SFDR

At ING Luxembourg level, acting as financial market participant and as financial adviser, multiple disclosures are required in relation to the decision making process and when providing investment advice:

1. The disclosure is required on whether sustainability risks are included:

2. The disclosure on whether or not any negative sustainability effects are taken into consideration (Principle Adverse Impact - PAI):

3. Disclosure regarding the organization’s remuneration policy, that must include how the policy is consistent with the integration of sustainability risks:

"Sustainability is a key component of ING Group’s strategy. As a financial institution, ING Luxembourg as part of the ING Group plays a role by financing change, sharing knowledge and using its influence. ING Luxembourg not only manages its own direct and indirect impact, ING Luxembourg also helps its clients address the risks and opportunities that sustainability challenges create. The remuneration policy of ING Luxembourg adheres to these principles and does not encourage excessive risk taking with respect to sustainability risks and is linked to risk‐adjusted performance. In addition to the general principles set out in the Remuneration Regulations Framework, specific requirements apply to the Remuneration of SFDR Staff*. These requirements are based on the SFDR. The Remuneration of SFDR Staff should be consistent with the integration of sustainability risks. In this respect sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment."

*employees involved in the provision of investment and insurance advice or portfolio management

Transparency requirements with regards to sustainability also apply at a product level. The pre-contractual information must indicate how sustainability risks are taken into account in investment decisions and within advice, how this affects the expected return or why they are not relevant.

If a sustainable product is offered, additional information requirements apply. Additional information about the sustainability of the i product must then be provided to prevent all kinds of investments from being incorrectly advertised as "green" or "sustainable" ("greenwashing").

Under the SFDR regulation there are different product categories:

• Financial products having sustainable objectives (article 9)
• Financial products promoting environmental or social characteristics as part of the broad investment strategy (article 8)
• Financial products that either consider ESG risks as part of the investment process or are explicitly declared as non-sustainable (article 6). There is a difference between products taken sustainability risk into account and those who do not.

For each product, the following information will be disclosed:

• a description of the environmental or social characteristics or the sustainable investment objective;
• the information on the methodologies used to assess, measure and monitor the environmental or social characteristics and the relevant sustainability indicators used to measure the environmental or social characteristics or the overall sustainable impact of the financial product.

The information regarding how sustainability risks are taken into account for each product that falls under the SFDR regulation, can be found in the ING Sustainability Risks Policy.