Insider Code

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Generic Insider Code Netherlands ING Bank

The Generic Insider Code is an ING code, based on the EU Market Abuse Regulation. The main purpose of this Code is to prevent ‘Generic Insiders’ to be involved in Market Abuse which includes Insider Dealing, Market Manipulation and the unlawful disclosure of Inside Information. Market Abuse harms the integrity of financial markets and public confidence in securities and derivatives. This confidence is necessary for the proper functioning of financial markets.

This Code applies to ‘Generic Insiders’ of ING Bank and ING Group employed in the Netherlands who (could) possess Inside Information and therefore are assigned as ‘Generic Insider’ and are as such governed by the (additional) rules of the Generic Insider Code Netherlands ING Bank. These rules refer, among other things to their personal account dealing in Financial Instruments, the monitoring thereof and the treatment of confidential information.

Insider Code ING Bank

The Insider Code ING Bank is an ING code, based on the EU Market Abuse Regulation. The main purpose of this Code is to prevent ‘Insiders ING’ to be involved in Market Abuse which includes for this code Insider Dealing, Market Manipulation and the unlawful disclosure of Inside Information while having inside information regarding ING. Market Abuse harms the integrity of financial markets and public confidence in securities and derivatives. This confidence is necessary for the proper functioning of financial markets.

This Code applies to ‘Insiders ING’ of ING Bank and ING Group professionally based in the Netherlands - exceptions may apply to certain employees of ING outside the Netherlands - who (could) possess Inside Information on ING and therefore are assigned as ‘Insider ING’ and are as such governed by the (additional) rules of the Insider Code ING Bank. These rules refer, among other things to their personal account dealing in ING Financial Instruments, the monitoring thereof and the treatment of confidential information.

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