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ING Groep NV – ‘20-F’ for 12/31/23 – ‘EX-97’

On:  Friday, 3/8/24, at 6:47am ET   ·   For:  12/31/23   ·   Accession #:  1628280-24-9782   ·   File #:  1-14642

Previous ‘20-F’:  ‘20-F’ on 3/10/23 for 12/31/22   ·   Latest ‘20-F’:  This Filing   ·   16 References:   

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  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 3/08/24  ING Groep NV                      20-F       12/31/23  308:148M                                   Workiva Inc Wde… FA01/FA

Annual or Annual-Transition Report by a Foreign Non-Canadian Issuer   —   Form 20-F   —   SEA’34

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 20-F        Annual or Annual-Transition Report by a Foreign     HTML  30.40M 
                Non-Canadian Issuer                                              
 2: EX-2.1      Plan of Acquisition, Reorganization, Arrangement,   HTML    312K 
                Liquidation or Succession                                        
 3: EX-8        Opinion of Counsel re: Tax Matters                  HTML     94K 
 6: EX-13.1     Annual or Quarterly Report to Security Holders      HTML     88K 
 7: EX-13.2     Annual or Quarterly Report to Security Holders      HTML     88K 
10: EX-97       Clawback Policy re: Recovery of Erroneously         HTML     96K 
                Awarded Compensation                                             
 4: EX-12.1     Statement re: the Computation of Ratios             HTML     91K 
 5: EX-12.2     Statement re: the Computation of Ratios             HTML     91K 
 8: EX-15.1     Letter re: Unaudited Interim Financial Info         HTML     87K 
 9: EX-15.2     Letter re: Unaudited Interim Financial Info         HTML     86K 
16: R1          Cover                                               HTML    200K 
17: R2          Audit Information                                   HTML     90K 
18: R3          Consolidated statement of financial position        HTML    173K 
19: R4          Consolidated statement of profit or loss            HTML    159K 
20: R5          Consolidated statement of comprehensive income      HTML    129K 
21: R6          Consolidated statement of changes in equity         HTML    187K 
22: R7          Consolidated statement of cash flows                HTML    196K 
23: R8          Consolidated statement of cash flows                HTML    108K 
                (Parenthetical)                                                  
24: R9          Risk management                                     HTML   4.23M 
25: R10         Basis of preparation and significant accounting     HTML    653K 
                policies                                                         
26: R11         Cash and balances with central bank                 HTML    101K 
27: R12         Loans and advances to banks                         HTML    114K 
28: R13         Financial assets at fair value through profit or    HTML    212K 
                loss                                                             
29: R14         Financial assets at fair value through other        HTML    210K 
                comprehensive income                                             
30: R15         Debt securities                                     HTML    188K 
31: R16         Loans and advances to customers                     HTML    178K 
32: R17         Investment in associates and joint ventures         HTML    168K 
33: R18         Property and equipment                              HTML    234K 
34: R19         Intangible assets                                   HTML    248K 
35: R20         Other assets                                        HTML    109K 
36: R21         Deposits from banks                                 HTML    115K 
37: R22         Customer deposits                                   HTML    128K 
38: R23         Financial liabilities at fair value through profit  HTML    148K 
                or loss                                                          
39: R24         Provisions                                          HTML    188K 
40: R25         Other liabilities                                   HTML    123K 
41: R26         Debt securities in issue                            HTML    129K 
42: R27         Subordinated loans                                  HTML    109K 
43: R28         Equity                                              HTML    516K 
44: R29         Net interest income                                 HTML    192K 
45: R30         Net fee and commission income                       HTML    141K 
46: R31         Valuation results and net trading income            HTML    153K 
47: R32         Investment income                                   HTML    103K 
48: R33         Other net income                                    HTML     99K 
49: R34         Staff expenses                                      HTML    193K 
50: R35         Other operating expenses                            HTML    159K 
51: R36         Audit fees                                          HTML    100K 
52: R37         Earnings per ordinary share                         HTML    138K 
53: R38         Dividend per ordinary share                         HTML    122K 
54: R39         Segments                                            HTML   1.00M 
55: R40         Information on geographical areas                   HTML    808K 
56: R41         Changes in liabilities arising from financing       HTML    156K 
                activities                                                       
57: R42         Pensions and other post-employment benefits         HTML    339K 
58: R43         Taxation                                            HTML    448K 
59: R44         Fair value of assets and liabilities                HTML   1.00M 
60: R45         Derivatives and hedge accounting                    HTML    649K 
61: R46         Assets by contractual maturity                      HTML    267K 
62: R47         Liabilities and off-balance sheet commitments by    HTML    401K 
                maturity                                                         
63: R48         Transfer of financial assets, assets pledged and    HTML    175K 
                received as collateral                                           
64: R49         Offsetting financial assets and liabilities         HTML    537K 
65: R50         Contingent liabilities and commitments              HTML    131K 
66: R51         Legal proceedings                                   HTML    176K 
67: R52         Consolidated companies and business acquired and    HTML    109K 
                divested                                                         
68: R53         Principal subsidiaries, investments in associates   HTML    146K 
                and joint ventures                                               
69: R54         Structured entities                                 HTML    152K 
70: R55         Related parties                                     HTML    236K 
71: R56         Capital management                                  HTML    207K 
72: R57         Condensed financial information of the parent       HTML    539K 
                company                                                          
73: R58         Subsequent events                                   HTML     89K 
74: R59         Basis of preparation and significant accounting     HTML    704K 
                policies (Policies)                                              
75: R60         Risk management (Tables)                            HTML   3.48M 
76: R61         Basis of preparation and significant accounting     HTML    125K 
                policies (Tables)                                                
77: R62         Cash and balances with central bank (Tables)        HTML     98K 
78: R63         Loans and advances to banks (Tables)                HTML    109K 
79: R64         Financial assets at fair value through profit or    HTML    185K 
                loss (Tables)                                                    
80: R65         Financial assets at fair value through other        HTML    195K 
                comprehensive income (Tables)                                    
81: R66         Debt securities (Tables)                            HTML    189K 
82: R67         Loans and advances to customers (Tables)            HTML    172K 
83: R68         Investment in associates and joint ventures         HTML    152K 
                (Tables)                                                         
84: R69         Property and equipment (Tables)                     HTML    228K 
85: R70         Intangible assets (Tables)                          HTML    230K 
86: R71         Other assets (Tables)                               HTML    106K 
87: R72         Deposits from banks (Tables)                        HTML    109K 
88: R73         Customer deposits (Tables)                          HTML    125K 
89: R74         Financial liabilities at fair value through profit  HTML    142K 
                or loss (Tables)                                                 
90: R75         Provisions (Tables)                                 HTML    173K 
91: R76         Other liabilities (Tables)                          HTML    113K 
92: R77         Debt securities in issue (Tables)                   HTML    125K 
93: R78         Subordinated loans (Tables)                         HTML     91K 
94: R79         Equity (Tables)                                     HTML    416K 
95: R80         Net interest income (Tables)                        HTML    172K 
96: R81         Net fee and commission income (Tables)              HTML    134K 
97: R82         Valuation results and net trading income (Tables)   HTML    120K 
98: R83         Investment income (Tables)                          HTML    101K 
99: R84         Staff expenses (Tables)                             HTML    160K 
100: R85         Other operating expenses (Tables)                   HTML    140K  
101: R86         Audit fees (Tables)                                 HTML     99K  
102: R87         Earnings per ordinary share (Tables)                HTML    133K  
103: R88         Dividend per ordinary share (Tables)                HTML    112K  
104: R89         Segments (Tables)                                   HTML    971K  
105: R90         Information on geographical areas (Tables)          HTML    766K  
106: R91         Changes in liabilities arising from financing       HTML    154K  
                activities (Tables)                                              
107: R92         Pensions and other post-employment benefits         HTML    301K  
                (Tables)                                                         
108: R93         Taxation (Tables)                                   HTML    414K  
109: R94         Fair value of assets and liabilities (Tables)       HTML    801K  
110: R95         Derivatives and hedge accounting (Tables)           HTML    822K  
111: R96         Assets by contractual maturity (Tables)             HTML    266K  
112: R97         Liabilities and off-balance sheet commitments by    HTML    393K  
                maturity (Tables)                                                
113: R98         Transfer of financial assets, assets pledged and    HTML    166K  
                received as collateral (Tables)                                  
114: R99         Offsetting financial assets and liabilities         HTML    531K  
                (Tables)                                                         
115: R100        Contingent liabilities and commitments (Tables)     HTML    106K  
116: R101        Principal subsidiaries, investments in associates   HTML    138K  
                and joint ventures (Tables)                                      
117: R102        Structured entities (Tables)                        HTML     94K  
118: R103        Related parties (Tables)                            HTML    212K  
119: R104        Capital management (Tables)                         HTML    136K  
120: R105        Condensed financial information of the parent       HTML    538K  
                company (Tables)                                                 
121: R106        Risk management - Outstandings per line of          HTML    619K  
                business (Details)                                               
122: R107        Risk management - Outstandings by economic sectors  HTML    460K  
                and geographical area (Details)                                  
123: R108        Risk management - Credit risk mitigation and        HTML    228K  
                credit quality - Additional information (Details)                
124: R109        Risk management - Cover values including            HTML    165K  
                guarantees received - Total ING Bank (Details)                   
125: R110        Risk management - Credit quality outstandings       HTML    105K  
                (Details)                                                        
126: R111        Risk management - Aging analysis (past due but      HTML    154K  
                performing): Consumer lending portfolio by                       
                geographic area, outstandings (Details)                          
127: R112        Risk management - Aging analysis (past due but      HTML    171K  
                performing): Business lending portfolio by                       
                geographic area, outstandings (Details)                          
128: R113        Risk management - Summary forborne portfolio        HTML    102K  
                (Details)                                                        
129: R114        Risk management - Summary forborne portfolio by     HTML    119K  
                forberance type (Details)                                        
130: R115        Risk management - Wholesale Banking: Forborne       HTML    149K  
                portfolio by geographical area (Details)                         
131: R116        Risk management - Wholesale Banking: Forborne       HTML    166K  
                portfolio by economic sector (Details)                           
132: R117        Risk management - Retail Banking: Forborne          HTML    156K  
                portfolio by geographical area (Details)                         
133: R118        Risk management - Non-performing Loans:             HTML    173K  
                outstandings by economic sector and business lines               
                (Details)                                                        
134: R119        Risk management - Non-performing Loans:             HTML    382K  
                outstandings by economic sectors and geographical                
                area (Details)                                                   
135: R120        Risk management - Gross carrying amount per IFRS 9  HTML    214K  
                stage and rating class (Details)                                 
136: R121        Risk management - Changes in gross carrying         HTML    250K  
                amounts and loan loss provisions (Details)                       
137: R122        Risk management - Financial assets modified         HTML     93K  
                (Details)                                                        
138: R123        Risk management - Macroeconomic scenarios applied   HTML    126K  
                - Additional Information (Details)                               
139: R124        Risk management - Management adjustments (Details)  HTML    104K  
140: R125        Risk management - Sensitivity analysis (Details)    HTML    188K  
141: R126        Risk management - Reconciliation of model           HTML    104K  
                (reportable) ECL to total ECL (Details)                          
142: R127        Risk management - Quantitative SICR thresholds      HTML    114K  
                (Details)                                                        
143: R128        Risk management - NII/NPV-at-Risk banking book per  HTML    104K  
                currency - year one (Details)                                    
144: R129        Risk management - Non-derivative financial          HTML    102K  
                instruments to transition to alternative                         
                benchmarks (Details)                                             
145: R130        Risk management - Derivative financial instruments  HTML     98K  
                to transition to alternative benchmarks (Details)                
146: R131        Risk management - Notional amounts of hedging       HTML    103K  
                instruments (Details)                                            
147: R132        Risk management - Foreign currency exposures        HTML    132K  
                banking books (Details)                                          
148: R133        Risk management - Revaluation reserve equity        HTML    108K  
                securities at fair value through other                           
                comprehensive income (Details)                                   
149: R134        Risk management - Most important foreign exchange   HTML    102K  
                year-end trading positions (Details)                             
150: R135        Risk management - Most important interest rate and  HTML    152K  
                credit spread sensitivities at year-end (Detail)                 
151: R136        Basis of preparation and significant accounting     HTML    136K  
                policies - Additional information (Details)                      
152: R137        Basis of preparation and significant accounting     HTML     95K  
                policies - Reconciliation net result under IFRS-EU               
                and IFRS-IASB (Details)                                          
153: R138        Basis of preparation and significant accounting     HTML     95K  
                policies - Reconciliation shareholders' equity                   
                under IFRS-EU and IFRS-IASB (Details)                            
154: R139        Cash and balances with central bank - Summary of    HTML     93K  
                cash and balances with central bank (Details)                    
155: R140        Loans and advances to banks - Schedule of loans     HTML     96K  
                and advances to banks (Details)                                  
156: R141        Financial assets at fair value through profit or    HTML     97K  
                loss - Summary of financial assets at fair value                 
                through profit or loss (Details)                                 
157: R142        Financial assets at fair value through profit or    HTML    114K  
                loss - Summary of exposure to (Reverse) Repurchase               
                Agreements (Details)                                             
158: R143        Financial assets at fair value through profit or    HTML     97K  
                loss - Summary of trading assets (Details)                       
159: R144        Financial assets at fair value through profit or    HTML     97K  
                loss - Summary of non-trading derivatives                        
                (Details)                                                        
160: R145        Financial assets at fair value through profit or    HTML     92K  
                loss - Designated as at fair value through profit                
                or loss (Details)                                                
161: R146        Financial assets at fair value through profit or    HTML    112K  
                loss - Additional information (Details)                          
162: R147        Financial assets at fair value through profit or    HTML     94K  
                loss - Mandatorily at fair value through profit or               
                loss (Details)                                                   
163: R148        Financial assets at fair value through other        HTML     99K  
                comprehensive income - Summary of financial assets               
                at fair value through other comprehensive income                 
                (Details)                                                        
164: R149        Financial assets at fair value through other        HTML     97K  
                comprehensive income- Summary of equity securities               
                designated as at fair value through other                        
                comprehensive income (Details)                                   
165: R150        Financial assets at fair value through other        HTML    124K  
                comprehensive income - Summary of changes in fair                
                value through other comprehensive income financial               
                assets (Details)                                                 
166: R151        Financial assets at fair value through other        HTML    117K  
                comprehensive income - Additional information                    
                (Details)                                                        
167: R152        Debt securities - Summary of securities at          HTML    107K  
                amortised costs (Details)                                        
168: R153        Debt securities - Additional information (Details)  HTML     93K  
169: R154        Debt securities - Debt securities by type and       HTML    161K  
                balance sheet lines (Details)                                    
170: R155        Loans and advances to customers - Summary of loans  HTML    120K  
                and advances to customers (Details)                              
171: R156        Loans and advances to customers - Additional        HTML    102K  
                information (Details)                                            
172: R157        Loans and advances to customers - Finance lease     HTML    110K  
                receivables (Details)                                            
173: R158        Investment in associates and joint ventures -       HTML    115K  
                Summary of investments in associates and joint                   
                ventures (Details)                                               
174: R159        Investment in associates and joint ventures -       HTML    104K  
                Additional information (Details)                                 
175: R160        Investment in associates and joint ventures -       HTML    107K  
                Summary of changes in investments in associates                  
                and joint ventures (Details)                                     
176: R161        Property and equipment - Schedule of property and   HTML    107K  
                equipment (Details)                                              
177: R162        Property and equipment - Schedule of changes in     HTML    158K  
                property in own use (Details)                                    
178: R163        Property and equipment - Additional information     HTML     90K  
                (Details)                                                        
179: R164        Intangible assets - Schedule of changes in          HTML    159K  
                intangible assets (Details)                                      
180: R165        Intangible assets - Schedule off goodwill           HTML    105K  
                allocation to group of CGUs (Details)                            
181: R166        Intangible assets - Additional information          HTML    104K  
                (Details)                                                        
182: R167        Other assets - Schedule of other assets (Details)   HTML    101K  
183: R168        Deposits from banks - Schedule of deposits from     HTML     96K  
                banks by type (Details)                                          
184: R169        Deposits from banks - Additional information        HTML     91K  
                (Details)                                                        
185: R170        Customer deposits - Schedule of customer deposits   HTML     94K  
                (Details)                                                        
186: R171        Customer deposits - Additional Information          HTML     92K  
                (Details)                                                        
187: R172        Customer deposits - Schedule of customer deposits   HTML     96K  
                by type (Details)                                                
188: R173        Financial liabilities at fair value through profit  HTML     95K  
                or loss - financial liabilities at fair value                    
                through profit or loss (Details)                                 
189: R174        Financial liabilities at fair value through profit  HTML     97K  
                or loss - Trading liabilities by type (Details)                  
190: R175        Financial liabilities at fair value through profit  HTML     96K  
                or loss - Non-trading rerivatives by type (Detail)               
191: R176        Financial liabilities at fair value through profit  HTML     94K  
                or loss - Summary of designated as at fair value                 
                through profit or loss by type (Details)                         
192: R177        Financial liabilities at fair value through profit  HTML     93K  
                or loss - Additional information (Details)                       
193: R178        Provisions - Summary of provisions by type          HTML     99K  
                (Details)                                                        
194: R179        Provisions - Summary of changes in provisions       HTML    113K  
                (Details)                                                        
195: R180        Provisions - Additional information (Details)       HTML    125K  
196: R181        Other liabilities - Summary of other liabilities    HTML    107K  
                (Details)                                                        
197: R182        Other liabilities - Additional information          HTML     89K  
                (Details)                                                        
198: R183        Debt securities in issue - Summary of maturities    HTML    112K  
                of debt securities in issue (Details)                            
199: R184        Subordinated loans - Schedule of subordinated       HTML     87K  
                loans by group companies (Details)                               
200: R185        Subordinated loans - Additional information         HTML    114K  
                (Details)                                                        
201: R186        Equity - Summary of equity (Details)                HTML    126K  
202: R187        Equity - Hyperinflation additional information      HTML    106K  
                (Details)                                                        
203: R188        Equity - Schedule of share capital (Details)        HTML    101K  
204: R189        Equity - Summary of changes in issued share         HTML    104K  
                capital (Details)                                                
205: R190        Equity - Schedule of share premium (Details)        HTML     89K  
206: R191        Equity - Share capital and premium additional       HTML    106K  
                information (Details)                                            
207: R192        Equity - Schedule of changes in revaluation, cash   HTML    115K  
                flow, and property reserve (Details)                             
208: R193        Equity - Other reserves additional information      HTML    120K  
                (Details)                                                        
209: R194        Equity - Schedule of changes in currency            HTML     99K  
                translation reserve (Details)                                    
210: R195        Equity - Schedule of changes in share of            HTML     94K  
                associates, joint ventures and other reserves                    
                (Details)                                                        
211: R196        Equity - Share of equity method investments         HTML    103K  
                additional information (Details)                                 
212: R197        Equity - Schedule of changes in treasury shares     HTML    114K  
                (Details)                                                        
213: R198        Equity - Treasury shares additional information     HTML    121K  
                (Details)                                                        
214: R199        Equity - Schedule of changes in retained earnings   HTML    104K  
                (Details)                                                        
215: R200        Equity - Retained earnings additional information   HTML    101K  
                (Details)                                                        
216: R201        Equity - Schedule of non-distributable reserves     HTML     91K  
                (Details)                                                        
217: R202        Net interest income - Summary of net interest       HTML    139K  
                income (Details)                                                 
218: R203        Net interest income - Additional information        HTML    110K  
                (Details)                                                        
219: R204        Net fee and commission income - Schedule of net     HTML    112K  
                fee and commission income (Details)                              
220: R205        Valuation results and net trading income - Summary  HTML    108K  
                of valuation results and net trading income                      
                (Details)                                                        
221: R206        Valuation results and net trading income -          HTML     95K  
                Additional information (Details)                                 
222: R207        Investment income - Summary of investment income    HTML     93K  
                (Details)                                                        
223: R208        Other net income (Details)                          HTML     98K  
224: R209        Staff expenses - Summary of staff expenses          HTML    101K  
                (Details)                                                        
225: R210        Staff expenses - Summary of number of employees     HTML     92K  
                (Details)                                                        
226: R211        Staff expenses - Additional Information (Details)   HTML    106K  
227: R212        Staff expenses - Summary of changes in share        HTML    107K  
                awards (Details)                                                 
228: R213        Other operating expenses - Summary of other         HTML    119K  
                operating expenses (Details)                                     
229: R214        Other operating expenses - Additional information   HTML     98K  
                (Details)                                                        
230: R215        Audit fees - Summary of audit and non-audit         HTML     91K  
                services (Details)                                               
231: R216        Earnings per ordinary share - Summary of earnings   HTML    116K  
                per ordinary share (Details)                                     
232: R217        Dividend per ordinary share - Schedule of           HTML    101K  
                dividends to shareholders of the parent (Details)                
233: R218        Dividend per ordinary share - Additional            HTML     98K  
                information (Details)                                            
234: R219        Segments - Additional information (Details)         HTML    119K  
235: R220        Segments - Summary of reconciliation between IFRS   HTML    105K  
                and underlying income, expenses and net result                   
                (Details)                                                        
236: R221        Segments - Schedule of ING Group total (Details)    HTML    143K  
237: R222        Segments - Summary of segments banking by line of   HTML    175K  
                business (Details)                                               
238: R223        Segments - Summary of geographical segments         HTML    222K  
                banking (Details)                                                
239: R224        Information on geographical areas - Additional      HTML    146K  
                information (Details)                                            
240: R225        Information on geographical areas - Summary of      HTML    264K  
                additional information by country (Details)                      
241: R226        Changes in liabilities arising from financing       HTML    120K  
                activities - Summary of changes in liabilties                    
                arising from financing activities (Details)                      
242: R227        Pension and other post-employment benefits -        HTML    109K  
                Summary of information on plan assets and defined                
                benefit obligation per country (Detail)                          
243: R228        Pension and other post-employment benefits -        HTML    107K  
                Schedule of changes in fair value of plan assets                 
                (Details)                                                        
244: R229        Pension and other post-employment benefits -        HTML    120K  
                Schedule of changes in present value of defined                  
                benefit obligation and other post-employment                     
                benefits (Details)                                               
245: R230        Pension and other post-employment benefits -        HTML    101K  
                Summary of changes in the net defined benefit                    
                assets/liability remeasurement reserve (Details)                 
246: R231        Pension and other post-employment benefits -        HTML    115K  
                Summary of pension and other staff-related benefit               
                costs (Details)                                                  
247: R232        Pension and other post employment benefits -        HTML    123K  
                Additional information (Details)                                 
248: R233        Taxation - Summary of changes in deferred tax       HTML    145K  
                (Details)                                                        
249: R234        Taxation - Summary of deferred tax in connection    HTML     94K  
                with unused tax losses carried forward (Details)                 
250: R235        Taxation - Summary of total unused tax losses       HTML    102K  
                carried forward analysed by expiry terms (Details)               
251: R236        Taxation - Breakdown of certain net deferred tax    HTML    108K  
                asset positions by jurisdiction (Details)                        
252: R237        Taxation - Summary of taxation by type (Details)    HTML    104K  
253: R238        Taxation - Reconciliation of weighted average       HTML    118K  
                statutory income tax rate to effective income tax                
                rate (Details)                                                   
254: R239        Taxation - Summary of income tax related to other   HTML    104K  
                comprehensive income (Details)                                   
255: R240        Taxation - Additional information (Details)         HTML    120K  
256: R241        Fair value of assets and liabilities - Deferred     HTML     96K  
                day one profit or loss reserve (Details)                         
257: R242        Fair value of assets and liabilities - Summary of   HTML    109K  
                valuation adjustment (Details)                                   
258: R243        Fair value of assets and liabilities - Methods      HTML    158K  
                applied in determining fair values of financial                  
                assets and liabilities (Carried at Fair Value)                   
                (Detail)                                                         
259: R244        Fair value of assets and liabilities - Additional   HTML    113K  
                information (Details)                                            
260: R245        Fair value of assets and liabilities - Valuation    HTML    255K  
                techniques and range of unobservable inputs                      
                (Details)                                                        
261: R246        Fair value of assets and liabilities - Changes in   HTML    143K  
                level 3 financial assets (Details)                               
262: R247        Fair value of assets and liabilities - Changes in   HTML    124K  
                level 3 financial liabilities (Details)                          
263: R248        Fair value of assets and liabilities - Sensitivity  HTML    102K  
                analysis of level 3 instruments (Details)                        
264: R249        Fair value of assets and liabilities - Methods      HTML    141K  
                applied in determining fair values of financial                  
                assets and liabilities (Carried at Amortised Cost)               
                (Detail)                                                         
265: R250        Derivatives and hedge accounting - Gross carrying   HTML     97K  
                value of derivatives designated under fair value                 
                hedge accounting (Details)                                       
266: R251        Derivatives and hedge accounting - Maturity         HTML    121K  
                derivatives designated in fair value hedging                     
                (Details)                                                        
267: R252        Derivatives and hedge accounting - Hedged items     HTML    132K  
                included in a fair value hedging relationship                    
                (Details)                                                        
268: R253        Derivatives and hedge accounting - Gross carrying   HTML     99K  
                value of derivatives used for cash flow hedge                    
                accounting (Details)                                             
269: R254        Derivatives and hedge accounting - Maturity         HTML    132K  
                derivatives designated in cash flow hedging                      
                (Details)                                                        
270: R255        Derivatives and hedge accounting - Cash flow        HTML    145K  
                hedging - impact of hedging instruments on the                   
                statement of profit or loss and other                            
                comprehensive income (Detail)                                    
271: R256        Derivatives and hedge accounting - Movement cash    HTML    107K  
                flow hedge reserve (Details)                                     
272: R257        Derivatives and hedge accounting - Gross carrying   HTML     93K  
                value of derivatives used for net investment                     
                hedging (Details)                                                
273: R258        Derivatives and hedge accounting - Maturity         HTML    109K  
                derivatives designated in net investment hedging                 
                (Details)                                                        
274: R259        Derivatives and hedge accounting - Net investment   HTML    104K  
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‘EX-97’   —   Clawback Policy re: Recovery of Erroneously Awarded Compensation


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EXHIBIT 97 CLAWBACK RULES FOR ERRONEOUSLY AWARDED VARIABLE REMUNERATION FOR EXECUTIVE OFFICERS
I.BACKGROUND
ING Groep N.V. (hereafter “ING”) has adopted these Clawback Rules regarding the recovery of erroneously awarded Variable Remuneration (“Clawback Rules”) to provide for the recovery or “clawback” of excess Variable Remuneration awarded to current or former Executive Officers of ING in the event of a required Restatement (as defined below).
These Clawback Rules are intended to comply with the requirements of Section 303A.14 of the New York Stock Exchange (“NYSE”) Listed Company Manual (the “Listing Standard”). To the extent that any provision in these Clawback Rules is ambiguous as to its compliance with the Listing Standard or to the extent any provision in these Clawback Rules must be modified to comply with the Listing Standard, such provision will be read, or will be modified, as the case may be, in such a manner so that all applicable provisions under these Clawback Rules comply with the Listing Standard.
II. INTRODUCTION
In the event that ING is required to prepare an accounting restatement due to the material non-compliance of ING with any financial reporting requirement under applicable securities laws, including any required accounting restatement to correct an error in previously issued financial statements that is material to the previously issued financial statements, or that would result in a material misstatement if the error were corrected in the current period or left uncorrected in the current period (a “Restatement”), ING shall recover reasonably promptly the amount of erroneously awarded Variable Remuneration in compliance with these Clawback Rules except to the extent provided under the section entitled “V. Exceptions” herein. Recovery can be effectuated by ING amongst others by means of applying clawback (returning ownership of paid and/or vested Variable Remuneration) and/or holdback (forfeiture of awarded but unvested Variable Remuneration) and/or in-year Variable Remuneration reduction (reduction of awarded but not yet paid Variable Remuneration related to a specific performance year) of the erroneously awarded Variable Remuneration.
III. SCOPE OF CLAWBACK RULES
A. Persons covered and recovery period. These Clawback Rules apply to all Variable Remuneration received by an Executive Officer:
after beginning service as an Executive Officer,
who served as an Executive Officer at any time during the performance period for that Variable Remuneration,
while ING has a class of securities listed on NYSE (or any other recognised US stock exchange), and
during the three completed financial years immediately preceding the date that ING is required to prepare a Restatement (the “Recovery Period”).
Notwithstanding this look-back requirement, ING is only required to apply these Clawback Rules to Variable Remuneration received on or after 2 October 2023.
For purposes of these Clawback Rules, Variable Remuneration shall be deemed “received” in ING’s fiscal period during which the Financial Reporting Measure (as defined herein) specified in the Variable Remuneration award is attained, even if the payment or grant of the Variable Remuneration occurs after the end of that period.
B. Transition period. In addition to the Recovery Period, these Clawback Rules apply to any transition period (that results from a change in ING’s fiscal year) within or immediately following the Recovery Period (a “Transition Period”), provided that a Transition Period between the last day of ING’s previous fiscal year end and the first day of ING’s new fiscal year that comprises a period of nine to 12 months will be deemed a completed fiscal year. For clarity, ING’s obligation to recover erroneously awarded Variable Remuneration under these Clawback Rules is not dependent on if or when a Restatement is filed.
C. Determining recovery period. For purposes of determining the relevant Recovery Period, the date that ING is required to prepare the Restatement is the earlier to occur of:
the date the Relevant Body concludes, or reasonably should have concluded, that ING is required to prepare a Restatement, or
the date a court, regulator, or other legally authorized body directs ING to prepare a Restatement.

IV. AMOUNT SUBJECT TO RECOVERY
A. Recoverable amount. The amount of Variable Remuneration subject to recovery under these Clawback Rules is the amount of Variable Remuneration received that exceeds the amount of Variable Remuneration that otherwise would have been received had it been determined based on the restated amounts, computed without regard to any taxes paid.
B. Covered compensation based on stock price. For Variable Remuneration based on stock price, where the amount of erroneously awarded Variable Remuneration is not subject to mathematical recalculation directly from the information in a Restatement, the recoverable amount shall be based on a reasonable estimate of the effect of the Restatement on the stock price upon which the Variable Remuneration was received. In such event, ING shall maintain documentation of the determination of that reasonable estimate and provide such documentation to NYSE.



V. EXCEPTIONS
ING shall recover erroneously awarded Variable Remuneration in compliance with these Clawback Rules except to the extent that the conditions set out below are met and the Supervisory Board of ING Groep N.V. has decided that recovery would be impracticable:
A. Direct expense exceeds recoverable amount. The direct expense paid to a third party to assist in enforcing these Clawback Rules would exceed the amount to be recovered; provided, however, that before concluding it would be impracticable to recover any amount of erroneously awarded Variable Remuneration based on the anticipated expense of enforcement, ING shall make a reasonable attempt to recover such erroneously awarded Variable Remuneration, document such reasonable attempt(s) to recover, and provide that documentation to NYSE.
B. Violation of home country law. Recovery would violate Dutch law and/or any other relevant jurisdiction law that is applicable to the relevant Executive Officer (“Relevant Law”), where such law was adopted prior to November 28, 2022; provided, however, that before concluding it would be impracticable to recover any amount of erroneously awarded Variable Remuneration based on violation of Relevant Law, ING shall obtain an opinion of legal counsel, acceptable to NYSE, that recovery would result in such a violation, and shall provide such opinion to NYSE.
C. Recovery from certain tax-qualified retirement plans. Recovery would likely cause an otherwise tax-qualified retirement plan, under which benefits are broadly available to employees of ING, to fail to meet the requirements of 26 U.S.C. 401(a)(13) or 26 U.S.C. 411(a) and regulations thereunder.
VI. PROHIBITION AGAINST INDEMNIFICATION
ING shall not indemnify any Executive Officer or former Executive Officer against the loss of erroneously awarded Variable Remuneration.
VII. DISCLOSURE
ING shall file all disclosures with respect to recoveries under these Clawback Rules in accordance with the requirements of the U.S. Federal securities laws, including the disclosure required by the applicable Securities and Exchange Commission (“SEC”) filings.
VIII. DEFINITIONS
Unless the context otherwise requires, the following definitions apply for purposes of these Clawback Rules:
Executive Board” means the management board of ING Groep N.V.
Executive Officer” means a member of the Executive Board or of the Management Board Banking.
Financial Reporting Measures” means any of the following: (i) measures that are determined and presented in accordance with the accounting principles used in preparing ING’s financial statements, and any measures that are derived wholly or in part from such measures, (ii) stock price or (iii) total shareholder return. A Financial Reporting Measure need not be presented within ING’s financial statements or included in a filing with the SEC.
Management Board Banking” means the management board of ING Bank N.V.
Relevant Body” means the Executive Board, a committee of the Executive Board, or the officer or officers of ING authorised to conclude that ING is required to prepare a Restatement if the Executive Board action is not required.
Variable Remuneration” means any compensation that is awarded, granted, earned, or vested based wholly or in part upon the attainment of a Financial Reporting Measure.
IX. EFFECTIVENESS
These Clawback Rules shall be effective as of 1 December 2023. These Clawback Rules are meant to apply in conjunction with the clawback rules and provisions as outlined in applicable laws and regulations (such as legislation and rules pursuant to the EU Capital Requirements Directive) and ING’s implementation thereof.






Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘20-F’ Filing    Date    Other Filings
Filed on:3/8/24IRANNOTICE
For Period end:12/31/2313F-HR
11/28/22
 List all Filings 


2 Subsequent Filings that Reference this Filing

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 3/13/24  ING Groep NV                      424B5                  2:1.4M                                   Donnelley … Solutions/FA
 3/11/24  ING Groep NV                      424B5                  1:1.4M                                   Donnelley … Solutions/FA


14 Previous Filings that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 9/11/23  ING Groep NV                      8-A12B                 1:22K                                    Donnelley … Solutions/FA
 5/17/22  ING Groep NV                      6-K         5/17/22    2:116K                                   Donnelley … Solutions/FA
 3/28/22  ING Groep NV                      6-K         3/28/22    7:926K                                   Donnelley … Solutions/FA
 9/14/21  ING Groep NV                      6-K         9/14/21    7:900K                                   Donnelley … Solutions/FA
 4/01/21  ING Groep NV                      6-K         4/01/21    7:887K                                   Donnelley … Solutions/FA
 9/10/19  ING Groep NV                      6-K         9/10/19    7:742K                                   Donnelley … Solutions/FA
 4/09/19  ING Groep NV                      6-K         4/09/19    7:507K                                   Donnelley … Solutions/FA
10/02/18  ING Groep NV                      6-K        10/02/18    7:646K                                   Donnelley … Solutions/FA
 3/29/17  ING Groep NV                      6-K         3/29/17    8:944K                                   Donnelley … Solutions/FA
 4/16/15  ING Groep NV                      6-K         4/16/15    9:1.2M                                   Donnelley … Solutions/FA
 6/12/07  ING Groep NV                      6-K         6/06/07    3:316K                                   Donnelley … Solutions/FA
 9/23/05  ING Groep NV                      6-K         9/23/05    3:227K                                   Donnelley … Solutions/FA
 3/30/04  ING Groep NV                      20-F       12/31/03   16:4.1M                                   Bowne - Bol/FA
 3/27/03  ING Groep NV                      20-F       12/31/02   12:6.1M                                   Bowne - Bol/FA
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