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ING Complaint Process for Accounting and Auditing Matters

This ING Complaint Process for Accounting and Auditing Matters (“Complaint Process”) has been approved and adopted by the boards of the U.S. domiciled insurance companies which are members of the ING family of companies (“ING Companies”). The ING Companies have a commitment to engage in and promote honest and ethical conduct and to produce full, fair, complete, accurate, timely and understandable financial disclosure. As a demonstration of this commitment, the ING Companies have adopted this Complaint Process.

External parties who have complaints about accounting or auditing matters should call the ING Fraud Hotline at 1.877.ING.TIPS; the fraud hotline is maintained by ING Special Investigations Unit; detailed instructions for how to access the fraud hotline are provided in the ING Agent’s Code of Conduct and on claims forms in communications to state anti-fraud agencies.

Special Investigations will investigate each complaint about an accounting or auditing matter and report to the HC Americas whether the complaint was unfounded or supported by fact, a minor or major complaint, and whether the complained of problem has been corrected or needs further remediation.

The HC Americas will keep a log of external complaints about accounting and auditing matters and investigative findings and will prepare a Quarterly Accounting and Auditing Complaint Report for the boards of the ING Companies which states (i) the total number of external complaints received in the prior quarter and (ii) the facts of any substantiated complaint and the nature of the remedial action proposed or taken.

Any major external complaint about an accounting or auditing matter (one which poses a risk of significant reputational or economic loss to ING, its shareholders or customers, or a material violation of the securities laws) will be reported by the HC Americas promptly to the boards of directors.

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