ING GROEP NV

Item 16B. Code of Ethics

ING has adopted a Code of Ethics (as defined in Item 16B of Form 20-F)

that applies to all employees including ING’s principal executive officer,

principal financial officer and principal accounting officer. The provisions of

ING’s Code of Ethics are contained in the ING Orange Code, the ING Global

Code of Conduct and the ING Whistleblower Policy.

In 2025, there were no amendments to the provisions of the ING Orange

Code, the ING Global Code of Conduct or the ING Whistleblower Policy.

In 2025, ING did not grant any waivers (including implicit waivers) under

the provisions of the ING Orange Code, the ING Global Code of Conduct or

the ING Whistleblower Policy that constitute the Code of Ethics to ING’s

principal executive officer, principal financial officer or principal accounting

officer.

The ING Orange Code is available on the ING website at the following

hyperlink: https://ing.com/about-us/purpose-and-values.

The ING Global Code of Conduct is available on the ING website at the

following hyperlink: https://ing.com/about-us/purpose-and-values.

The ING Whistleblower Policy is available on the ING website at the

following hyperlink: www.ing.com/about-us/compliance/whistleblower-

policy.