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Filings with the Dutch Authority for the Financial Markets (AFM)

Pursuant to the Dutch Financial Supervision Act, shareholders and holders of American depositary receipts (ADRs) of ING Groep N.V. are required to provide updated information on their holdings once they reach, exceed or fall below threshold levels of 3%, 5%, 10%, 15%, 20%, 25%, 30%, 40%, 50%, 60%, 75% and 95%.

Based on filings to the AFM (Dutch Authority for the Financial Markets) and to the best of our knowledge, currently the only shareholders with an interest of 3% or more are BlackRock, Inc., which reported an interest of 5.07% on 13 July 2020 and JP Morgan Chase & Co, which reported an interest of 4.38% on 12 February 2021.

Filings with the U.S. Securities and Exchange Commission (SEC)

According to the U.S. Securities and Exchange Commission, shareholders in a company which have registered a class of their equity securities under the Exchange Act, are required to file beneficial owner reports if the ownership exceeds more than 5% of the outstanding shares of that class. The shareholder is obliged to file Schedule 13D or 13G until their holdings drop below 5%.

On 5 February 2020, BlackRock, Inc. disclosed by way of a Schedule 13G filed with the SEC, beneficial ownership of 259,231,767 ordinary shares of ING Group as of 31 December 2019, representing 6.7% of ING Group’s issued share capital.

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