ING is a large institutional investor that manages assets for the account of clients worldwide as well as for its own account.

In April 2004, ING Group adopted a Global Voting Policy to govern the exercise of voting rights for all of ING's client and proprietary assets world-wide. The policy provides the groundwork for ING's asset management units to adopt a higher profile as institutional investors.

The policy outlines key principles and is intended to provide a framework for ING's individual asset management units to draw up more detailed voting procedures that conform with the regulations and standards of the countries in which they operate.

In order to avoid potential conflicts of interest, the voting policy makes a clear distinction between proprietary assets, held for ING's own account, and assets held on behalf of clients.

In 2005 ING started to make more active use of its voting rights and has started reporting on its voting behaviour.

ING Investment Management Europe discloses its voting conduct on a detailed level providing information per ballot on the ING Investment Management website. You can find this document on the ING Investment Management website.