1 Introduction; 2 Group Structures; 3 ESG Implementation; 4 Observations from the Field; 5 ConclusionThis study analyzes how a Dutch parent or subsidiary entity, which holds or is part of an international and economically active group, addresses (potential) negative effects of its business activities via ESG. The research focuses on the actual implementation and execution of ESG policies. The methods used for this analysis are diverse and include interdisciplinary legal-economic research and interviews. The conclusions of this report are threefold. First, it is shown that legal and operational business structures are often rather distinct concepts. Second, there exists a great variety between organizations in terms of the approach chosen for the implementation and execution of ESG policies. Third, and perhaps most fundamentally, even organizations that strive for centralized decision-making may, due to a wide variety of factors, in practice not always be able to have a unified ESG strategy. These observations carry significant implications for the ESG policy-making debate and also form a basis for future research. The ICFG (International Center for Financial law & Governance) is the multidisciplinary research centre of the Erasmus School of Law in the field of financial law and governance. The ICFG's ambition is to bring together national and international academics, professionals and students in order to foster a high-quality exchange of ideas in relation to financial businesses and other organizations active in the financial markets. The ICFG series contains publications that reflect the research activities of the ICFG and its researchers.