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Disclosure Policy

Purpose, Scope and Basis
The main purpose of the Disclosure Policy is to ensure that required information, other than confidential business information, is disclosed to the public, investors, employees, customers, creditors and other relevant parties in a timely, accurate, complete, understandable, convenient and affordable manner.

All kinds of financial information, explanations and disclosures required in line with the Banking Law and the relevant regulations, Capital Markets Board (CMB) Legislation, Turkish Commercial Code, Istanbul Stock Exchange (ISE) Legislation and other relevant legislation, are provided by also taking into consideration the generally accepted accounting principles and the Corporate Governance Policies of the CMB.

ING Bank A.Ş. (“Bank”) Disclosure Policy has been created based on the “Communiqué, Serial: VIII, No: 54 on the Principles Governing Public Disclosure of Material Circumstances” issued by the CMB.

Rights and Responsibilities
The Disclosure Policy has been established by the Bank's Board of Directors. The Board of Directors has the right and the responsibility to disclose information to the public, and to monitor, supervise, and develop the disclosure policy. Coordination of the disclosure function is the responsibility of the Financial Control Department and the Legislation Department. The officials of the aforesaid departments fulfill these responsibilities in close coordination with the Senior Management.

Disclosure of Financial Information
The financial statements prepared quarterly on solo and consolidated basis in accordance with the legislation issued by the Banking Regulation and Supervision Agency (BRSA), footnotes and remarks regarding the relevant financial statements, the independent audit report and the interim report are submitted to the ISE within the prescribed legal period and published on the Bank's website and the websites of the BRSA and the Banks Association of Turkey. At year-ends, the financial statements prepared quarterly on solo and consolidated basis in accordance with the legislation issued by the Banking Regulation and Supervision Agency (BRSA), footnotes and remarks regarding the relevant financial statements, and the independent audit report are submitted to the ISE within the prescribed legal period and published on the Bank's website and the websites of the BRSA and the Banks Association of Turkey. The relevant financial statements are attested and signed by the Chairman of the Bank's Board of Directors, members of the Audit Committee, CEO, Vice President in charge of financial reporting, and the director of the relevant unit. The interim reports prepared quarterly provide information on the Bank's market position, general financial performance and other important matters.

Disclosure of the Annual Report
The annual report, prepared in accordance with the legislation issued by the BRSA, is submitted to the ISE within the prescribed legal period and published on the Bank's website. The relevant financial statements are attested and signed by the Chairman of the Bank's Board of Directors, members of the Audit Committee, CEO, Vice President in charge of financial reporting, and the director of the relevant unit.

The interim reports prepared quarterly provide information on the Bank's market position, general financial performance and other important matters.

Disclosure of Material Circumstances
The disclosure of material circumstances that must be provided in accordance with the CMB legislation, is submitted to the ISE and the Public Disclosure Platform (www.kap.gov.tr), which was established by the ISE with the objective of informing the public, within the prescribed period, and published on the Bank's website on the next business day at the latest, following the disclosure. The relevant disclosures are kept on the Bank's website for five years. The disclosure of material circumstances is signed by the directors authorized by the Bank's Board of Directors, and presented to the relevant authorities.

To ensure the confidentiality of the material circumstances until they are disclosed to the public, the Bank employees who have access to insider information are informed on their responsibilities arising from the legislation. In agreements drawn up with persons and institutions who may have access to insider information due to the services they provide for the Bank, the provisions of the relevant legislation are complied with.

In accordance with the Banking Law No. 5411 and the relevant legislation, the Bank strictly complies with its legal obligation of maintaining the confidentiality of the Bank's and the customers' information, and not disclosing them to persons other than the legally authorized parties. In addition to the employees of the Bank, this obligation also applies to the institutions from which the Bank receives services and their employees. The news about the Bank published in domestic media, are followed through a professional media monitoring agency. In this context, when disclosure of material circumstances is required within the scope of the relevant legislation, the disclosure regarding the relevant matter is provided by compiling the required information from the relevant units.

In disclosures provided in relation to news or rumors in the media which do not require disclosure of material circumstances in accordance with the relevant legislation, the method and the content of the disclosure are determined by taking into consideration factors such as the content of the news, the extent of the audience reached by the media organ, and whether or not the reputation of the Bank is affected by the news. In instances where disclosure is provided in relation to these types of new and rumors, in the case that the content of the disclosure includes a factor that requires disclosure of material circumstances, the disclosure of material circumstances is also provided in line with the provisions of the relevant legislation.

Disclosure by Press Releases
When deemed necessary, press releases are issued through printed and visual media. Press releases through printed and visual media can be issued by the Bank's Chairman of the Board of Directors, CEO or other officials approved by the aforesaid individuals.

Other Disclosure
Necessary disclosure are provided in matters such as amendments to the Articles of Association, general assembly meetings, and capital increase.

Disclosures other than those stated above are provided to the public after being signed within the scope of the authorities specified in the signatory circular of the Bank.

Questions about the Bank received through e-mail, telephone and other channels are answered as soon as possible by coordinating the relevant units.

Confidentiality of Insider Information
The Bank's Board of Directors is responsible for taking and implanting all the measures to maintain the confidentiality of the information which has not been disclosed yet and which may affect the value of the capital market instruments and the investment decisions of the investors.

The Bank draws up a list of employees who are authorized to access insider information. The responsibilities of the individuals included in the list and the reasons for their appearance in the list are clearly stated. The list is continually updated.

Necessary measures are taken to ensure that attorneys, independent auditors, tax consultants and other similar individuals, who may have access to insider information during the conduct of business and transactions on behalf of the Bank, maintain the confidentiality of the information they acquire, both legally and within the scope of the provisions of the special agreement.

Determination of the Persons who have Administrative Responsibility
The persons who have administrative responsibility and persons who are closely related to them are determined on the basis of the CMB legislation. Additionally, when determining the persons who have administrative responsibility, the duties of the persons within the Bank's organization, and the content of the information accessed by such persons, are also taken into consideration.


In this context, in addition to the senior management of the Bank, the directors of certain departments at the Head Office who have access to information about the Bank as a whole, and who are authorized to make administrative decisions that may affect factors such as the asset-liability structure, profit-loss, cash flow, strategic objectives, etc. at macro level, are determined as persons who have administrative responsibility. Necessary updates are made when there are organizational changes.

ING Bank A.Ş. Internet Website (www.ingbank.com.tr)
The Bank's website is actively and intensively used in public disclosures. The Bank's website contains information and data required by the legislation. Special care is taken in continually keeping the internet website up-to-date.

Implementation and Amendments
The Bank's Board of Directors has the right and the responsibility to develop and to follow up the implementation of the Disclosure Policy. The effectiveness and reliability of the public disclosure process within the scope of the Disclosure Policy are under the supervision and control of the Bank's Board of Directors. The Bank's Board of Directors has the right to amend the policy. The amendments are disclosed to the public and published on the internet website within one week following the amendment.

The implementation of the Disclosure Policy is under the responsibility of the Bank's Senior Management.