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Whistleblower Law
Who can report a concern?
ING’s Whistleblower policy allows:
- employees (including trainees and volunteers)
- former employees (you learned about breaches during a work-based relationship with ING)
- candidates (where information on breaches has been acquired during the recruitment process or other pre-contractual negotiations)
- (persons working under the supervision and direction of) contractors, subcontractors, suppliers
- shareholders and persons belonging to the administrative, management or supervisory body
of ING Luxembourg and its subsidiaries (hereinafter “we” or “ING”) to report, in good faith, information or reasonable suspicions about actual or potential breaches of Luxembourg laws and/or EU regulations, which occurred or are very likely to occur within the ING and the attempts to conceal such breaches (hereinafter the “concern(s)” or “breach(es)”).
Which concerns can be reported?
The Whistleblower Policy applies to suspected or actual breaches, including but not limited to:
- Accounting, internal accounting controls or auditing matters
- Money laundering or terrorist financing
- Financing clients who violate Human Rights or commit environmental crimes
- Market manipulation
- Insider trading
- Confidentiality or privacy breaches
- Theft
- Fraud
- Bribery or corruption
- Violations of any other laws, regulations.
How to report a concern?
Please fill in the Whistleblowing Reporting Form and send it:
- via email to the address indicated on the form, or
- via post to ING Luxembourg SA, Attn.: Chief Compliance Officer - 26, Place de la Gare, L-2965 Luxembourg.
We recommend to use our internal channels before using external channels set-up by public authorities. Nevertheless, you will not lose protection if you decide to use external channels first.
How does the ING Whistleblowing channel work?
Follow-up and investigation
After a concern has been received by ING an acknowledgement of receipt will be sent within 7 days. Based on the provided information the concern will be investigated. Often, follow-up contact is needed for further clarification, contact will be sought via the available communication channels. An update on the follow-up of the concern will be shared within 3 months after ING’s acknowledgement of receipt.
Anonymity
You can report a concern anonymously. However, we encourage you to leave us your contact details to help us complete our investigation and to keep you informed of its status and outcome.
Confidentiality
All reports are confidential. The people processing and investigating your concern are the only ones who will know your identity. If, in order to conduct our investigation, we will need to reveal your identity, we will discuss it with you and make sure you agree before proceeding: information that could identify you will only be disclosed with your permission, unless ING will be legally required to share such information with public authorities.
Protection against retaliation
You can report, in good faith, a concern without fear of retaliation. This protection also applies to facilitators, third parties and legal entities you're associated with, own or work for.
Data protection
The ING’s internal whistleblowing channel comply with the provisions of the General Data Protection Regulations (GDPR). For further information about our undertakings relating to data privacy, please refer to our “Privacy Statement”.