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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 the AFM (Dutch Authority for the Financial Markets) register, as consulted on 21 December 2021, shareholders with holdings of 3% or more are BlackRock, Inc. (5.07% interest reported on 13 July 2020), Artisan Investments GP LLC (3.08% interest reported on 19 March 2021), Capital Research and Management Company (5.09% voting rights reported on 3 September 2021) and Goldman Sachs Group Inc. (3.05% interest reported on 15 December 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 29 January 2021, BlackRock, Inc. disclosed by way of a Schedule 13G filed with the SEC, beneficial ownership of 289,185,500 ordinary shares of ING Group as of 31 December 2020, representing 7.4% of ING Group’s issued share capital.

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