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Anti-Bribery and Corruption Policy

We, as ING, aim to enable our clients to be one step ahead at all times. We need a well-established corporate culture to achieve and support this aim. ING Group NV (shall hereinafter be referred to as "ING" including its subsidiaries) introduced the Orange Code in 2015. Inspired by the aim of "putting integrity above all other things", this Code is actually a manifest that helps us to reveal who we are and how we work, and also to reinforce our relations with our clients. Orange Code includes the following:

ING Values - The principles we stick to, no matter what.

  • We are honest 
  • We are responsible 
  • We are prudent 
ING Behaviors -The commitments we make to each other and the standards by which we will measure each other’s performance. :
  • You take it on and make it happen. 
  • You help others to be successful. 
  • You are always a step ahead. 

Zero Tolerance Approach to Bribery and Corruption

ING addresses personal conduct related integrity risks by committing to conduct business in an honest and ethical manner and taking a zero tolerance approach to Bribery and Corruption in all of its relationships and business dealings, wherever it operates. ING expects all its staff members including the Senior Management and members of the Executive Committee and the members of the Board of Directors, to always do business in accordance with the Orange Code This zero tolerance approach means we are committed to the prevention, deterrence and detection of bribery and corruption. We do not and will not pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we accept bribes or improper inducements or anything that could be perceived as such and we expect such kind of an approach from all our clients, suppliers, service providers and business partners, as well as all third parties which are in business dealings with ING or which are in relation with ING in order to offer service for and on behalf of ING or to provide service for and on behalf of ING for commercial purposes including our representatives.

ING's anti-bribery and corruption principle, provided under ING's Anti-Bribery and Corruption Policy, is summarized below:

  1. All forms of Bribery and Corruption, including Facilitation Payments, are strictly prohibited, whether they take place directly or indirectly through another party.
  2. Gifts or Entertainment must always be proportionate and reasonable. They must have a legitimate purpose and must not create a conflict of interest or the perception thereof. Excess and lavishness must be avoided at all times.  
  3. ING will not allow employees or third parties to make gifts or political donations to political parties or to offer Gifts or Entertainment to candidates for political positions on its behalf. 
  4. Decisions to allow paid or unpaid internships and Secondments should be based on merit and must not be made to improperly influence the recipient or his/her closely related individuals.  
  5. Questionable behavior should be challenged and rumors of improper payments or activities should be reported to management or could also be reported via the whistleblower reporting channels. 
Public Officials

While our policies do not prohibit legitimate business interactions with public officials or state-owned entities, they are subject to heightened attention and stricter conditions, such as pre-approvals and lower limits in order to ensure compliance with the provisions prescribed under the applicable local regulations.

Travel and Accommodation

In general terms, ING employees should not accept or offer travel and accommodation related to corporate hospitality packages.

Charitable Contributions

ING employees should ensure that charitable contributions are made to bona fide charities and are not used to conceal a bribe.

Recording and registration

ING employees should ensure that expenses and payments related to third parties are registered and accurately recorded in the financial books.


ING employees are encouraged to report any and all violations via the internal reporting lines.