ING GROEP NV

Item 16B. Code of Ethics

Orange code and the global Code of Conduct

Building on the values and behaviours of our Orange Code, the ING Global Code of Conduct outlines the 10 conduct principles expected from all of us. The principles aim to prevent and protect us from making unethical and/or illegal decisions within ING's day-to-day business. Prevention of bribery & corruption (AB&C), and whistleblowing (speak up), are among those 10 core principles and have their own policy.

When ING employees go through the onboarding process, they are required to take an e-learning and commit to adhere to the Global Code of Conduct. Also, every year, all ING employees must acknowledge their adherence to the Global Code of Conduct. We monitor this acknowledgement via the compliance risk dashboard.

The global Code of Conduct was updated in Q4 2024. A mandatory global required learning will be launched in Q1 2025, accompanied by email communications and a newsletter announcement.

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 2024, 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 2024.

Orange Code Decision Making

Balancing the rights and interests of our stakeholders is one of the key Orange Code principles. To further enhance risk judgement, we continued to apply the Orange Code decision-making model to dilemmas. This four-step model supports well-balanced and informed decision-making.

In 2024, the focus was on supporting decision-making and advisory bodies at ING – dealing with e.g., environmental and social risk, product approval and review processes, data ethics and model validation – in organising dilemma dialogues as part of their decision-making process.

Conflicts of Interest

ING, being a large financial institution, is prone to multiple conflicts of interest, due to overlapping interests of different stakeholders as businesses, employees, customers, shareholders, and society. In 2024, we updated the global conflicts of interest policy, including the related framework document, coming into effect in May 2025.

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 2024.

Whistleblower

ING wants to create, facilitate and maintain an environment in which employees feel encouraged and supported to speak up at all times. Conduct Ethics is about supporting and protecting our employees by means of (i) dealing with dilemmas, (ii) setting the right environment for ethical decisions and behaviours, (iii) providing for an escalation/reporting process in case of concerns, and ensuring fair consequence management. For this we rely on our Orange Code, with the values and behaviours that guide us, the Global Code of Conduct - revised in 2024 - that prevents and protects employees from behaving unethically, and the whistleblowing framework in case of concerns.

ING Group Annual Report 2024 on Form 20-F 131

In 2024, ING further enhanced the whistleblower process with explicit focus on anti-retaliation, fair consequence management, and deliberate after-care. A global cross-channel Speak up programme is in place to harmonise the different Speak up channels for undesirable behaviour.

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

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 2024.

Dutch Banker’s Oath

In the Netherlands, all employees are required to take the Banker's Oath. 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. Before taking the oath, an e-learning and a challenge (discussing dilemmas) are mandatory, to stress the content and the importance of the oath. It also shows employees the dilemmas they may face in their daily work, and how to carefully balance the interests of all our stakeholders in the decisions they make.

In 2024, there were no amendments to the Banker's Oath. ING NL did grant temporary waivers for the Banker's Oath, but not to any principal executives, financial and accounting officers in 2024 (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.