ING Business Principles

As a global provider of financial products and services, ING plays an important role in society. In order to fulfill this role it needs to maintain the confidence of its customers, shareholders, employees, and other stakeholders by acting with professionalism and integrity.

ING Group attaches paramount importance to upholding its reputation, and the ING Business Principles play an important role in this respect. ING expects the highest levels of integrity from its employees, regardless of their position in the organization.

• We are committed to our integrity
• We aim for an above average return
• We are open and clear
• We promote sustainable development and respect human rights
• We respect each other
• We are involved in the communities we operate in

• The Business Principles apply to the whole of ING Group, its subsidiaries and business units and to every employee
• It is the responsibility of all those in authority at ING to ensure that these Principles are fully communicated to all present and future staff. They must also ensure that these are strictly observed.
• The members of the Executive Board and all Managers are responsible for applying the Business Principles within their areas of responsibility.
• The Executive Board receives regular reports, including an annual review, on the effective operation of the Business Principles.

• Every Capability at ING is required to act in accordance with both the letter and spirit of these Business Principles and obliged to promptly report any violation of these Principles to his/her line manager or the responsible compliance officer.
• Anyone becoming aware of a violation of the Business Principles by an Executive Board member is obliged to report such violation to the Group Compliance Officer promptly, who will report it to the chairman of the Supervisory Board of ING Group.
• Any violation of the Business Principles may also be reported according to the ING Whistleblower Procedure.
• ING employees will be held accountable for acting in accordance with the Business Principles.
• Upon violation of the Business Principles, disciplinary measures may be taken, up to and including termination of employment.
• Violations of these Business Principles will be promptly disclosed to the extent required by the applicable laws, rules and regulations.

• Early in 2004, the Executive Board of ING Group added an additional Business Principle on human rights.
• ING's top managers have received a management guide to help them define their role and responsibilities concerning human rights and their business units.