ING GROEP NV

Item 16B. Code of Ethics

Orange code and the global Code of Conduct

The Orange Code and the global Code of Conduct are the foundation of ING’s risk culture. The global Code of

Conduct defines the most essential conduct principles expected from ING employees in their daily activities,

to create additional risk awareness and better meet expectations stated in external rules and guidelines. In

2021, the global Code of Conduct has been embedded into our employees’ performance management cycle

to ensure continuous attention to the Global Code of Conduct, and dialogue on how to apply it in our daily

work practice.

The Orange Code is a declaration of who we are. It describes what we can expect from each other when we

turn up to work each day. It is a set of standards that we collectively value, strive to live up to, and invite

others to measure us by.

The Orange Code is the sum of two parts, the ING values and ING behaviours, with integrity being the

overarching principle. The ING values (being honest, prudent and responsible) are non-negotiable promises

we make to the world, principles we seek to stick to, no matter what. The ING behaviours (take it on and

make it happen, help others to be successful, and always be a step ahead) represent our way to

differentiate ourselves. The Orange Code is embedded in commitments we make to each other and the

standards by which we measure each other’s performance.

The ING Code of ethics are the ING Orange Code and the ING Global Code of Conduct and no waivers have

been granted for either of them.

The Orange Code applies to all employees worldwide, including the principal executive, financial and

accounting officers. The values and behaviours of the Orange Code are available on the ING website at

https://www.ing.jobs/global/careers/why-join/our-orange-code.htm.

In 2023, there were no amendments to the Orange Code. ING did not grant any waivers (including implicit

waivers) under the Orange Code to the principal executive, financial or accounting officers in 2023.

Orange Code Decision Making

To enhance risk awareness, support moral learning, and enable people to perform proper risk judgement,

the Orange Code Decision Making model (introduced globally as of 2017, approved by the MBB) aims to

ING Group Annual Report 2023 on Form 20-F 141

support our employees in dealing with dilemmas in a balanced and fair way, by using the OCDM-method

and/or having OCDM-dialogue sessions. This four-step approach supports balanced decision-making by

weighing the rights and interest of all stakeholders involved and also ensuring the necessary mitigating

measures where possible. ING’s Risk Culture&Behavioural Risk Department ensures awareness for and and

knowledge of OCDM in the countries and at global level, so that all can properly apply the model. Moreover,

the model has been embedded into other decision making processes, such as the data ethics governance

process and the global Product Approval and Review Process.

Conflicts of Interest

ING is committed to identify conflicts of interest and act on them. The Conflicts of Interest policy sets the

obligation to identify, assess and manage conflicts of interest when personal or organisational interests are

in conflict over the interest of our client(s), employees or other stakeholders. In 2022 the Conflicts of Interest

policy was revised and implemented to further align with the standards as defined by enterprise risk

management. The policy incorporates key requirements for both personal and organisational conflicts of

interest in line with the European Bank Authority Guidelines on Internal Governance. Next to the updated

policy, mandatory instructions on conflict of interest registers are implemented which provides instructions

to identify, assess, mitigate or prevent and record all structural and incidental conflicts of interest.

ING maintains a policy on Conflicts of Interests which applies to all employees worldwide, including the

principal executive, financial and accounting officers. A description of the policy on Conflicts of Interest is

available to view on the ING website at https://www.ing.com/About-us/Compliance/Conflicts-of-interest-

and-confidential-information.htm.

ING did not grant any waivers (including implicit waivers) under the Conflicts of Interest Policy to the

principal executive, financial or accounting officers in 2023.

The programme launched in 2021 to enhance the global whistleblower process has been concluded. In 2022

whistleblowing enhancement activities have continued with an emphasis on increasing employee

awareness on misconduct reporting. Sanitized whistleblowing data has been shared within the organisation

to provide more transparency on the types of concerns employees do report and our rapidity of response. In

2023 an update of the whistleblower policy was approved adjusting the wording in line with European

regulatory standards and streamlining the process steps. Updated policy will be effective per start of 2024

on a concern by concern reported basis.

The Whistleblower Policy is available on the ING website at www.ing.com/About-us/Compliance/ING-Group-

Whistleblower-Policy.htm.

ING granted ING Türkiye a waiver and ING Bank Śląski S.A (Poland) a deviation, because local regulations in

both locations are stricter than the ING Whistleblower Policy. No further waivers or deviations were granted

(including implicit waivers) under the Whistleblower Policy to the principal executive, financial or accounting

officers in 2023.

Banker’s Oath

In the Netherlands, all employees of ING take the Bankers’ Oath (including ING's principal executive, financial

and accounting officers) and pledge this promise in a meaningful ceremony. The Oath came into force in

the Netherlands on 1 April 2015, as part of a joint approach from all banks, aimed at introducing social

regulations, a revised Dutch Banking Code implementing an oath with associated rules of conduct and

disciplinary law. This way the Dutch banks show society what they stand for and are accountable for, both

as individual banks and as a sector. In 2021, due to the Covid-19 pandemic, ING NL changed to virtual

Bankers’ Oath ceremonies via Teams, instead of the former physical ones, to ensure that all new employees

(around 400 a month) can still take the Bankers’ Oath in time and in a meaningful ceremony. Before taking

the Oath, an e-learning is followed and the importance of the Oath is discussed. Also, dilemmas that the

employees may come across in their daily work are shown, to ensure careful balancing of the interests of all

our stakeholders, in the decisions we make. In 2020 and 2021 the whole Bankers’ Oath programme for new

joiners was revised and updated, to ensure that all elements still align with the current developments, both

internally and externally.

In 2023, there were no amendments to the Banker's Oath. The ING NL Banker’s Oath Guidelines (last

reviewed in 2020) will be reviewed soon however (Q1 2024 expectedly). ING NL did grant temporary waivers

for the Banker's Oath, but not to any principal executives, financial and accounting officers in 2023 (unless

they were not in scope of the Banker’s Oath obligation according to ING NL’s Banker’s Oath Guidelines). The

text of the Banker’s Oath can be found here: https://www.ing.com/About-us/Corporate-governance/Dutch-

Banking-Code.htm.