Whistleblower Policy

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ING’s Whistleblower policy encourages and protects employees, former employees, candidates, and parties with whom ING has a business relationship (such as contractors, subcontractors and suppliers) who speak up when they encounter behaviour by or within ING that is/seems unethical, illegal or goes against the values of our Orange Code.

The Whistleblower Policy applies to concerns about, suspected or actual criminal conduct, unethical conduct or other misconduct including a (suspected) breach of (EU) law by or within ING, including but not limited to:

  • Accounting, internal accounting controls or auditing matters
  • Money laundering or terrorist financing
  • Financing clients who violate human rights or commit environmental crimes
  • Market manipulation
  • Insider trading
  • Confidentiality or privacy breaches
  • Theft
  • Fraud
  • Bribery or corruption
  • Undesirable behaviours
  • Violations of any other laws, regulations or ING policies

ING’s whistleblowing channels (e.g. via can be used to raise these concerns (also anonymously), without fear of retaliation. It alerts management to allegations of crimes or other suspected misconduct and helps ensure appropriate and adequate action is taken to address the situation.

After the Whistleblowing concern has been received by ING an acknowledgement of receipt will be sent within 7 days. Based on the provided information the Whistleblowing concern will be investigated. Often, follow-up contact is needed for further clarification, contact will be sought via the available (anonymous) communication channels. An update on the follow-up of the concern will be shared within three (and in exceptional situations, six) months after ING’s acknowledgement of receipt.

We take the utmost care to protect the identity of whistleblowers and the confidentiality of such a report, within the limits defined by applicable laws and regulations.

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