ING Group Annual Report. Shaping our future

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1 ING Group Annual Report 2010 Shaping our future

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4 > ING posts 2010 underlying net profit of EUR 3,893 million > Operational separation Bank and Insurer effectuated in 2010 > Main priorities: creation of strong businesses and repayment of the Dutch State when prudent and possible > Base case scenario: divestment of Insurance through two IPOs > Steering on sound financial performance, increased customer focus, operational excellence and good corporate citizenship 2 ING Group Annual Report 2010

5 Contents 1 Who we are Key figures 4 ING at a glance 6 Chairman s statement 8 ING share 10 2 Report of the Executive Board ING and the financial environment 12 Strategy 16 Corporate responsibility 19 Capital management 22 Risk management 23 Human resources 24 Banking overview 26 Retail Banking 29 Commercial Banking 37 Insurance overview 41 Insurance 43 Investment management 52 3 Corporate governance Report of the Supervisory Board 55 Corporate governance 59 Report of ING Trust Office 71 Report of ING Continuity Foundation 74 Conformity statement 75 Section 404 Sarbanes-Oxley Act 76 Remuneration report 78 Works councils 86 4 Consolidated annual accounts Consolidated balance sheet 88 Consolidated profit and loss account 89 Consolidated statement of comprehensive income 90 Consolidated statement of cash flows 91 Consolidated statement of changes in equity 92 Accounting policies for the consolidated annual accounts 94 Notes to the consolidated annual accounts 112 Risk management 203 Capital management 249 Subsequent events Parent company annual accounts Parent company balance sheet 256 Parent company profit and loss account 257 Parent company statement of changes in equity 258 Accounting policies for the parent company annual accounts 259 Notes to the parent company annual accounts Other information Independent auditor s report 266 Proposed appropriation of result and Subsequent events Additional information Risk factors 268 Financial glossary 282 General information 289 ING Group Annual Report

6 1 Who we are Key figures ING Group in accordance with IFRS-EU in EUR million unless otherwise indicated Income Banking operations 17,734 12,293 11,662 14,602 14,195 Insurance operations 37,488 35,808 54,920 62,208 59,642 Intercompany eliminations Total 54,887 47,765 66,291 76,586 73,621 Staff expenses and operating expenses Banking operations 10,153 10,158 10,122 9,970 9,070 Insurance operations 4,341 4,387 5,449 5,498 5,269 Total 14,494 14,545 15,571 15,468 14,339 Addition to loan loss provision Banking operations 1,751 2,973 1, Result Banking result before taxation 5, ,510 5,005 Insurance result before taxation 1, ,593 6,533 4,935 Result before taxation 4,477 1,525 1,487 11,043 9,940 Taxation 1, ,535 1,907 Minority interests Net result 3, ,242 7,692 Figures per ordinary share (in EUR) Basic earnings (1) Dividend Shareholders equity (in parent) Balance sheet (in EUR billion) Total assets per 31 December 1,247 1,164 1,332 1,313 1,226 Total equity per 31 December Shareholders equity (in parent) per 31 December Core Tier 1 securities per 31 December (1) See note 49 in the Annual Accounts. FTEs and Market capitalisation Employees (FTEs, per 31 December) 107, , , , ,801 Market capitalisation (in EUR billion) ING Group evaluates the results of its businesses using a non-gaap financial performance measure called underlying result. Underlying result is derived from the result in accordance with IFRS-EU by excluding the impact of divestments and special items. Historic results have been restated for divestments in order to create a comparable sequence (i.e. 2010, 2009 and 2008 results exclude the results of a divestment which was completed in 2010). See note 51 in the consolidated annual accounts for a reconciliation between IFRS and underlying result. Underlying net result, Underlying Return on Equity and Debt/equity ratio % change 2008 Banking operations 4,322 1, Insurance operations n.a. 1,002 Underlying net result (in EUR million) 3, Underlying Return on Equity based on IFRS-EU equity 9.7% 4.2% 0.8% Debt/equity ratio per 31 December (2) 13.3% 12.4% 13.5% (2) ING Group evaluates its debt/equity ratio on the basis of core debt and adjusted equity. Further information is provided in the section Capital management in the consolidated annual accounts. 4 ING Group Annual Report 2010

7 Who we are 1 Key figures continued Banking operations in EUR million unless otherwise indicated % Change 2008 Total underlying income 17,298 13, ,631 Underlying net interest result 13,450 12, ,062 Underlying operating expenses 9,685 9, ,803 Underlying addition to loan loss provision 1,751 2, ,235 Underlying result before tax 5, Underlying net result 4,322 1, Balance sheet total ING Bank N.V. per 31 December (in EUR billion) ,035 Core Tier 1 capital ING Bank N.V. per 31 December 30,894 25, ,934 Bank core Tier 1 ratio per 31 December (1) 9.6% 7.8% 7.3% Risk-weighted assets per 31 December (in EUR billion) (1) Client balances per 31 December (in EUR billion) 1,168 1, ,074 Net production client balances (in EUR billion) Interest margin 1.42% 1.32% 1.07% Underlying Return on Equity based on 7.5% core Tier % 5.0% 3.4% Underlying cost/income ratio 56.0% 68.7% 84.3% Underlying cost/income ratio, excl. market impacts 54.2% 54.3% 65.8% Employees (FTEs, per 31 December adjusted for divestments) 72,343 70, ,249 (1) Adjusted for divestments. Insurance operations in EUR million unless otherwise indicated % Change 2008 Total underlying income 37,466 35, ,838 Investment margin 1,481 1, ,662 Fees and premium-based revenues 4,903 4, ,723 Technical margin Income non-modelled life business Operating income (Life/IM) 7,300 6, ,324 Total operating result 1,743 1, ,953 Underlying result before tax ,355 Underlying net result ,002 Shareholders equity ING Verzekeringen N.V. per 31 December 20,811 15, ,892 Client balances per 31 December (in EUR billion) Net production client balances (in EUR billion) Investment spread (basis points) New sales (APE) 4,877 4, ,917 Administrative expenses 3,698 3, ,783 Administrative expenses/operating income 43.9% 44.3% 44.2% Underlying Return on Equity based on IFRS-EU equity 1.8% 0.9% 6.3% Insurance Group Directive Solvency ratio 250% 247% n.a. Employees (FTEs, per 31 December, adjusted for divestments) 34,763 35, ,460 ING Group Annual Report

8 1 Who we are ING at a glance INCOME 54,887m 2009: 47,765m NET RESULT 3,220m 2009: 935m OUR MISSION ING aims to deliver its financial products and services in the way its customers want them delivered: with exemplary service, convenience and at competitive prices. This is reflected in our mission statement: to set the standard in helping our customers manage their financial future. OUR PROFILE ING is a global financial institution of Dutch origin, currently offering banking, investments, life insurance and retirement services to meet the needs of a broad customer base. Going forward, we will concentrate on our position as an international retail, direct and commercial bank, while creating an optimal base for an independent future for our insurance operations (including investment management). OUR STRATEGY To serve the interests of our stakeholders, increase management focus and create value for our shareholders, ING is moving towards separation of its banking and insurance operations. We believe the widespread demand for greater simplicity, reliability and transparency makes this the best course of action. In the future, ING Bank will build on its global presence and international network and capitalise on its leadership position in gathering savings, multi-channel distribution, simple propositions and marketing. ING Insurance has a strong position as a global provider of life insurance and retirement services. While moving towards the public offerings of a Europe-led and a US-focused business, ING Insurance will initially concentrate on further improving its operational performance. Both the Bank and the Insurer will focus on earning our customers trust through transparent products, value for money and superior service. This reflects ING s universal customer ideal: saving and investing for the future should be easier. OUR CUSTOMERS ING serves a broad customer base, comprising individuals, families, small businesses, large corporations, institutions and governments. OUR STAKEHOLDERS ING conducts business on the basis of clearly defined business principles. In all our activities, we carefully weigh the interests of our various stakeholders: customers, employees, business relations and suppliers, society at large and shareholders. ING strives to be a good corporate citizen. OUR CORPORATE RESPONSIBILITY ING wants to build its future on sustainable profit based on sound business ethics and respect for its stakeholders and be a good corporate citizen. For only by acting with professionalism and integrity, will we be able to maintain our stakeholders trust and preserve our reputation. Our Business Principles prescribe the corporate values we pursue and the responsibilities we have towards society and the environment: we act with integrity, we are open and clear, we respect each other and we are socially and environmentally responsible. COMPOSITION OF THE BOARDS* on 31 December 2010 EXECUTIVE BOARD Jan H.M. Hommen (67), CEO and chairman Patrick G. Flynn (50), CFO J.V. (Koos) Timmermans (1) (50), CRO (1) Nominated for reappointment as of 9 May SUPERVISORY BOARD Peter A.F.W. Elverding (1) (62), chairman Jeroen van der Veer (63), vice-chairman J.P. (Tineke) Bahlmann (60) Henk W. Breukink (1) (60) Claus Dieter Hoffmann (2) (68) Piet C. Klaver (65) Godfried J.A. van der Lugt (3) (70) Aman Mehta (64) Joan E. Spero (66) Jackson P. Tai (4) (60) Lodewijk J. de Waal (60) (1) Nominated for reappointment as of 9 May (2) Retirement as of 9 May (3) Resigned on 24 January (4) Resigned on 6 January ING Group Annual Report 2010

9 Who we are 1 ING at a glance continued BANKING INSURANCE UNDERLYING INCOME 17,298m 2009: 13,483m UNDERLYING NET RESULT 4,322m 2009: 1,194m UNDERLYING INCOME 37,466m 2009: 35,119m UNDERLYING NET RESULT 429m 2009: 220m RETAIL BANKING Retail Banking provides retail and private banking services to individuals and small and medium-sized enterprises in the Netherlands, Belgium, Luxembourg, Poland, Romania, Turkey, India, Thailand and China (through a stake in Bank of Beijing) with a multi-product, multi-channel distribution approach. In mature markets, we focus on wealth accumulation, savings and mortgages, with an emphasis on operational excellence, cost leadership and customer satisfaction. In developing markets we aim to become a prominent local player by offering simple but high quality products. ING Direct offers direct banking services in Canada, Spain, Australia, France, the US, Italy, Germany, the UK and Austria. ING Direct s focus is on offering five simple and transparent retail banking products at very low cost: savings, mortgages, payment accounts, investment products and consumer lending. COMMERCIAL BANKING Commercial Banking offers core banking services such as lending, payments and cash management in more than 40 countries. It provides clients with tailored solutions in areas including corporate finance, structured finance, commercial finance, equity markets, financial markets and leasing. Clients are corporations ranging from medium-sized and large companies to major multinationals as well as governments and financial institutions. INSURANCE BENELUX Insurance Benelux includes ING s life and non-life insurance, investment and pension businesses in the Netherlands, Belgium and Luxembourg. Insurance Benelux, already a leading player in the industry, aims to become the most efficient large insurer in the region. INSURANCE CENTRAL & REST OF EUROPE Insurance Central & Rest of Europe consists of ING s life insurance and pensions operations in nine countries which include Poland, the Czech Republic, Slovakia, Hungary, Romania, Greece and Spain as well as greenfield operations in Bulgaria and Turkey. INSURANCE US (EXCLUDING US CLOSED BLOCK VA) Insurance US includes ING s retirement services and life insurance operations in the US. In the US, ING is the third-largest provider of defined contribution retirement plans in terms of assets under management and administration. US CLOSED BLOCK VA US Closed Block VA consists of ING s Closed Block Variable Annuity business in the US, which has been closed to new business since early 2010 and which is now being managed in run-off. INSURANCE LATIN AMERICA Insurance Latin America includes ING s pension, insurance and investment businesses in the region and is present in six countries including Mexico, Chile, Peru, Colombia, Uruguay, and Brazil through its joint venture in SulAmérica, the leading independent wealth management and insurance company in the country. In Latin America, ING is the second largest provider of mandatory pensions. INSURANCE ASIA/PACIFIC Insurance Asia/Pacific is one of the major foreign life insurance companies in the region and is present in seven countries including Japan, Malaysia, South Korea, Thailand, China, Hong Kong and India. It offers life insurance, investment and retirement services products and services to a broad range of retail, corporate and institutional clients. ING INVESTMENT MANAGEMENT ING Investment Management (ING IM) is a leading global asset manager and is the principal investment manager of ING Group. It has operations in 33 countries across the Americas, Asia-Pacific, Europe and the Middle East. ING IM provides retail and institutional clients with access to domestic, regional and global investment solutions. COMMITTEES OF THE SUPERVISORY BOARD** on 31 December 2010 Audit Committee Jackson Tai, chairman Tineke Bahlmann Henk Breukink Godfried van der Lugt Jeroen van der Veer Risk Committee Peter Elverding, chairman Tineke Bahlmann Claus Dieter Hoffmann Piet Klaver Godfried van der Lugt Jackson Tai Remuneration Committee Jeroen van der Veer, chairman Peter Elverding Piet Klaver Joan Spero Lodewijk de Waal Nomination Committee Peter Elverding, chairman Piet Klaver Joan Spero Jeroen van der Veer Lodewijk de Waal Corporate Governance Committee Peter Elverding, chairman Henk Breukink Claus Dieter Hoffmann Aman Mehta Lodewijk de Waal * You can find more information on the members of the Executive Board on page 65 and on the members of the Supervisory Board on pages The names of the nominated candidates for appointment at the General Meeting on 9 May 2011 can be found on page 57. ** The current composition of the Supervisory Board Committees can be found on the Company s website (www.ing.com). ING Group Annual Report

10 1 Who we are Chairman s statement The customer is the vital axis around which all our activities revolve Jan Hommen, chairman Dear stakeholder, Looking back on 2010, we can conclude that ING closed a remarkable year in the history of the company. It was a real transition year. Throughout those 12 months we worked hard at shaping our future. We took important steps to create strong stand-alone companies in preparation for the final separation of our Banking and Insurance/Investment Management businesses. The Bank will continue as one integrated banking organisation with one management team and one balance sheet. For our Insurance/Investment Management activities we plan to have two initial public offerings (IPOs). After three challenging years during which the global financial crisis had its impact on the company, 2010 marked a significant turning point for ING. In particular, I am very grateful for the continued trust and loyalty of our customers. A number of achievements and key priorities stood out in First of all, the Group s business performance in 2010 was strong. Although the economic recovery remains fragile, and financial markets continue to be volatile, ING posted an underlying net profit of EUR 3,893 million in 2010, up from EUR 974 million a year earlier. The operational separation of the bank and insurer was effectuated at year-end, with arm s-length agreements in place between the two businesses for all commercial cooperation and shared infrastructure. The focus for 2011 will be on preparing the insurance company for two IPOs so we will be ready to move forward when market conditions are favourable. The measures taken under the Back to Basics programme, which was completed in 2010, to reduce risks, decrease costs, deleverage and reduce the size of the balance sheet, enabled us to quickly restore a healthy profitability profile. We substantially reduced our leverage and risk, actively managed our sovereign portfolio and set clear future performance targets for our banking and insurance businesses. A number of divestments were carried out. ING also comfortably passed the stress test conducted by the Committee of European Banking Supervisors. In addition, we repaid 50% of the Dutch State aid in December In May 2011, we intend to repay another 20%. Provided that the strong capital generation continues, we intend to repay the final 30% by May In 2010, we were faced with changes in the regulatory environment which will have an impact on the business models of both our banking and insurance businesses and the way we manage our company. Proposals were made by the regulatory authorities to increase capital, liquidity and risk requirements for banks and insurance companies (Basel III, Solvency II). ING spent much effort to prepare for these changes in the regulatory environment. 8 ING Group Annual Report 2010

11 Who we are 1 The requirements proposed by the Basel Committee will demand stronger capital reserves and liquidity buffers to protect banks during economic downturns. Most of the requirements will not come into force until 2013, but ING is relatively well positioned to meet them. Also with regard to our remuneration policy we take into account the globally changing views on remuneration policies as well as the guidelines proposed by regulators and authorities. We are well aware that remuneration is subject to ongoing public debate and we have taken steps to ensure that our remuneration policy strikes a balance between the interests of our customers, employees, shareholders and society at large, and supports the long-term objectives of our company. ING formulated a new moderate and sustainable remuneration policy with both individual and group objectives for the Executive Board with an increased focus on long-term value creation and performance measurement based on non-financial indicators. This new policy was approved by the AGM in April The general principles of the new policy have also been applied to the remuneration of the members of the Management Boards and other senior managers throughout the organisation. Our strong results are the outcome of the hard work and dedication of all our employees who even in the most difficult periods of the crisis continued to focus on servicing our customers. Customer satisfaction is central to everything ING does. The customer is the vital axis around which all our activities revolve and we will continue to take customer needs as the starting point for everything we do, whether it is developing new products, fine-tuning processes or anything else. Over the year we achieved a great deal in this area but much more remains to be done. We use the Net Promoter Score to measure what customers think of us and whether they would recommend ING to others, and then use the feedback to make further improvements to our processes and products. Deepening relationships with all our stakeholders was a key priority in It is vital to engage in dialogue with all stakeholders and to be more transparent and open for feedback about the way we operate. Gathering their views has proved valuable and, where possible, we have incorporated feedback into our products and services. As a major international company, ING has a responsibility to make a positive contribution to society through its commercial activities and by being a good corporate citizen. For example, our personal financial services help people to be better at managing their money. We have a Corporate Responsibility (CR) programme through which we ran many initiatives in 2010, one of which was a series of workshops for entrepreneurs advising them how to run their businesses in a more environmentally sustainable way. Improving financial and other types of education is an important part of our CR strategy. We are proud of our Chances for Children programme through which we provide underprivileged children with quality education to give them a real chance of a better future. I was especially pleased with the 2010 Chances for Children Global Challenge. Staff and management throughout the company rolled up their sleeves to volunteer and raise funds for children and education-related projects in what has become a great annual tradition at ING. 38 countries took part in 2010 s Global Challenge and over 20,000 ING employees were involved. We raised EUR 927,000. You can read more about this and many other initiatives in the chapter on Corporate responsibility. Our employees are our human capital. Engaged and motivated employees are central to our success as they are the main point of contact with our customers. In 2010, ING continued to work towards being a top employer, to attract and retain employees and to enhance employee engagement. Our 2010 Winning Performance Culture Survey showed that throughout the ING Group employee engagement had risen. Most people say they like their job and are proud to work for the company. I am very pleased with the outcome of the survey because it was not an easy year for our people given all the changes the company went through. In January 2011, Godfried van der Lugt and Jackson Tai both resigned from the Supervisory Board. In 2011, Claus Dieter Hoffmann will retire from the Supervisory Board after the General Meeting. On behalf of my colleagues in the Executive Board and Supervisory Board, I would like to take this opportunity to express my sincere gratitude and appreciation for the contribution they have made to ING. Godfried van der Lugt witnessed the beginning of ING and as a former chairman of the Executive Board of ING Group and as a member of the Supervisory Board he has played a very valuable role in the development of the company which has greatly benefited from his expertise. We also announced changes in the structure and composition of the Management Boards for Banking and Insurance/Investment Management. On 1 January 2011, Lard Friese and Gilbert Van Hassel joined the Management Board Insurance. At the end of 2010, Tom McInerney stepped down as Insurance/Investment Management chief operating officer. William Connelly has been appointed CEO of Commercial Banking and joined the Management Board Banking, succeeding Eric Boyer who from 1 January 2011 has concentrated solely on his role as vice-chairman of the Bank. As I stated, 2010 was a year of real transition for ING. We have gone through a lot of change and reshaped our businesses. We know there are more challenges and opportunities ahead and we stand ready to meet them. Being a major player in the financial sector puts us constantly in the spotlight. Regaining the trust of all our stakeholders following the global financial crisis is a key priority for us. Our achievements in the past year lead us to believe that the business is on a solid footing and has excellent growth prospects. We therefore look forward to the future with confidence and optimism. Jan Hommen chairman of the Executive Board ING Group Annual Report

12 1 Who we are ING share PROFIT RETENTION AND DISTRIBUTION POLICY ING Group s profit retention and distribution policy is determined by its internal requirements and its growth opportunities on the one hand and the capital providers dividend expectations on the other. ING Group s internal needs are determined by statutory solvency requirements and capital ratios, in excess of which ING Group needs to maintain healthy buffers. An important determinant are the credit ratings which are of utmost importance to ING Group, because they directly affect the company s financing costs and hence profitability. For their part, the capital providers expect a dividend which reflects ING Group s financial results and is relatively predictable. ING s policy is to pay dividends in relation to the long-term underlying development of cash earnings. Dividends will only be paid when the Executive Board considers such a dividend appropriate. Given the uncertain financial environment, increasing regulatory requirements and ING s priority to repurchase the remaining outstanding core Tier 1 securities, the Executive Board will not propose to pay a dividend over 2010 at the annual General Meeting. CORE TIER 1 SECURITIES In October 2008, to support its capital position, ING Group made use of the previously announced capital support facilities by the Dutch Government by issuing EUR 10 billion of core Tier 1 securities to the Dutch State with a coupon of 8.5%. The core Tier 1 securities are pari passu with common equity. In December 2009, ING repurchased the first half of the core Tier 1 securities of EUR 5 billion plus a total premium of EUR 605 million. Furthermore, at the next coupon reset date on 13 May 2011, ING intends to exercise its option for early repurchase of EUR 2 billion of the remaining core Tier 1 securities. The total payment in May 2011 will amount to EUR 3 billion and includes a 50% repurchase premium. ING will fund this repurchase from retained earnings. Provided that the strong capital generation continues, ING intends to repurchase the remaining EUR 3 billion of the core Tier 1 securities ultimately by May 2012 from retained earnings. The final decision on repurchase of these core Tier 1 securities will be made before the envisaged repayment date and will be conditional upon there having been no material changes regarding ING s capital requirements and/or ING s outlook on external market circumstances. LISTINGS Depositary receipts for ING Group ordinary shares are listed on the stock exchanges of Amsterdam, Brussels and New York (NYSE). Options on ING Group ordinary shares (or the depositary receipts therefor) are traded on the NYSE Euronext Amsterdam Derivative Markets and the Chicago Board Options Exchange. Authorised and issued capital Year-end 2010 Year-end 2009 in EUR million Ordinary shares authorised 1,080 1,080 issued Cumulative preference shares authorised 1,080 1,080 issued Shares in issue and shares outstanding in the market Year-end 2010 Year-end 2009 in millions (Depositary receipts for) ordinary shares of EUR 0.24 nominal value 3, ,831.6 (Depositary receipts for) own ordinary shares held by ING Group and its subsidiaries (Depositary receipts for) ordinary shares outstanding in the market 3, ,784.5 Prices depositary receipts for ordinary shares* Euronext Amsterdam by NYSE Euronext in EUR Price high Price low Price year-end Price/earnings ratio** 8.6 *** *** * 2009 prices were adjusted for the increase in the number of shares due to the rights issue, while 2008 was not adjusted. ** Based on the share price at year-end and net profit per ordinary share for the financial year. *** Not applicable. Dividend history in EUR Interim dividend 0.74 Final dividend Total 0.74 Geographical distribution of ING shares* in percentages United States 38 Netherlands 25 United Kingdom 17 Switzerland 7 Belgium 5 Luxembourg 3 Other 5 Total 100 * Year-end 2010 figures, estimated on information provided by several large custodians. SHAREHOLDERS AND DEPOSITARY-RECEIPT HOLDERS WITH STAKES OF 5% OR MORE To the best of our knowledge, as at 31 December 2010, there were no shareholders or holders of depositary receipts for shares who reported to hold an interest of 5% or more as mentioned in the Dutch Financial Supervision Act, other than Stichting ING Aandelen (ING Trust Office) and Stichting Continuïteit ING (ING Continuity Foundation). 10 ING Group Annual Report 2010

13 Who we are 1 ING share continued INVESTOR RELATIONS To be kept informed of press releases and other ING news, you can subscribe to the service through our Investor Relations section at INVESTORS AND FINANCIAL ANALYSTS MAY CONTACT: ING Group Investor Relations (IH ) P.O. Box AV Amsterdam The Netherlands Telephone: Fax: IMPORTANT DATES IN 2011* Publication results 1Q 2011 Thursday, 5 May 2011, 7:30 a.m. Annual General Meeting Monday, 9 May 2011 Publication results 2Q 2011 Thursday, 4 August 2011, 7:30 a.m. Publication results 3Q 2011 Thursday, 3 November 2011, 7:30 a.m. * All dates shown are provisional. Main credit ratings of ING* Standard & Poor s Moody s Fitch ING GROUP** A A1 A ING BANK*** short term A-1 Prime-1 F1+ long term A+ Aa3 A+ financial strength C+ ING INSURANCE**** short term A-2 Prime-2 F2 long term A Baa1 A * Still valid on 14 March 2011, the date of this Annual Report. ** All ratings on ING Group have a stable outlook. *** All Bank long-term ratings have a stable outlook. **** All Insurance long-term ratings have a negative outlook. ING s long-term credit ratings are shown in the table above. Each of these ratings reflects only the view of the applicable rating agency at the time the rating was issued, and any explanation of the significance of a rating may be obtained only from the rating agency. A security rating is not a recommendation to buy, sell or hold securities and each rating should be evaluated independently of any other rating. There is no assurance that any credit rating will remain in effect for any given period of time or that a rating will not be lowered, suspended or withdrawn entirely by the rating agency if, in the rating agency s judgement, circumstances so warrant. ING accepts no responsibility for the accuracy or reliability of the ratings. One-year price development ING depositary receipts for shares Index 31 December 2009 = 100 in EUR /10 03/10 05/10 07/10 09/10 11/10 01/11 ING FTSE 300 Banks FTSE 300 Life Ins ING Group Annual Report

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