s financial structure. By reducing the outstanding share count, the bank increases earnings per share (EPS) assuming net income remains stable. With approximately 15.4 million shares repurchased from what was likely a base of several billion shares outstanding, the EPS enhancement may be modest in the short term but accumulates significantly over the full programme.
The buyback also impacts ING’s capital ratios. While it reduces absolute capital through the cash outflow, it simultaneously reduces risk-weighted assets if the repurchased shares were previously counted in certain capital calculations. The net effect depends on ING’s specific capital structure and regulatory framework, but management evidently determined the bank would maintain adequate buffers above minimum requirements.
Return on equity (ROE) typically benefits from buybacks as the equity base decreases while earnings capacity remains intact. This can make the bank appear more efficient in generating returns for remaining shareholders. However, critics note this represents financial engineering rather than operational improvement.
Market Reception and Signaling Effects
Share buybacks serve as powerful signals to the market. By committing €1.1 billion to repurchases, ING’s management explicitly states their belief that investing in their own stock offers better returns than alternative uses of capital such as acquisitions, technology investments, or simply holding cash. This signal can be particularly valuable in the banking sector, where management often has superior information about asset quality, loan performance, and future earnings potential compared to outside investors.
The sustained execution at progressively higher prices reinforces this signal. If management believed the shares had become overvalued, they might slow or pause the programme. Instead, the consistent weekly purchases indicate ongoing confidence even as the share price has appreciated.
Outlook: Future Implications and Scenarios
Short-Term Outlook (Next 3-6 Months)
Over the immediate term, ING will likely complete the remaining 68.65% of the buyback programme, requiring approximately €755 million in additional purchases. If the bank maintains the recent weekly pace of €46.5 million, completion would occur in roughly 16 additional weeks, or early April 2026. However, several factors could alter this timeline.
Market volatility could prompt ING to accelerate purchases if share prices decline, allowing them to acquire more shares for the allocated capital. Conversely, rapid price appreciation might lead to a temporary pause or slower pace. Regulatory considerations, such as blackout periods around earnings announcements, will also influence the weekly purchase volumes.
The continued reduction in share count will gradually enhance per-share metrics, potentially attracting value investors and index funds that screen for improving EPS trends. This incremental demand could provide modest support for the share price, creating a reinforcing cycle where the buyback itself helps validate the buyback decision.
Medium-Term Outlook (6-18 Months)
Following programme completion, ING’s management will face a critical decision: return to normal dividend payments alone, or announce a subsequent buyback programme. This decision will depend on several evolving factors including the European banking sector’s overall health, regulatory capital requirements, ING’s organic growth opportunities, and the prevailing interest rate environment.
If the European Central Bank maintains relatively tight monetary policy through 2026, banks like ING may continue generating strong net interest margins, producing excess capital that could fund additional buybacks. The precedent set by this €1.1 billion programme suggests management views buybacks favorably as a capital allocation tool, increasing the probability of future programmes.
The bank’s ESG ratings, including its AAA rating from MSCI and strong Sustainalytics assessment, position it well for continued access to capital markets. However, there may be growing scrutiny from stakeholders who prefer to see capital deployed toward sustainable lending and green finance initiatives rather than shareholder returns. Management will need to balance these competing priorities carefully.
Long-Term Outlook (2-5 Years)
Over the longer horizon, ING’s capital allocation strategy will likely evolve based on the structural transformation of European banking. Several mega-trends will influence whether buybacks remain a preferred tool. First, the transition to digital banking and fintech competition may require substantial technology investments, potentially absorbing capital that might otherwise fund buybacks. Second, the push toward sustainable finance may create attractive lending opportunities in renewable energy, green infrastructure, and climate transition projects, offering better risk-adjusted returns than buybacks.
Third, regulatory frameworks continue to evolve. If Basel IV or subsequent accords impose stricter capital requirements, banks may need to retain more capital, constraining buyback capacity. Conversely, if regulators become more comfortable with banks’ resilience, they might permit more aggressive capital returns.
The long-term share price trajectory will depend primarily on ING’s ability to grow intrinsic value through profitable lending, fee generation, and operational efficiency rather than on buybacks alone. However, the discipline demonstrated in this programme suggests a management team focused on shareholder value creation, which should benefit long-term investors regardless of specific capital allocation choices.
Solutions: Strategic Recommendations
For ING Group Management
ING should consider several enhancements to maximize the effectiveness of this and future buyback programmes. First, improve communication with investors by providing more detailed quarterly updates on buyback progress, including analysis of how the programme has affected key metrics like EPS, ROE, and book value per share. This transparency helps investors better assess the programme’s value creation.
Second, develop a systematic framework for deciding between buybacks and dividends based on quantifiable criteria such as share price relative to book value, available capital above regulatory minimums, and organic growth investment opportunities. This framework should be communicated to investors to set clear expectations.
Third, implement dynamic programme adjustments based on market conditions. Rather than executing buybacks mechanically at a fixed pace, ING could increase purchases during market corrections when shares are cheaper and reduce them during rallies. This requires discretion in the programme authorization to allow management flexibility.
Fourth, consider employee stock ownership programs that align employee interests with shareholder value creation. Buybacks reduce share dilution from employee stock compensation, but direct ownership programmes can enhance this alignment further.
Fifth, enhance ESG integration by explicitly linking capital allocation decisions to sustainability metrics. For example, ING could commit to maintaining buyback capacity only if it meets certain green lending growth targets, demonstrating that shareholder returns and sustainability objectives are complementary rather than competing.
For Singapore-Based Investors
Singaporean institutional and retail investors holding ING shares should evaluate several action items in response to this buyback. For long-term holders, the programme generally represents positive news, as it should support share price and improve per-share metrics. However, investors should monitor whether the buyback is funded by excess capital or if it strains the bank’s financial flexibility.
Investors should compare ING’s capital return approach to peer banks such as DBS, OCBC, and UOB, which typically favor dividends over buybacks. The relative merits depend on individual tax situations, as Singapore’s tax exemption on foreign dividends makes dividend-paying stocks attractive, while buybacks offer potential capital gains.
For portfolio managers, the buyback may warrant adjusting position sizes. If ING’s weight in a portfolio has grown due to price appreciation from the buyback, rebalancing may be appropriate. Conversely, if the buyback signals undervaluation, increasing exposure could be justified.
Investors should also assess currency risk. With the buyback denominated in euros but Singapore-based investors potentially holding shares in SGD equivalent, exchange rate movements between EUR/SGD could significantly impact returns. The euro has experienced volatility against Asian currencies, and this risk factor deserves careful consideration.
For Singapore’s Financial Sector
Singapore’s banking sector can extract valuable lessons from ING’s approach. DBS, OCBC, and UOB have historically favored dividends, maintaining high payout ratios that appeal to income-seeking investors. However, share buybacks offer advantages in certain circumstances, particularly when shares trade below intrinsic value or when banks want to offset dilution from employee stock plans.
The Monetary Authority of Singapore (MAS) could consider whether current regulations optimally balance bank stability with shareholder-friendly capital return policies. If Singapore banks face more restrictive capital return constraints than European peers, this could affect their relative valuations and attractiveness to international investors.
Singapore’s wealth management industry should educate clients on the different implications of buybacks versus dividends. Many Singaporean investors have strong preferences for dividend income, but buybacks can be economically equivalent or superior depending on tax treatment and future capital needs.
Long-Term Solutions: Structural Recommendations
Enhancing Shareholder Value Creation
For ING to maximize long-term value from capital management strategies, several structural solutions deserve consideration. The bank should establish a formal capital allocation committee that systematically evaluates competing uses of capital quarterly, including organic growth investments, acquisitions, dividend payments, and share buybacks. This committee should use rigorous financial modeling to project the long-term value creation of each option under various scenarios.
The bank could implement a progressive capital return policy that automatically increases shareholder returns as capital ratios exceed certain thresholds. For example, if Common Equity Tier 1 (CET1) ratios exceed regulatory minimums by specified margins, the excess could trigger mandatory shareholder distributions through either dividends or buybacks. This approach provides predictability for investors while maintaining prudent capital buffers.
ING should develop sophisticated valuation models that incorporate real-time market data to identify optimal buyback timing. Machine learning algorithms could analyze patterns in share price movements, trading volumes, volatility, and macro factors to recommend when to accelerate or pause buyback activity. This data-driven approach could significantly enhance returns from buyback programmes.
Regulatory and Governance Framework
From a governance perspective, ING should strengthen independent board oversight of capital allocation decisions. While management naturally focuses on operational metrics, independent directors can provide perspective on whether capital returns are excessive or insufficient relative to peer banks and long-term strategic needs. Enhanced board-level capital committees could review buyback programmes quarterly, adjusting parameters based on evolving conditions.
European banking regulators should consider harmonizing capital return policies across jurisdictions to create a level playing field. Currently, banks in different European countries face varying restrictions on buybacks and dividends, potentially creating competitive distortions. Consistent rules would allow investors to better compare banks on an apples-to-apples basis.
Regulators could also mandate standardized disclosure requirements for buyback programmes, ensuring all banks report consistent metrics such as average purchase price, volume-weighted average price relative to market prices, and detailed reconciliations of how buybacks affect capital ratios. This transparency would enhance market efficiency.
Integration with Sustainability Goals
A critical long-term solution involves better integrating capital allocation with sustainability objectives. ING has strong ESG credentials with its AAA MSCI rating and commitment to financing the transition to a low-carbon economy. However, large capital returns through buybacks could face criticism from stakeholders who believe these funds should support green lending.
ING could pioneer a “conditional capital return” framework where buyback programmes are sized based on meeting sustainability metrics. For example, if ING achieves targets for reducing financed emissions or increasing renewable energy lending, it could authorize proportionally larger buybacks. This links shareholder returns to ESG performance, aligning diverse stakeholder interests.
The bank should publish integrated capital allocation reports that explicitly show trade-offs between shareholder returns, sustainable finance growth, technology investments, and capital buffer maintenance. This transparency helps stakeholders understand that buybacks don’t necessarily come at the expense of other priorities but rather represent optimal allocation of genuinely excess capital.
Technology and Innovation Investment
While buybacks return capital to shareholders, ING must simultaneously invest heavily in technology to remain competitive. The rise of digital banking, blockchain-based services, artificial intelligence for credit decisions, and fintech partnerships requires substantial capital. A long-term solution involves ring-fencing a portion of profits for mandatory technology investment before considering capital returns.
ING could establish innovation hurdle rates where if the bank identifies technology investments exceeding a certain return threshold, these automatically take priority over buybacks. This ensures the bank doesn’t buy back shares while forgoing high-return digital transformation opportunities.
The bank should develop internal venture capital capabilities to invest in fintech startups and emerging technologies. These strategic investments could generate returns exceeding those from buybacks while building capabilities and partnerships essential for long-term competitiveness. Capital allocated to strategic innovation might deserve different treatment than excess capital returned to shareholders.
Impact on Singapore: Comprehensive Analysis
Impact on Singapore-Based ING Shareholders
Singapore hosts a significant population of investors who hold shares in international financial institutions including ING Group through direct share ownership, exchange-traded funds, or mutual funds focused on European or global financials. The buyback programme affects these investors through several channels.
First, Singaporean shareholders benefit from the same price appreciation and EPS enhancement as all ING shareholders. If the shares continue trading above the programme’s average cost of €22.43, current holders gain value. The programme may provide downside support during market corrections, as ING’s consistent buying activity could cushion price declines.
Second, tax implications matter significantly for Singapore-based investors. Singapore does not tax capital gains, making share price appreciation from buybacks tax-efficient. However, Singapore also offers tax exemptions on qualified foreign dividends, partially reducing the buyback advantage. Investors must evaluate their personal circumstances, but the lack of capital gains tax generally favors buybacks over dividends for Singapore tax residents.
Third, currency dynamics affect Singapore-based returns. ING shares trade in euros, but Singaporean investors typically account for returns in Singapore dollars. Since the buyback announcement in late October 2025, EUR/SGD exchange rates have likely fluctuated, creating currency gains or losses independent of the share price movement. The euro’s recent performance against the Singapore dollar has been volatile due to diverging monetary policies between the European Central Bank and the Monetary Authority of Singapore. Investors should consider hedging currency exposure if ING represents a significant portfolio position.
Fourth, the buyback impacts the relative attractiveness of ING versus Singapore’s domestic banks. DBS, OCBC, and UOB have delivered strong returns over the past decade, benefiting from Singapore’s stable economy and these banks’ dominant market positions. Singaporean investors may evaluate whether ING’s European exposure and buyback strategy offer better risk-adjusted returns than home-country options. The comparison involves weighing ING’s growth in emerging European markets and digital banking initiatives against the Singapore banks’ stable dividends and regional expansion in Southeast Asia.
Impact on Singapore’s Banking Sector
While ING has limited direct operations in Singapore compared to global hubs, the buyback programme offers lessons for Singapore’s banking sector and influences competitive dynamics. DBS Group, OCBC Bank, and United Overseas Bank have traditionally favored high dividend payout ratios, returning substantial cash to shareholders while maintaining strong capital positions. This approach has created a shareholder base that expects consistent income.
However, share buybacks offer advantages these banks might increasingly consider. First, buybacks provide flexibility, as they can be paused or scaled without the negative signal associated with dividend cuts. Second, they benefit all shareholders proportionally through price appreciation, whereas dividends favor those who don’t need to reinvest cash. Third, buybacks can offset dilution from employee stock compensation programmes.
The Monetary Authority of Singapore maintains conservative capital requirements, and the three major banks operate with CET1 ratios well above regulatory minimums. This suggests capacity for enhanced capital returns, whether through larger dividends or inaugural buyback programmes. Observing ING’s execution may encourage Singapore banks to experiment with buybacks as a complementary tool alongside dividends.
Singapore’s banking sector faces strategic questions about capital deployment similar to those confronting ING. The domestic market is relatively saturated, pushing banks toward regional expansion in Southeast Asia, Greater China, and South Asia. These growth initiatives require capital, potentially limiting funds available for shareholder returns. However, if organic growth opportunities prove limited or low-return, buybacks become more attractive.
The buyback precedent set by ING and other international banks may influence shareholder expectations for Singapore banks. International institutional investors who own significant stakes in DBS, OCBC, and UOB may begin pressing for more aggressive capital returns if these banks accumulate excess capital. This pressure could reshape Singapore banking sector norms over time.
Impact on Singapore’s Asset Management Industry
Singapore has grown into a major wealth management and asset management hub, with over SGD 4 trillion in assets under management. Many funds domiciled in Singapore include European financial stocks like ING in their portfolios. The buyback programme impacts these asset managers through several mechanisms.
Portfolio managers at Singapore-based institutions must decide how ING’s buyback affects their position sizing. If the programme successfully boosts ING’s share price, its weight in portfolios increases automatically. Disciplined rebalancing might require reducing ING exposure to maintain target allocations. Conversely, if managers believe the buyback signals undervaluation, they might opportunistically increase positions.
Fund marketing teams in Singapore can use ING’s buyback as an example when explaining capital allocation strategies to investors. Many retail and high-net-worth clients in Singapore may be unfamiliar with share buybacks, instead associating shareholder returns exclusively with dividends. Educational materials highlighting how buybacks create value help asset managers justify holdings in buyback-heavy international portfolios.
The performance analytics teams at Singapore’s asset management firms should incorporate buyback adjustments when evaluating returns. A bank that buys back shares at prices below intrinsic value creates more per-share value than one paying equivalent cash as dividends. Sophisticated performance attribution should credit management teams for value-creative buybacks while penalizing value-destructive ones executed at excessive prices.
Singapore’s robo-advisory platforms and digital wealth managers, which have grown rapidly, typically employ algorithm-driven portfolio construction. These systems should incorporate buyback factors when screening for attractive stocks. A bank trading at 0.8x book value with an active buyback programme may offer better risk-adjusted returns than one at 1.2x book value with only dividends, and screening algorithms should capture this distinction.
Impact on Singapore’s Regulatory Framework
Although ING Group’s buyback occurs under European regulatory oversight, it offers insights relevant to the Monetary Authority of Singapore’s approach to capital management and shareholder returns for banks under its supervision. The MAS could examine whether its current framework optimally balances financial stability with efficient capital allocation.
Currently, MAS requires Singapore-incorporated banks to maintain capital ratios above international minimums, with higher buffers for systemically important institutions. These requirements ensure resilience but may inadvertently lead to excess capital accumulation. The MAS could consider implementing a graduated approach where capital returns automatically increase as ratios exceed certain thresholds, similar to the Federal Reserve’s stress capital buffer methodology.
The buyback programme also raises questions about different capital return mechanisms. European regulators have increasingly approved large buyback programmes as banks rebuilt capital post-financial crisis. Singapore’s banks have utilized buybacks less frequently, with dividends remaining the dominant return method. The MAS might study whether this difference reflects regulatory preference, bank management philosophy, or shareholder expectations, and whether adjustments would benefit the system.
From a systemic risk perspective, the MAS should consider whether large-scale buyback programmes by major banks could create procyclical risks. Buybacks tend to occur when banks feel confident about future earnings and capital generation, which often coincides with economic expansions. If many banks simultaneously execute buybacks during boom periods, then struggle to maintain capital during downturns, this could amplify credit cycles. Countercyclical policies might restrict buybacks during expansions while encouraging them during recessions, smoothing systemic risk.
The MAS might also examine disclosure requirements for any future buyback programmes by Singapore banks. Investors benefit from transparent, detailed reporting on buyback execution, average prices paid, and impact on capital ratios. Standardized disclosure requirements would facilitate comparison across institutions and enhance market discipline.
Impact on Singapore’s Economy
At the macroeconomic level, ING’s buyback has subtle effects on Singapore through several channels. First, Singaporean investors receiving economic benefits from the programme may adjust their consumption and investment patterns. If shareholders perceive wealth gains from share price appreciation, this modest positive wealth effect could marginally boost spending or other investments, though the magnitude is likely trivial relative to Singapore’s GDP.
Second, the buyback influences capital flows. Singaporean investors selling ING shares during buyback operations convert euro-denominated assets into cash, potentially repatriating funds to Singapore dollars. While individual transactions are small, collectively these flows impact EUR/SGD exchange rates marginally. Given Singapore’s role as an international financial center, capital flows from European corporate actions aggregate to meaningful volumes.
Third, the buyback serves as a case study for Singapore’s ongoing efforts to enhance its attractiveness as a listing venue for international companies. Singapore Exchange (SGX) competes with Hong Kong, Tokyo, and other Asian exchanges to attract company listings and secondary placements. Understanding how European companies manage shareholder returns helps SGX design policies and market infrastructure that accommodates diverse capital management strategies.
Fourth, the case influences Singapore’s dialogue about corporate governance. Singapore’s corporate governance code emphasizes sustainable long-term value creation. Large buyback programmes raise perennial questions about whether capital returns prioritize short-term shareholders over long-term stakeholders, including employees, customers, and communities. Singapore’s policymakers and business leaders benefit from observing international practices to inform local standards.
Impact on Singapore’s Financial Education
Financial literacy stands as a priority for Singapore’s government and financial industry. Many Singaporean investors have traditional preferences for dividend-paying stocks and may not fully understand share buyback mechanics and implications. ING’s programme offers a teachable moment for financial educators.
The Monetary Authority of Singapore’s investor education initiatives could incorporate buyback case studies showing how these programmes affect shareholder value differently than dividends. Interactive calculators could demonstrate how buybacks reduce share count, increase EPS, and potentially boost share prices, helping investors make informed comparisons between dividend-paying and buyback-focused stocks.
Singapore’s Institute of Banking and Finance could develop professional education modules on capital allocation strategies for banking professionals. As Singapore’s financial sector becomes increasingly sophisticated, professionals need deep understanding of how international peers approach capital management. Comparing ING’s buyback strategy with the dividend preferences of DBS, OCBC, and UOB provides rich material for professional development.
Academic institutions in Singapore, including the National University of Singapore Business School and Singapore Management University, could incorporate this buyback case into corporate finance curricula. Students benefit from analyzing real-world capital allocation decisions, evaluating whether ING’s management made optimal choices, and considering alternative scenarios.
Long-Term Strategic Implications for Singapore
Looking ahead five to ten years, ING’s buyback and similar programs by international financial institutions may influence Singapore’s evolution as a financial center in several ways. First, as global investors become more sophisticated about evaluating different capital return methods, Singapore’s asset management industry must develop expertise in analyzing buybacks alongside dividends. This expertise becomes a competitive advantage in managing international portfolios.
Second, if share buybacks become increasingly common in Asian banking sectors, following trends in Europe and North America, Singapore’s banks may eventually adopt more balanced approaches combining dividends and buybacks. This evolution would align Singapore practices with global norms while maintaining the strong capital positions that have characterized the sector.
Third, Singapore’s regulatory framework may evolve to better accommodate diverse capital management strategies. As the MAS observes international practices, it may refine guidelines to give banks more flexibility in choosing between dividends, buybacks, and other capital actions based on specific circumstances rather than following rigid formulas.
Fourth, Singapore’s position as a wealth booking center for high-net-worth individuals across Asia means the tax efficiency of different capital return methods matters significantly. If more companies shift toward buybacks and away from dividends globally, Singapore’s attractive tax treatment of capital gains (zero taxation) becomes an even stronger competitive advantage versus jurisdictions that tax capital gains heavily. This could attract additional wealth management assets to Singapore.
Finally, as sustainability considerations increasingly influence capital allocation decisions, Singapore can position itself as a leader in frameworks that integrate ESG factors with shareholder returns. If ING and other banks develop conditional capital return programmes linked to sustainability metrics, Singapore’s expertise in both finance and sustainability could make it a natural hub for such innovative approaches.
Conclusion
ING Group’s €1.1 billion share buyback programme represents a significant capital allocation decision with implications extending far beyond the bank’s European home markets. For Singapore specifically, the programme affects local shareholders, provides lessons for domestic banks, influences asset management practices, informs regulatory thinking, and contributes to financial education.
The buyback demonstrates confidence from ING’s management in the bank’s intrinsic value and generates tangible benefits through reduced share count and enhanced per-share metrics. The disciplined execution, with careful attention to purchase prices and timing, suggests a well-designed programme likely to create shareholder value.
For Singapore-based stakeholders, the key takeaways involve understanding buyback mechanics, evaluating whether Singapore banks should adopt similar strategies, incorporating buyback analysis into investment processes, and recognizing how global capital allocation trends affect the city-state’s role as a financial center. As international finance continues evolving, Singapore’s ability to understand, accommodate, and potentially lead in innovative capital management approaches will support its competitive position.
The long-term outlook suggests share buybacks will remain an important tool for financial institutions globally, including potentially in Singapore. Success requires sophisticated analysis, disciplined execution, clear communication with stakeholders, and careful balancing of capital returns with investments in growth, technology, and sustainability. ING’s programme offers a valuable case study in these challenges and opportunities.