Zero tolerance approach to bribery and corruption

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We expect all ING employees at every level of the organisation to always do business in accordance with the values and behaviours of our Orange Code.

We have a zero tolerance approach when it comes to bribery and corruption. We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose. Nor do we, or will we, accept bribes or improper inducements or anything that could be perceived as such. We expect the same from our customers, business partners and third parties we retain or that perform services or deliver business on our behalf. Bribery and corruption is not accepted in any form.

The principles of ING’s Anti-Bribery and Corruption Policy state:

  1. All forms of bribery and corruption, including facilitation payments, are strictly prohibited.

  2. Gifts or entertainment must always be proportionate and reasonable; must have a legitimate purpose; and must not create a conflict of interest or the perception thereof.

  3. Employees and third parties may not make gifts or donations to political parties nor offer gifts or entertainment to candidates for political positions on ING’s behalf.

  4. Paid and unpaid internships and secondments should be based on merit.

  5. Questionable behaviour should be challenged and (suspected) improper payments or activities should be reported to management or via the whistleblower channels.

Public officials

Legitimate business interactions with public officials or state-owned entities are subject to heightened attention and stricter conditions, such as pre-approvals and lower limits.

Travel and accommodation

Travel and accommodation should generally not be offered or accepted as part of corporate hospitality packages.

Charitable contributions

Charitable contributions should only be made to bona fide charities so they cannot be used to conceal a bribe.

Recording and registration

Expenses and payments related to third parties should be registered and accurately recorded in the financial books.

Violations

ING employees are encouraged to report violations via the internal reporting lines outlined in the Whistleblower Policy. Shareholders, third parties and other stakeholders can report their suspicions to ING’s chief compliance officer.

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