ING LEASE UK GIFTS, ENTERTAINMENT AND ANTI-BRIBERY POLICY

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1 ING LEASE UK GIFTS, ENTERTAINMENT AND ANTI-BRIBERY POLICY 1

2 CONTENTS Statement from the Board of ING Lease (UK) Limited POLICY 1. Introduction 2. Objectives 3. Scope 4. Definitions 5. Rules on Gifts and Entertainment 5.1 General rules 5.2 Specific rules on Entertainment 5.3 Specific rules on Gifts 5.4 Government Officials and State owned companies and enterprises 5.5 Reporting violations of The Policy 5.6 Third Parties 6. Books and record keeping 7. Responsibilities 7.1 Employees 7.2 Management 7.3 Compliance Officer 8 Guidance and training 9 Sanctions for non compliance 10 Exceptions, Deviations and Waivers 11. Monitoring and Reporting Appendix 1: Gifts and Entertainment limits for non government officials Appendix 2: Gifts and Entertainment limits for government officials 2

3 BRIBERY ACT 2010 STATEMENT FROM THE BOARD OF ING LEASE (UK) LIMITED ING Lease (UK) Limited (the "Company") does not tolerate any form of bribery and corruption. This policy extends to all the Company's business dealings and transactions and it is given force in a detailed anti-bribery programme which is regularly revised to capture changes in law, reputation demands and changes in the business. The programme includes the assessment of bribery risk in relation to business operations; the review of the activities of third parties when performing services for or on behalf of the Company; policies and procedures for record keeping and staff support; training of relevant staff and offering such training to relevant third parties; and review of implementation of the programme by senior management. All Directors, employees and others who perform services on behalf of the Company are required to comply with this policy. 3

4 ING Gifts, Entertainment and Anti-Bribery Policies 1. Introduction The ING Business Principles state that ING expects the highest level of personal conduct by all its employees. In any event, bribery is unacceptable and unlawful, and it is a condition of employment of all employees of ING Lease (UK) and a condition of the engagement of any other third party who performs services for or on behalf of ING Lease (UK) that they do not engage in bribery in the performance of their functions. The ING Group Gifts, Entertainment and Anti-Bribery Policy ( The Policy ) expands upon these principles. The attention of employees is drawn in particular to the Bribery Act 2010 (the Act ) and to the criminal offences which may be committed by individuals and by the company in relation to bribery. The Act came into force on 1 July 2011 and imposes criminal liability on the part of both ING and individuals. In particular, the Act updates and consolidates existing law and substantially increases the penalties. An individual may face unlimited fines, imprisonment for up to ten years and director disqualification for an act of bribery, while ING may face unlimited fines, disbarment from tendering for public contracts throughout the EU and of course reputational damage. Although the Act contains a number of offences, the offence of bribery in the UK context is, broadly, committed where a person offers, promises or gives a financial or other advantage to another person, intending the advantage to bring about the improper performance by another person (not necessarily the recipient of the advantage) of a relevant function or activity, or to reward such improper performance. The offence is also committed where the person offering, promising or giving the advantage knows that the acceptance of the advantage is itself the improper performance of a relevant function or activity. The concept of the improper performance of a relevant function or activity relates to the breach of an expectation that a person will act in good faith, impartially or in accordance with a position of trust, in terms of what a reasonable person in the UK would expect. The provisions cover bribery in both the public and private sectors. Note that different rules apply in relation to dealings with foreign public officials ( FPOs ). As ING Lease (UK) does not operate outside the UK, the issue of dealing with FPOs is not considered further in this Policy. However, any ING Group employee, or any other person who performs services for or on behalf of any part of the ING Group, is covered by these rules and they, and ING, may be liable in case of breach. It is therefore the responsibility of such persons to familiarise themselves with the rules under the Act relating to dealing with FPOs and to ensure full compliance. Offering business Gifts and Entertainment is a customary way to strengthen business relationships and, so long as it does not amount to actual or attempted bribery, is a lawful business practice. Therefore, an invitation to an introducer to attend a sports event as part of a public relations exercise designed to cement good relations or enhance knowledge in ING s field is unlikely, of itself, to be evidence of an intention to induce improper performance of a relevant function. 4

5 Accordingly, employees may offer and accept appropriate, proportionate and lawful Gifts and Entertainment in connection with their ING work with customers and other, governmental or non-governmental, business parties, provided that all such Gifts and Entertainment are offered and accepted in a transparent way, are allowed within the limits set out in The Policy and do not expose the employee or ING to any risk of an accusation that in doing so, there was an intention to induce improper performance of a relevant function. In summary, you may not in particular offer, promise or give Gifts and Entertainment or Anything of Value, directly or through a third party, if your intention is that these should induce the actual or intended recipient or another person, such as the recipient's spouse, partner, friend or relative, to perform their own functions or activity in breach of an expectation of good faith, impartiality or trust. You may also not do so where you know or believe that the acceptance of the Gifts and Entertainment or Anything of Value would itself breach such an expectation on the part of the recipient or related person. Similarly, neither you nor your spouse, partner, friend or relative may request, agree to receive or accept any financial or other advantage in such circumstances. 2. Objectives of the Policy Protect ING Lease (UK), the ING Group and their staff from actual or perceived conflicts of interests associated with Gifts and Entertainment; Form part of the adequate procedures designed to prevent bribery put in place by ING Lease (UK), in order to have the defence available under section 7(2) of the Bribery Act 2010 to an allegation that it has committed the offence in section 7(1); Ensure that all our business dealings, either directly or indirectly, with Government Officials or third party private entities are conducted in a context that is free from bribery and free from the appearance of bribery; and Ensure we maintain accurate and transparent records. 3. Scope of the Policy The Policy applies to all employees of ING Lease (UK) together with all of our Third Parties e.g. Brokers. 4. Definitions Anything of Value: Any financial or other advantage to any other person, including, but not limited to, Cash or cash equivalents, loans, fees, rewards, the purchase of property or services, Gifts, Entertainment, cars, jewellery, home improvements, intangible benefits, travel and stocks. Bribe: An offer, promise, provision or receipt of Anything of Value, to or from any person, intending the recipient or any other person to "perform improperly" a "relevant function or activity", or knowing 5

6 or believing that its acceptance would itself constitute the improper performance of a relevant function or activity. A "relevant function or activity" includes, whether carried out in the UK or anywhere else, any function of a public nature; any activity connected with a business, including any trade or profession; any activity performed in the course of a person's employment; and any activity performed by or on behalf of a company, partnership or association. The term "perform improperly" encompasses the performance of the relevant function or activity in breach of an expectation of good faith or impartiality, or in breach of a position of trust. Charitable contributions: Payments made without demand or expectation of business return, solely for the benefit of society, for charitable, education, social welfare and similar causes, to bona fide charities, that is, charities which are registered with the Charity Commission for England and Wales, the Office of the Scottish Charity Regulator or an equivalent charity regulator elsewhere. Employees must first obtain written approval from Management and the Compliance Officer before making any Charitable Contributions on ING s behalf. Cash and cash equivalents: Payments in currency or anything that is directly convertible to currency, including cheques, equities or other securities. Entertainment: Any benefit provided to an ING employee or related individual (e.g. spouse, children, other family member or friend) by an external party* or provided by an ING employee to an external party in the form of: Meals, drinks, visits to theatres, other venues, etc.; Tickets to events (e.g., invitations to concerts, exhibitions, sporting events); or Personal events at discounted rates (e.g., travel or accommodation arrangements, etc.). * If the external party is not present then this is categorised as a Gift. Gifts: Any benefit (both monetary and non-monetary) other than Entertainment provided to an ING employee or related individual by an external party or provided by an ING employee to an external party. Benefits include services and the provision of goods at no cost to the recipient or at a price below market value. 6

7 Gifts do not include any item that: Is one of a number of identical promotional items that are widely distributed (e.g., branded pens, diaries, USB sticks, desk sets, promotional materials, other items marked with a corporate logo, etc.); or Is covered by the definition of Entertainment. Government Official: Any individual who holds a legislative, administrative or judicial position of any kind, whether appointed or elected, within the United Kingdom or elsewhere or at a local, regional or national level; Any individual who exercises a public function for or on behalf of any public agency or public enterprise within the United Kingdom or elsewhere; Any individual who is an official, or agent of a public international organisation such as the European Commission or any other institution of the European Union; Any government controlled party; Any other person acting in an official capacity for or on behalf of the government or its controlled party; Employees of state-owned companies and enterprises or controlled commercial enterprises; and Political parties, their officials, and candidates for public office. Management: The directors of ING Lease (UK). Third Parties: Entities or persons who perform services for or on behalf of ING Lease (UK). Examples include, but are not limited to, employees of any other parts of ING, distributors, intermediaries, agents, brokers, advisers, consultants, public affairs consultants, vendors and joint venture partners. 5. Rules on Gifts and Entertainment 5.1 General rules An ING employee may not, directly or through a third party, offer, promise or give to, or request, agree to receive or request from, any Third Party or Government Official any Gifts or Entertainment if: 7

8 By doing so, the employee would violate The Policy; The Gifts or Entertainment could be perceived as a Bribe; Doing so is dishonest, illegal or misleading; or By doing so, the recipient appears to be under any obligation. Never solicit, accept or offer Gifts in Cash or cash equivalents, with the exception, subject to following paragraph, of making Charitable contributions. Gifts or Entertainment at a private address cannot be offered or accepted. If ING Lease (UK) or any other part of ING has any connection with the charity, for example if any officer or employee is a trustee or is otherwise involved in the management or administration of the charity, or if a trustee or anyone else connected with the charity is in a position to provide business contacts, commercial opportunities, access to government officials or any other benefit to ING Lease (UK) or any other part of ING, then the contribution must be authorised before it can be made. As per the ING Business Principles, ING are not permitted to make Gifts or donations to political parties or candidates for political office. Gifts and Entertainment offered by suppliers and vendors should be treated with extra caution. Where the member of staff is responsible for choosing between suppliers or vendors, such Gifts and Entertainment should be declined unless Management approval is obtained after consulting the Compliance Officer. Any Gift or Entertainment offered or accepted by an ING employee must be reasonable (see below) in cost, quantity and frequency. The circumstances and local customs determine what should be considered excessive. Any gift or Entertainment should reflect a desire to cement good relations and show appreciation, and promotional expenditure should seek to improve the image of ING Lease (UK) as a commercial organisation, to better present its services, or establish cordial relations. The recipient of any Gift or Entertainment must not be given the impression that they are under an obligation to confer any business advantage or that the recipient s independence will be affected. Employees must consult Management and the Compliance Officer if it is ever unclear whether a Gift or Entertainment complies with this Policy. When there is any doubt, Employees must decline the Gift or Entertainment. The above general rules apply also to Third Parties. Employees are responsible for ensuring compliance with the general rules by any Third Party with whom they have contact or in respect of whose services, where provided for or on behalf of ING, they have any responsibility. 5.2 Specific rules on Entertainment The limits for Entertainment offered and received are detailed in Appendix 1 Entertainment that includes travel and accommodation may not be accepted or offered. 8

9 However, ING employees may accept tickets to events provided they pay the travel and accommodation expenses themselves. The travel and accommodation costs may be reclaimable from ING subject to Management approval; If refusing Entertainment raises difficulties, the employee must inform Management and obtain permission to accept. In this case, the employee must donate the value of the accepted Entertainment to a charity nominated by ING. In this instance, the person offering the Entertainment should be notified of this fact. Entertainment should not involve activities, products, or venues that might embarrass ING or be considered in bad taste by ING or by the recipient or that might violate ING Group Business Principles or ING Lease (UK) visions and values or if there is reason to believe that the recipient will attempt to conceal it. Exceptions: Management can, in exceptional circumstances, seek a waiver to the rules if thought to be necessary. In such a case the written support of the ING Lease (UK) Compliance Officer must be obtained and permission sought from the Appropriate member of the executive board and the Business Line Compliance Officer, and the General Manager Compliance ING Group. In case of major sponsoring programmes organised by ING, specific stipulations may be issued by the ING person responsible for the sponsoring programme where Entertainment exceeding 500 (approximately 450) may be appropriate. These stipulations can be found on the Corporate Compliance intranet; Entertainment including the reasonable costs of travel and accommodation may be accepted when it is offered in connection with a bona fide, publicised industry association event, training or educational meeting or business conference. Management has to approve this Entertainment after obtaining written support from the local Compliance Officer. Entertainment with a value of under 50, providing it does not violate the Policy, could not be perceived as a bribe, is not dishonest, illegal or misleading or give the appearance of putting the recipient under an obligation, is considered as nominal and does not fall under this Policy. 5.3 Specific rules on Gifts The limits for Entertainment offered and received are detailed in Appendix 1 Any gift which is not proportionate and reasonable, and which is not consistent with the normal business practice of developing and maintaining a business relationship, may not be accepted or offered. If refusing a Gift raises difficulties, the recipient must inform Management. In these situations the value of the accepted Gift should be donated to a charity nominated by 9

10 ING. If the original recipient makes use of the Gift, he/she must make a donation of the value of the Gift to a charity nominated by ING. Gifts should not involve products or services that might embarrass or be considered in bad taste by the recipient or that might violate ING Business Principles or if there is reason to believe that the recipient will attempt to conceal it.. Exceptions: Management can seek, in exceptional circumstances, a waiver to the rules if thought to be necessary based on local Circumstances. The written support of the ING Lease (UK) Compliance Officer must be obtained and permission sought from the Appropriate member of the executive board and the Business Line Compliance Officer, and the General Manager Compliance ING Group. 5.4 Government Officials and state owned companies and enterprises Whilst this Policy does not prohibit legitimate business interactions with Government Officials or state-owned companies and enterprises Gifts or Entertainment of any amount increase the perception of Bribery and are consequently subject to stricter rules governing the offering or receipt of Gifts and Entertainment (or other financial advantage). In particular, it can be an offence to offer Gifts or Entertainment to Public Officials to induce them to take or reward them for taking any action that is intended to retain or obtain business or an advantage in business. Some countries have even stricter laws. Before offering Gifts or Entertainment to foreign public officials, Management and the Compliance Officer should seek advice from their respective counterparts in the country or jurisdiction from which the foreign public official is located in order to ensure that foreign market practice and applicable standards are complied with. Before, offering Gifts or Entertainment to Government Officials, you must first: Ensure that the Gift or Entertainment does not exceed the mandatory threshold or limit outlined in Appendix 2; Obtain written authorisation from Management and written support from the Compliance Officer; and Maintain appropriate records to show compliance with the above rule Facilitation payments are strictly prohibited. You must immediately report any requests for facilitation payments to the Compliance Officer. Gifts and Entertainment or other advantages for closely related individuals of Government Officials can never be offered 5.5 Reporting violations of The Policy Any (appearance of) violation of the rules must be promptly reported to the Compliance Officer. The report can also be filed anonymously in accordance with the ING Group Whistleblower Procedure (see this on the ING Lease (UK) Compliance intranet site). 10

11 5.6 Third Parties Under anti-bribery legislation, the actions of Third Parties can also expose ING to liability. All ING employees must act in good faith to ensure that any entity or person for or on behalf of ING will not make, promise, offer or authorise a payment of Anything of Value, either directly or indirectly to any other party, including but not limited to any Government Official, which may be perceived as a Bribe or as an inducement to influence any act or decision by such party, or as an inducement to do or omit to do something which is dishonest, illegal or a breach of trust, in the conduct of business. Reasonable due diligence must be undertaken before ING enters into any relationship with a Third Party in order to establish as far as possible that the Third Party will not offer or receive, or attempt to offer or receive, a Bribe to any other party, including but not limited to any Government Official, and that retaining the Third Party cannot be construed as a Bribe. Management of ING Lease (UK), advised by the Compliance and Legal departments, must undertake a risk assessment of all new and existing relationships with Third Parties, in order to determine which relationships have the potential to expose ING to liability under anti-bribery legislation. Where such risk is elevated, for example where the Third Party concerned is likely to deal with Government Officials, Management is expected to take reasonable steps, which could include: Providing a copy of The Policy to the Third Party and explaining to them that they are expected to comply with the anti-bribery and training requirements therein; Negotiation or renegotiation of the contract to incorporate relevant terms to indicate acceptance of the anti-bribery requirements of The Policy, to include a provision to allow termination of the contract in the event that the anti-bribery requirements of The Policy are violated by the Third Party; Encouraging Third Parties to contact the ING Lease (UK) Compliance Officer for any further guidance that they might require with respect to this Policy. When a Third Party which has been identified as high risk refuses to accept these steps, Management should consider terminating that relationship. Gifts and Entertainment must not be intended to influence any decision or act of any Government Official. Any employee seeking to provide Gifts, Entertainment, or social amenities to a Government Official should obtain written authorisation from Management who will require the written support from the Compliance Officer. Appropriate records to show compliance with the above rules must be maintained. In certain circumstances, it may be appropriate to pay for the travel or lodging of Government Officials (or provide similar services) if it is directly necessary for and related to a genuine business purpose. For example, it may be appropriate to provide travel and lodging expenses for a Government Official in connection with the promotion or demonstration of ING products or services. Payment of any travel or lodging expenses in these circumstances should be made only if doing so is widely accepted, customarily practised and permissible under UK law. 11

12 Cash payments are prohibited when paying for the travel expenses for a Government Official. Any employee seeking to pay travel and lodging expenses for a Government Official should obtain written authorisation from Management who needs written support from Compliance Officer. Appropriate records to show compliance with the above rules must be maintained. No expenses should be incurred or reimbursed for spouses or family members of Government Officials without prior approval of the General Manager Compliance ING Group. Management must ensure appropriate monitoring of Third Parties compliance with their antibribery agreements and ensure the appropriate level of monitoring of Third Parties and ensure periodic due diligence reviews. Management, in consultation with the local Compliance Officer, establishes the frequency of monitoring and periodic reviews. The Third Party review method must be reasonably balanced in light of the assessed Third Party risk. A review may be triggered before the planned date. When this happens, Management is encouraged to re-evaluate the Bribery risk for the Third Party to determine if the Bribery risk has changed. 6. Books and record keeping Management must ensure that all Gifts and Entertainment given and received are recorded in reasonable detail, accurately and fairly reflect the transactions and disposition of the assets in the businesses accounting / financial reporting system. ING Lease (UK) s accounting / financial reporting system must, in reasonable detail, accurately and fairly reflect all transactions and dispositions of the company s assets, including all Gifts and Entertainment given as well as Charitable Contributions made. Therefore, all Managers who are involved in the upkeep of the business accounting system must ensure this accuracy at all times, and must direct relevant Employees accordingly. A record of all Gifts and Entertainment above 50 provided to external persons and accepted by ING employees must be maintained. A template for the registers is provided in Appendix 3. Note that all Gifts and Entertainment given or received from Government Officials must be recorded in the Gifts and Entertainment register regardless of the amount. Off the books transactions, slush funds and falsifying records are strictly prohibited. 7. Responsibilities 7.1 Employees Employees are responsible for: Complying with all elements of The Policy; Reporting any (appearance of) violation of any element of The Policy to the Compliance Officer or, where they are uncomfortable with this or want to remain anonymous, through 12

13 the Whistleblower Procedure. 7.2 Management In order to ensure that the ING Lease (UK) policies and procedures to prevent bribery are embedded into all aspects of ING Lease (UK)'s activities and form part of the culture of compliance with anti-bribery principles and laws by ING, Management is responsible for the full implementation of the ING Group Gifts, Entertainment and Anti-Bribery Policy and in particular for ensuring that: The Gifts and Entertainment registers are updated; All staff are informed and fully trained about the requirements set out in this Policy; A risk assessment is conducted with respect to the anti-bribery provisions of this Policy for all new and existing Third Parties; Compliance with this Policy and laws and regulations is monitored. 7.3 Compliance Officer Acting under the authority of Management, the Compliance Officer is responsible for: In consultation with Management, developing such procedures as are necessary to implement this Policy and to comply with laws and regulations; Assisting Management with the implementation of this Policy and providing guidance to Employees; Assisting Management with the communications and training needs associated with the implementation of this Policy; Monitoring the implementation of this Policy; and Reporting any unauthorised Gifts and Entertainment as part of the quarterly Compliance reporting process. 8. Guidance and training Please note the guidance does not provide answers for all possible situations. In particular, the Bribery Act 2010 does not yet have a history of enforcement and judicial decisions which would assist in assessing easily the parameters of compliance with its requirements. If you have any questions regarding the Policy please contact the local Compliance Officer. Corporate Compliance will from time to time mandate training on this Policy, including training on chapter 5 to specific target groups. Ongoing training and training of relevant newly hired staff and logging of attendance will be the responsibility of the business, and will be monitored by the local Compliance Officer. 13

14 9. Sanctions for non compliance Under the Bribery Act 2010 and other applicable legislation, violations of the provisions in The Policy could result in civil and criminal penalties, and other sanctions, against ING and could also subject directors and employees to prosecution, criminal fines, imprisonment and other sanctions. Note that the US Foreign Corrupt Practices Act states that fines and penalties imposed upon individuals often may not be paid directly or indirectly by any corporation for which they may have acted. Failure to comply with any aspect of The Policy may be grounds for disciplinary action, including termination of employment. 10 Exceptions, deviations and waivers Management must ensure that exceptions, deviations and waivers are in accordance with ING s established procedures. Only the Chief Compliance Officers of ING Group and ING Bank can grant exceptions from this Policy in respect of Government Officials, including state-owned companies and enterprises, Third Parties, Political Donations and Charitable Contributions. Any such exceptions must be made in writing. For all other provisions, Management may authorise an exception from this Policy under specific circumstances. Before doing so, Management must first obtain written support from their Compliance Officer and the next higher level Compliance Officer. If Management wishes to deviate from this Policy by using a different method to meet the obligations or wishes to obtain a waiver to exclude any of the other Policy s obligations relating to this Policy, Management must follow the relevant ING waivers policies / guidelines. 11. Monitoring and Reporting In consultation with the Compliance Officer, Management must establish 1st Line of Defence tracking activities and 2nd Line of Defence monitoring activities to ensure: the obligations in this Policy are fully implemented into the business and are working; and appropriate monitoring of Third Party adherence to this Policy. Periodically, Management and the Compliance Officer will be required to report on the status of implementation, tracking and monitoring activities and to immediately report issues in relation to this Policy. 14

15 Appendix 1 Gifts and Entertainment limits for non Government Officials GIFTS - EMPLOYEES MAY Offer Gifts Up to a maximum of 100 euros ( 85 local currency equivalent) To a single external party / entity / person Not to exceed an annual cumulative value of 500 euros ( 440 local currency equivalent) per person / entity Receive Gifts Up to a maximum of 100 euros ( 85 local currency equivalent) From a single external party / entity / person Not to exceed an annual cumulative value of 500 euros ( 440 local currency equivalent) per person / entity Offer Entertainment Up to a maximum of 500 euros ( 440 local currency equivalent) per occasion ENTERTAINMENT - EMPLOYEES MAY To a single external party / entity Can be offered up to 3 times per year per person / entity Not to exceed a cumulative value of 1500 euros ( 1300 local currency equivalent) per person / entity Receive Entertainment Up to a maximum of 500 euros ( 440 local currency equivalent) per occasion From a single external party / entity Can be accepted up to 3 times per year per person / entity Not to exceed a cumulative value of 1500 euros ( 1300 local currency equivalent) per person / entity 15

16 Appendix 2 Gifts and Entertainment limits for Government Officials GIFTS - EMPLOYEES MAY: Offer Gifts Up to a maximum of 30 euros ( 26 local currency equivalent) To a single external party / entity Can be offered a maximum of one (1) time per year Receive Gifts Up to a maximum of 30 euros ( 26 local currency equivalent) From a single external party / entity Can be accepted a maximum of one (1) time per year Offer ENTERTAINMENT EMPLOYEES MAY: Entertainment Up to a maximum of 160 euros ( 140 local currency equivalent) To a single external party / entity Can be offered a maximum of one (1) time per year Receive Entertainment Up to a maximum of 160 euros ( 140 local currency equivalent) From a single external party / entity Can be accepted a maximum of one (1) time per year 16

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