ING takes the view that no professional decision may be influenced by personal interests.
ING must take all reasonable measures to adequately identify, prevent and manage conflicts of interest which might undermine its clients’ interests. The Bank and all its employees must therefore take reasonable measures to avoid, as far as possible, such conflicts of interest or situations liable to generate them.
Examples of conflicts of interest :
- An employee would favour the Bank’s commercial policy by selling a in-house investment product to the detriment of a third-party fund without taking account of the client’s investor profile.
- Acceptance by ING employees of gifts or invitations to events could influence their behaviour by, for example, according preferential treatment to one or more clients.
ING has put in place an organisational structure including rules and responsibilities in the prevention and management of conflicts of interest. The Bank has also established a policy, procedures, mechanisms and processes making it possible to take all necessary and reasonable measures to prevent, identify, manage, report and control conflicts of interest.