ING IM Policies

MiFID - Markets in Financial Instruments Directive

The Markets in Financial Instruments Directive (“MiFID”) became effective on 1 November 2007, and has been adopted into local European legislation. The purpose of MiFID is to harmonise European financial markets and to provide greater levels of transparency through a new regulatory regime for investment services.

ING Investment Management (“ING IM”) conducts business in a fair and professional way, with high fiduciary standards, and therefore supports the goals of MiFID. Though we always have made integrity and transparency the basis of our client relationships, ING IM has implanted MiFID as an extra measure of assurance about our commitment to integrity and transparency.

Execution of orders

ING IM has a duty to take all reasonable steps to ensure that it obtains the best possible results for its clients, when executing transactions directly with other parties (brokers or counterparties) or when placing or transmitting orders with a broker for execution. In order to fulfil this duty, ING Investment Management will consider factors such as price, costs, speed and likelihood of execution and settlement of the trade and the size and nature of the order, when executing these transactions. This process is described in the provided Best Execution Policy.

Conflicts of Interest

Conflicts of interest can exist or arise within investment firms. ING IM is taking all reasonable steps to identify, monitor and manage such conflicts of interest, if any. The ING Investment Management Europe offices have policies in place to address conflicts of interest. The Conflict of Interest Policy provides you with key information about the measures ING IM is taking to safeguard your interests.

ING Investment Management Advisors B.V.

As a SEC registered Investement Advisor, ING Investment Management Advisors B.V. is required to make its Form ADV Part 2a available to its (prospective) clients. Please click here to download Form ADV Part 2a ("the Brochure"). ING Investment Management Advisors B.V.'s Form ADV Part 1 can be downloaded on the SEC's website http://www.adviserinfo.sec.gov

Luxembourg Fund Range

Complaints Handling
Conflicts of Interest