Compliance Risk Management Charter

ING is committed to the preservation of its reputation and integrity through compliance with applicable laws, regulations and ethical standards in each of the markets in which it operates. All employees are expected to adhere to these laws, regulations and ethical standards, and management is responsible for ensuring such compliance. Compliance is therefore an essential ingredient of good corporate governance.

The Executive Board of ING Group has collective responsibility for managing compliance risk across ING Group. The general management of a business unit has collective responsibility for managing compliance risk within its business unit. Dedicated Compliance Officers throughout ING assist management in controlling compliance risk.

ING Group has adopted the Compliance Risk Management Charter to help its businesses effectively manage their compliance risks. The Charter defines compliance risk and describes the respective roles and responsibilities of management, employees, and Compliance Officers for managing compliance risk. The Compliance Charter refers to the Non-Financial Risk Framework that outlines the principles, processes and tools that managers, employees and Compliance Officers use to manage compliance risk within ING.