Zero tolerance approach to bribery and corruption

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Achieving our purpose to empower customers to stay a step ahead in life and in business requires a strong culture to support it. In 2015, ING Groep N.V. (including its subsidiaries, herein “ING”) introduced the Orange Code. Inspired by the aim to put “integrity, above all”, the code is a manifesto that sets out who we are, how we work and helps to strengthen our relationship of trust with our customers. The Orange Code comprises:

ING Values - the principles we stick to no matter what:

  • We are honest
  • We are prudent
  • We are responsible

ING Behaviours – the commitments we make to each other and the standards by which we measure each other’s performance:

  • You take it on and make it happen
  • You help others to be successful
  • You are a step ahead

ING’s zero tolerance approach to bribery and corruption

ING expects all our employees, including Senior Management and members of the Executive Board, Management Board Banking and Supervisory Board, to always do business in accordance with the Orange Code.

This zero tolerance approach also means we are committed to the mitigation, deterrence and detection of 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 and expect the same from our clients.

The ING zero tolerance principles to bribery and corruption also apply to third parties with whom ING does business or who are retained by ING to perform services or deliver business for and on behalf of ING.

The ING anti-bribery and anti-corruption principles are stated in the ING Anti-Bribery and Corruption Policy and are summarised below:

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

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

  3. ING will not allow employees or third parties to make gifts or political donations to political parties or to offer gifts or entertainment to candidates for political positions on its behalf.

  4. Decisions to allow paid or unpaid internships and secondments should be based on merit.

  5. Questionable behaviour should be challenged and rumours of improper payments or activities should be reported to management or could also be reported via the whistleblower reporting channels.

Public officials

Whilst our policies do not prohibit legitimate business interactions with public officials or state-owned entities, these are subject to heightened attention and stricter conditions, such as pre-approvals and lower limits.

Travel and accommodation

ING employees should generally not accept or offer travel and accommodation related to corporate hospitality packages.

Charitable contributions

ING employees should ensure that charitable contributions are made to bona fide charities and are not used to conceal a bribe.

Recording and registration

ING employees should ensure that expenses and payments related to third parties are registered and accurately recorded in the financial books.

Violations

ING employees are encouraged to report violations via the internal reporting lines. Shareholders of ING, third parties and also employees can follow the steps as outlined in the ING Group Whistleblower Policy.

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