Members of the Executive Board are permitted to hold ING shares and depositary receipts for shares for long-term investment purposes. Transactions in these shares are subject to ING’s regulations for insiders. Movements in the holding of ING shares may take place for various reasons, including as a result of dividend payout or as part of the remuneration.

The holdings of ING shares by Executive Board members are reported in the ING Group Annual Report. See the 2008 Annual Report on page 77.

Information on transactions in ING securities by persons and institutions who are obliged to notify transactions in ING securities can be found on the website of the Dutch regulator Autoriteit Financiële Markten (AFM): www.afm.nl. See the Dutch version of the website under marktpartijen > registers > insider transacties.