Whistleblower Policy

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The Whistleblower Policy guides and supports ING to:

  • Be responsive to all employees.
  • Be a trusted organisation that treats employees with respect; and
  • Demonstrates its commitment to the Orange Code, ING policies, laws and regulations.

The Whistleblower Policy helps ING to take appropriate and adequate action in case of a concern, which is a situation raised by a whistleblower about a (suspected) criminal conduct, unethical conduct or other misconduct by or within ING that leads to, or could lead to, a violation of:

  • The Orange Code, and/or
  • Any ING Policy, and/or
  • Any law and regulation.

In line with the Orange Code values (’we are honest, prudent and responsible’), ING wants to encourage and protect employees, who come forward and (anonymously) report concerns in good faith by:

  • Encouraging a culture in which employees can (anonymously) raise concerns in good faith regarding suspected or actual criminal conduct, unethical conduct or other misconduct without having to fear any adverse consequences; and
  • Increasing the likelihood of alerting management to concerns so they can be addressed to prevent non-compliance with the Orange Code, ING policies, laws and regulations.

ING exercises the utmost care with regard to the confidentiality of such a report or the anonymity of the employee, within the limits as defined by applicable laws and regulations.

Scope of the Whistleblower Policy

The Whistleblower Policy is applicable to all majority-owned ING businesses (or business entities), businesses under ING’s management control (including ING Groep N.V.) and their employees.

The Whistleblower Policy applies to concerns about suspected or actual criminal conduct, unethical conduct or other misconduct by or within ING, for example:

  • Accounting, internal accounting controls or auditing matters.
  • Money laundering or terrorist financing.
  • Market abuse.
  • Insider trading.
  • Breach of client confidentiality or privacy.
  • Theft.
  • Fraud.
  • Bribery or corruption.
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