Global Reporting Initiative (GRI) Index

We have selected the topics based on guidelines from the Global Reporting Initiative (GRI). Our financial services reporting relies on the format contained in GRI annexes.

Profile

Strategy and analysis
- 1.1 Chairman’s statement
  
  Please see page 2 and 3 of our CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- 1.2 Key impacts, risks and opportunities
  
  Please see page 12 to 23 of our CR Report 2010, available for download at www.ingforsomethingbetter.com/report
Organisational profile
- 2.1 Name of reporting organisation
  
  ING Groep N.V.
- 2.2 Products, services and brands
  
  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). For a full overview of our products, services and brands, please visit www.ing.com
- 2.3 Operational structure
  
  Please see page 60 to 62 of our Annual Report 2010 , available for download at www.ing.com
- 2.4 Location of head office
  
  Amstelveenseweg 500, 1081 KL Amsterdam
  P.O. Box 810, 1000 AV Amsterdam
  The Netherlands
  Telephone +31 20 5415411
  Fax +31 20 5415444
  Commercial Register of Amsterdam, no. 33231073
- 2.5 Countries of operation
  
  Please see our country list, available on www.ingforsomethingbetter.com/local
- 2.6 Nature of ownership and legal form
  
  Please see page 60 to 62 of our Annual Report 2010, available for download at www.ing.com
- 2.7 Markets served
  
  For an overview of our banking operations, please see page 26, 27, 28 and 30 of our Annual Report 2010, available for download at www.ing.com
  
  For an overview of our insurance operations, please see page 41, 42, 43, 44 and 45 of our Annual Report 2010, available for download at www.ing.com
- 2.8 Scale of the organisation
  
  Please see the inside front cover in our CR Report 2010, available at www.ingforsomethingbetter.com/report
- 2.9 Changes during reporting period
  
  Please see our Press Room on www.ing.com
- 2.10 Awards received
  
  We publish news about awards ING receives in the news section of www.ingforsomethingbetter.com or on www.ing.com . See page 55 of the CR report 2010 for Award Meilleure practique d'egalite entre les femmes et les hommes dans les entreprises 2010. And see page 35 and 45 for award in the Annual report 2010.
Report parameters
- 3.1 Reporting period
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.2 Most recent previous report
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.3 Reporting cycle
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.4 Contact point
  
  Please see the back cover of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.5 Defining the report content
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report . See page 14, 15, 16 and 17 for our stakeholders.
- 3.6 Boundary of the report
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.7 Specific limitations of the boundary
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.8 Basis for reporting on joint venture
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.9 Data measurement techniques
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.10 Restatements
  
  For changes see page and 98 of the CR report 2010. Report is available for download at www.ingforsomethingbetter.com/report
- 3.11 Significant changes
  
  Please see page 97 and 98 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
- 3.12 GRI Index
  
  Please see www.ingforsomethingbetter.com/gri
- 3.13 Assurance
  
  Please see page 84 and 85 of the CR report 2010, available for download at www.ingforsomethingbetter.com/report
Governance, Commitments and Engagement

Structure and governance
- 4.1 Governance structure
  
  Please see page 96 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
  and page 59 to 68 of the Annual Report 2010, available for download at www.ing.com
- 4.2 Function of CEO
  
  Please see page 3 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
  and page 55 to 65 of the Annual Report 2010, available for download at www.ing.com
- 4.3 Independent board members
  
  Please see page 55, 56 and 57 of the Annual Report 2010, available for download at www.ing.com
- 4.4 Mechanisms for shareholders and employees to provide recommendations
  
  See page 25, 60 and 167 of the Annual Report 2010, available for download at www.ing.com
- 4.5 Linkage between compensation for members of the highest governance body, senior managers, and executives
  
  • At ING, corporate responsibility and sustainable business practices are part of our core business. • Therefore we are integrating sustainability into the personal accountability and performance objectives of our senior management. Their performance objectives will increasingly be linked to non-financial drivers. • For 2010, at least 40% of total variable compensation for Executive Board members will be based on pre-defined non-financial performance indicators. • The non-financial performance objectives contribute to enhanced business sustainability. Examples include: diversity of the workforce, employee engagement, development of sustainable products and community investment. • Setting these objectives is in line with our long term aspiration to belong to the sector leaders in the Dow Jones Sustainability Index. See the Annual report 2009 (we did not report this in the Annual report 2010, only in 2009)
- 4.6 Conflict of interest
  
  See page 66 and 67 of the Annual Report 2010, available for download at www.ing.com
- 4.7 Process for determining the qualifications and expertise of the members of the highest governance body
  
  • At ING, corporate responsibility and sustainable business practices are part of our core business. • Therefore we are integrating sustainability into the personal accountability and performance objectives of our senior management. Their performance objectives will increasingly be linked to non-financial drivers. • For 2010, at least 40% of total variable compensation for Executive Board members will be based on pre-defined non-financial performance indicators. • The non-financial performance objectives contribute to enhanced business sustainability. Examples include: diversity of the workforce, employee engagement, development of sustainable products and community investment. • Setting these objectives is in line with our long term aspiration to belong to the sector leaders in the Dow Jones Sustainability Index. See the Annual report 2009 (we did not report this in the Annual report 2010, only in 2009)
- 4.8 Code of conduct
  
  Please see page 4, 5, 6 and 7 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- 4.9 Management of sustainability performance
  
  Please see page 38 and 83 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
  and page 56 to 58 of the Annual Report 2010, available for download at www.ing.com
  
  We do not report on the frequency of which the highest governance body assesses sustainability performance. The frequency depends on the specific area of sustainability. Social, environmental and economic performance is measured within different departments.
- 4.10 Evaluation of performance of highest governance body
  
  Please see page 59 and 83 of the Annual Report 2010, available for download at www.ing.com
Commitment to external initiatives
- 4.11 Precautionary approach
  
  Please see page 37 until 42 of the CR Report 2010 (and related webpages), available for download at www.ingforsomethingbetter.com/report
- 4.12 Externally developed charters
  
  Please see page 17 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- 4.13 Memberships
  
  Please see page 17 of our Corporate Responsibility report 2010 www.ing.com/cr
Stakeholder engagement
- 4.14 Stakeholder groups
  
  Please see page 17 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and www.ingforsomethingbetter.com/stakeholders
- 4.15 Identification of stakeholders groups
  
  Please see page 16 and 17 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and www.ingforsomethingbetter.com/stakeholders . See for the selection our strategy (p.12) and please see page 14, 15, 16 and 17 of our Corporate Responsibility report 2010. See also page 6 of the Annual report 2010. After the crisis in 2008 we again identified our key stakeholders due to changed circumstances (such as the Dutch Governement loan). We started an intensified stakeholder engagement programme to involve our stakeholders in our business decisions.
- 4.16 Approach to stakeholder engagement
  
  Please see page 17 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and www.ingforsomethingbetter.com/stakeholders
- 4.17 Key topics and concern
  
  Please see page 16 and 17 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and www.ingforsomethingbetter.com/stakeholders . We have invested in a broad range of media to engage our stakeholders. These include offline and online platforms, a well as large scale quantitative opinion surveys. Specifically for our customers, we held more than 80 ‘financial information evenings’ at our local bank branches in the Netherlands. We also organised some 40 debates in the Netherlands on issues such as ING’s role in society, customer centricity and sustainable entrepreneurship. A cross-section of our stakeholders, including customers, investors, employees and social partners, attended. Engaging with sustainable entrepreneurs In 2010 we organised a series of dialogue sessions with entrepreneurs doing business in sustainable services or products. Senior managers at ING exchanged views with them about how ING could help the entrepreneurs to grow and achieve their goals. In line with these meetings, we organised several workshops in the Netherlands in which frontrunners in the field of sustainable entrepreneurship helped small and medium enterprise clients shift to a more sustainable business model. Topics that were discussed: financial crisis, sustainable entrepreneurship (e.g. sustainability in the food branche), financial education, INGs role in society in general and customer centricity.
Economic Performance Indicators

Economic Performance Indicators
- EC1 Direct economic value
  
  Please see page 29, 37, 41, and 53 of our Annual Report 2010, available for download at www.ing.com
- EC2 Financial implications due to climate changes
  
  Please see page 60 to 67 of our CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EC3 Defined benefit plan obligations
  
  Please see page 10 and 97 of our Annual Report 2010 , available for download at www.ing.com
- EC4 Significant financial assistance received from government
  
  Please see page 10 and page 167 of our Annual Report 2010 , available for download at www.ing.com
- EC5 Range of ratios of standard entry level wage compared to local minimum wage at significant locations of operation
  
  Please see our website www.ingforsomethingbetter.com/stakeholders
- EC6 Locally-based suppliers
  
  Please see our website www.ingforsomethingbetter.com/stakeholders
- EC7 Local hiring of senior management
  
  Please see page 90 and 91 of our CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EC8 Services provided for public benefit
  
  We do not have information available at corporate level. However, building local infrastructure can be a part of our community development programme.
Social Performance Indicators

Labour practices and decent work
- LA1 Breakdown of workforce
  
  Please see page 90 and 91 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- LA2 Employee turnover
  
  Please see page 92 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report . We do not have information available at corporate level regarding turnover by age group and gender.
- LA3 Benefits provided to full-time employees that are not provided to temporary or part-time employees, by major operations
  
  See for more details our website, www.ingforsomethingbetter.com/humanrights/
- LA4 Collective Bargaining Agreements
  
  See for more details our website, www.ingforsomethingbetter.com/humanrights
- LA5 Significant operational changes
  
  Please see page 54 to 59 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- LA6 Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational health and safety programs
  
  Please see page 33 - 35 of the Annual Report 2010, available for download at www.ing.com
- LA7 Rates of injury/absenteeism
  
  Please see page 53 of the CR Report 2009, available for download at www.ingforsomethingbetter.com/report
- LA8 Serious diseases
  
  Please see page 92 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- LA9 Health and safety topics covered in formal agreements with trade unions
  
  Please see page 92 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- LA10 Training
  
  Please see page 92 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- LA11 Skills management
  
  See for more details our website, www.ingforsomethingbetter.com/training
- LA12 Percentage of employees receiving regular performance and career development reviews
  
  See for more details our website, www.ingforsomethingbetter.com/training
- LA13 Breakdown by gender
  
  Please see page 90 to 93 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- LA14 Ratio of basic salary of men and women
  
  We do not report on this, as we have not been able to gather the data. It is not possible to give proper insight on ratios of salaries, as the construction of salaries consists of many variables like longitude of employment, age, country and type of job.
Human rights
- HR1 Agreements that have undergone human rights screening
  
  Please see www.ingforsomethingbetter.com/humanrights
- HR2 Human rights and suppliers
  
  Please see www.ingforsomethingbetter.com/humanrights
- HR3 Employee training on human rights
  
  Please see www.ingforsomethingbetter.com/humanrights
- HR4 Total number of incidents of discrimination
  
  Not reported. Our personel policy is based on equal opportunities and a non-discriminatory policy. Our local compliance organisations act when incidents are reported.
- HR5 Freedom of Association
  
  Please see www.ingforsomethingbetter.com/humanrights
- HR6 Child labour
  
  Please see www.ingforsomethingbetter.com/humanrights
- HR7 Forced and compulsory labour
  
  Please see www.ingforsomethingbetter.com/humanrights
- HR8 Percentage of security personnel trained in the organization's policies or procedures concerning aspects of human rights that are relevant to operations
  
  Not reported. We do not register our local compliance organisations act when incidents are reported. We will not be reporting this in the coming years.
- HR9 Total number of incidents of violations involving rights of indigenous people and actions taken
  
  Not reported. Our personel policy is based on equal opportunities and a non-discriminatory policy. Our local compliance organisations act when incidents are reported. We will not be reporting this in the coming years.
Society
- SO1 Community development programmes
  
  Please see page 69, 70, 71, 75, and 77 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- SO2 Risk related to corruption
  
  Please see our website on bribery and corruption www.ingforsomethingbetter.com/bribery and our Annual report 2010 available for download at www.ing.com
- SO3 Employee training on corruption
  
  Please see our website on bribery and corruption www.ingforsomethingbetter.com/bribery and our Annual report 2010 available for download at www.ing.com
- SO4 Incidents of corruption
  
  Please see our website on bribery and corruption www.ingforsomethingbetter.com/bribery and our Annual report 2010 available for download at www.ing.com
- SO5 Public policy positions
  
  Please see our website on bribery and corruption www.ingforsomethingbetter.com/bribery and our Annual report 2010 available for download at www.ing.com
- SO6 Non-compliance
  
  Please see page 96 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- SO8 Non-monetary sanctions for non-compliance with laws and regulations
  
  Please see page 239 and 240 of the Annual Report 2010, available for download at www.ing.com
Product responsibility
- PR1 Health and safety impacts of products and services
  
  We do not report on this issue (no intention of reporting in the future). The disclosure does not relate to our business because our products have minimum impact on health and safety.
- PR2 Product information and labelling
  
  Please see www.ingforsomethingbetter.com/customers
- PR3 Marketing communicationsPR3 Marketing communications
  
  Please see our CR Report page 31, 33 and 35 and see www.ingforsomethingbetter.com/customers
- PR4 Total number of incidents of non-compliance with regulations and voluntary codes concerning product and service information and labeling, by type of outcomes
  
  Not reported. Our personel policy is based on equal opportunities and a non-discriminatory policy. Our local compliance organisations act when incidents are reported. We will not be reporting this in the coming years.
- PR5 Practices related to customer satisfaction, including results of surveys measuring customer satisfaction
  
  Please see our CR Report page 31, 33 and 35 and page 83 and 89. www.ingforsomethingbetter.com/customers
- PR6 Marketing communications, including advertising, promotion and sponsorship
  
  Please see our CR Report page 31, 33, 35. And see www.ingforsomethingbetter.com/customers and page 30 of our Annual Report 2010, available for download on www.ing.com
- PR7 Total number of incidents of non-compliance with regulations and voluntary codes concerning marketing communications, including advertising, promotion, and sponsorship by type of outcomes
  
  See our Annual report 2010 page 203 - 205, available for download at www.ing.com
- PR8 Customer privacy
  
  Please see www.ingforsomethingbetter.com/customers and page 30 of our Annual Report 2010, available for download on www.ing.com
- PR9 Non-compliance
  
  Please see www.ingforsomethingbetter.com/customers and page 30 of our Annual Report 2010, available for download on www.ing.com
Environmental Performance Indicators

Materials
- EN1 Materials used by weight or volume
  
  Paper usage: Please see page 94 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN2 Recycled materials
  
  Paper usage: Please see page 94 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
Energy and water
- EN3 Direct energy consumption
  
  Please see page 94 and 95 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN4 Indirect energy consumption
  
  Please see page 94 and 95 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN5 Energy saved due to conservation and efficiency improvements
  
  Please see page 63 and 64 of the CR Report 2010, www.ingforsomethingbetter.com/report
- EN6 Initiatives to provide energy-efficient or renewable energy based products and services, and reductions in energy requirements as a result of these initiatives
  
  Please see page 63 and 64 of the CR Report 2010, www.ingforsomethingbetter.com/report
- EN7 Initiatives to reduce indirect energy consumption and reductions achieved
  
  We do not provide information about our indirect impact.
- EN8 Total water withdrawal
  
  We do not report on this GRI indicator, since the impact of total water withdrawal is relatively immaterial.
- EN9 Water sources significantly affected by withdrawal of water
  
  We do not report on this GRI Indicator (no intention of reporting in the future).
- EN10 Percentage and total volume of water recycled and reused
  
  We do not report on this GRI Indicator (no intention of reporting in the future).
Biodiversity
- EN11 Land owned in biodiversity-rich habitats
  
  **We do not report on this GRI Indicator (no intention of reporting in the future). Our impact on biodiversity through the land we use for our offices is not material.
- EN12 Impacts on biodiversity
  
  See page 60, 63, 64 and 67 the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN13 Habitats protected or restored
  
  We do not report on this GRI Indicator (no intention of reporting in the future). Our impact on biodiversity through the land we use for our offices is not material.
- EN14 Strategies, current actions, and future plans for managing impacts on biodiversity
  
  See page 22 and 67 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN15 Number of IUCN Red List species and national conservation list species with habitats in areas affected by operations, by level of extinction risk
  
  We do not report on this GRI Indicator (no intention of reporting in the future). Our business does not have an impact on the number of IUCN Red List species and national conserveration list species with habitats in areas affected by operations. We will not be reporting this in the coming years.
Emissions effluents and waste
- EN16 Greenhouse gas emissions
  
  Please see page 94 and 95 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN17 Other relevant greenhouse gas emissions
  
  Please see page 94 and 95 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved
  
  Please see page 94 and 95 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN19 Use and emissions of ozone-depleting substances
  
  Not applicable for financial services provider.
- EN20 Air emissions
  
  Please see page 95 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN21 Significant water discharges
  
  Not applicable for financial services provider.
- EN22 Total amount of waste
  
  We report on our paper usage. Please see page 94 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
- EN23 Significant spills
  
  Not applicable for financial services provider.
- EN24 Weight of transported, imported, exported, or treated waste deemed hazardous under the terms of the Basel Convention Annex I, II, III, and VIII, and percentage of transported waste shipped intern
  
  Not applicable for financial services provider.
- EN25 Identity, size, protected status, and biodiversity value of water bodies and related habitats significantly affected by the reporting organization's discharges of water and runoff
  
  Not applicable for financial services provider.
Products and services
- EN26 Environmental impact of principal products and services
  
  See our CR report 2010 pages 38, 40, 41 and 42. Please visit our website www.ingforsomethingbetter.com/esr
- EN27 Percentage of the weight of products sold that is reclaimable
  
  We do not report on this GRI indicator (no intention of reporting in the future), since the impact of products that are reclaimable is immaterial.
Compliance
- EN28 Incidents of non-compliance
  
  Please see our Annual Report 2010 page 237, available for download at www.ing.com
Transport
- EN29 Significant environmental impacts of transporting products and other goods and materials used for the organization's operations, and transporting members of the workforce
  
  We do not report on this GRI indicator (no intention of reporting in the future), since the impact of products that are reclaimable is immaterial.
Overall
- EN30 Total environmental protection expenditures and investments by type
  
  See our CR report 2010 pages 38, 40, 41, 42 and 87. Please visit our website www.ingforsomethingbetter.com/esr
Financial services sector supplement

CSR management
- FS 1 Environmental and social policies
  
  Please see pages 37, 38, 39, 40 and 41 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/esr
- FS 2 Environmental and social risk procedures
  
  Please see pages 37, 38, 39, 40 and 41 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/esr
- FS 3 Processes for monitoring clients’ implementation of and compliance with environmental and social requirements
  
  Please see pages 37, 38, 39, 40 and 41 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/esr
- FS 4 Processes for improving staff competency to implement the environmental and social policies and procedures
  
  Please see pages 37, 38, 39, 40 and 41 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/esr
- FS 5 Interactions with clients/ investees/business partners regarding environmental and social risks and opportunities
  
  Please see pages 37, 38, 39, 40 and 41 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/esr
- FS 6 Percentage of the portfolio for Business Lines by specific region, size and by sector
  
  Please go to our website www.ingforsomethingbetter.com/equatorprinciples
- FS 7 Monetary value of products and services designed to deliver a specific social benefit
  
  Please see pages 46, 47, 48, 49, 50, 51, 52, 53 and 86 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/greenproducts
- FS 8 Monetary value of products and services designed to deliver a specific environmental benefit
  
  Please see pages 46, 47, 48, 49, 50, 51, 52, 53 and 86 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/greenproducts
- FS 9 Coverage and frequency of audits to assess implementation of environmental and social policies and risk assessment procedures
  
  Please see pages 37, 38, 39, 40 and 41 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/equatorprinciples
- FS 10 Companies held in the institution’s portfolio with which the reporting organisation has interacted on environmental or social issues
  
  Please see pages 37, 38, 39, 40 and 41 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/equatorprinciples
- FS 11 Percentage of assets subject to positive and negative environmental or social screening
  
  Please see pages 37, 38, 39, 40 and 41 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report and our website www.ingforsomethingbetter.com/esr
- FS 12 Voting policy(ies) applied to environmental or social issues for shares over which the reporting organisation holds the right to vote shares or advises on voting
  
  Please see our website www.ingforsomethingbetter.com/voting policy
- FS 13 Access points in low-populated or economically disadvantaged areas by type
  
  ING does not have access points in low populated areas.
- FS 14 Initiatives to improve access to financial services for disadvantaged people
  
  Please see page 31 to 35 of the CR Report 2010, available for download at www.ingforsomethingbetter.com/report
Disclosure on management approach

Disclosure on management approach
- EC
  
  Please see the inside of the front cover in our CR Report 2010, available at www.ingforsomethingbetter.com/report and our Annual Report www.ing.com
- EN
  
  Please see page 80 to 95 of our CR Report 2010, available at www.ingforsomethingbetter.com/report
- LA
  
  Please see page 54 to 59 of our CR Report 2010, available at www.ingforsomethingbetter.com/report
- HR
  
  Please see www.ingforsomethingbetter.com/humanrights
- SO
  
  Please see page 68 to 77 of our CR Report 2010, available at www.ingforsomethingbetter.com/report
- PR
  
  Please see page 28 to 53 of our CR Report 2010, available at www.ingforsomethingbetter.com/report

Global Reporting Initiative (GRI) Index

Profile

Strategy and analysis

1.1 Chairman’s statement

1.2 Key impacts, risks and opportunities

Organisational profile

2.1 Name of reporting organisation

2.2 Products, services and brands

2.3 Operational structure

2.4 Location of head office

2.5 Countries of operation

2.6 Nature of ownership and legal form

2.7 Markets served

2.8 Scale of the organisation

2.9 Changes during reporting period

2.10 Awards received

Report parameters

3.1 Reporting period

3.2 Most recent previous report

3.3 Reporting cycle

3.4 Contact point

3.5 Defining the report content

3.6 Boundary of the report

3.7 Specific limitations of the boundary

3.8 Basis for reporting on joint venture

3.9 Data measurement techniques

3.10 Restatements

3.11 Significant changes

3.12 GRI Index

3.13 Assurance

Governance, Commitments and Engagement

Structure and governance

4.1 Governance structure

4.2 Function of CEO

4.3 Independent board members

4.4 Mechanisms for shareholders and employees to provide recommendations

4.5 Linkage between compensation for members of the highest governance body, senior managers, and executives

4.6 Conflict of interest

4.7 Process for determining the qualifications and expertise of the members of the highest governance body

4.8 Code of conduct

4.9 Management of sustainability performance

4.10 Evaluation of performance of highest governance body

Commitment to external initiatives

4.11 Precautionary approach

4.12 Externally developed charters

4.13 Memberships

Stakeholder engagement

4.14 Stakeholder groups

4.15 Identification of stakeholders groups

4.16 Approach to stakeholder engagement

4.17 Key topics and concern

Economic Performance Indicators

Economic Performance Indicators

EC1 Direct economic value

EC2 Financial implications due to climate changes

EC3 Defined benefit plan obligations

EC4 Significant financial assistance received from government

EC5 Range of ratios of standard entry level wage compared to local minimum wage at significant locations of operation

EC6 Locally-based suppliers

EC7 Local hiring of senior management

EC8 Services provided for public benefit

Social Performance Indicators

Labour practices and decent work

LA1 Breakdown of workforce

LA2 Employee turnover

LA3 Benefits provided to full-time employees that are not provided to temporary or part-time employees, by major operations

LA4 Collective Bargaining Agreements

LA5 Significant operational changes

LA6 Percentage of total workforce represented in formal joint management-worker health and safety committees that help monitor and advise on occupational health and safety programs

LA7 Rates of injury/absenteeism

LA8 Serious diseases

LA9 Health and safety topics covered in formal agreements with trade unions

LA10 Training

LA11 Skills management

LA12 Percentage of employees receiving regular performance and career development reviews

LA13 Breakdown by gender

LA14 Ratio of basic salary of men and women

Human rights

HR1 Agreements that have undergone human rights screening

HR2 Human rights and suppliers