Zero tolerance approach to bribery and corruption

We expect all ING employees at every level of the organisation to always do business in accordance with the values and behaviours of our Orange Code.

We have a zero tolerance approach when it comes to bribery and corruption. We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose. Nor do we, or will we, accept bribes or improper inducements or anything that could be perceived as such. We expect the same from our customers, business partners and third parties we retain or that perform services or deliver business on our behalf. Bribery and corruption is not accepted in any form.

Learn about:

The principles of ING’s Anti-Bribery and Corruption Policy state

  1. All forms of bribery and corruption, including facilitation payments, are strictly prohibited.
  2. Gifts or entertainment must always be proportionate and reasonable; must have a legitimate purpose; and must not create a conflict of interest or the perception thereof.
  3. Employees and third parties may not make gifts or donations to political parties nor offer gifts or entertainment to candidates for political positions on ING’s behalf.
  4. Paid and unpaid internships and secondments should be based on merit.
  5. Questionable behaviour should be challenged and (suspected) improper payments or activities should be reported to management or via the whistleblower channels.

Additional information

Public officials

Legitimate business interactions with public officials or state-owned entities are subject to heightened attention and stricter conditions, such as pre-approvals and lower limits.

Travel and accommodation

Travel and accommodation should generally not be offered or accepted.

Charitable contributions

Charitable contributions should only be made to bona fide charities so they cannot be used to conceal a bribe.

Recording and registration

Expenses and payments related to third parties should be registered and accurately recorded in the financial books.

Violations

ING employees are encouraged to report violations via the internal reporting lines outlined in the Whistleblower Policy.

Facilitation Payments

(Also known as expediting payments) are small payments to expedite or secure the performance of routine governmental action.

These payments generally concern non-discretionary actions by a Public Official such as processing government paperwork or other types of documents.

Conflict of interest

The contradiction within any of the Bank's activities relating to the customer, the Bank and/or Employee(s).

A Conflict of Interest is when an Employee or the Bank has a conflicting interest that may influence the motivation or decisions of that Employee or the Bank, while maintaining the principle of acting in the best interests of the Client.

A Conflict of Interest may occur in any situation where a Bank’s Employee uses its role for personal or other benefit.

Bribery

Unacceptable actions involving the direct or indirect offering, obtaining or possibility of obtaining a benefit, or making a promise to offer a benefit in order to:

  • induce the person receiving the benefit to take actions contrary to the law, internal regulations or rules of professional ethics, including the omission or dishonest performance of official duties
  • or influence the content of decisions taken by public officials or induce such persons to take unlawful actions

Corruption

Corruption is dishonest or illegal behaviour.

Corruption means any abuse of a position of trust, influence or power in order to gain an undue advantage. This involves the conduct of both sides: that of the person who abuses his position as well as that of the person who (e.g. through Bribery) seeks to gain an undue advantage by this abuse.

Corruption can occur in relation to Public Officials as well as between companies or private persons. It is particularly prevalent in certain kinds of transactions (for example, when awarding public or private contracts or government licenses), in certain economic sectors, and in certain countries.

Corrupt practices can range from small favours in anticipation of a future advantage, or providing educational or employment opportunities for friends and relatives, to the payment of large sums of money to senior members of governments or companies.

Defined terms

Facilitation Payments

(Also known as expediting payments) are small payments to expedite or secure the performance of routine governmental action.

These payments generally concern non-discretionary actions by a Public Official such as processing government paperwork or other types of documents

Conflict of interest

The contradiction within any of the Bank's activities relating to the customer, the Bank and/or Employee(s).

A Conflict of Interest is when an Employee or the Bank has a conflicting interest that may influence the motivation or decisions of that Employee or the Bank, while maintaining the principle of acting in the best interests of the Client.

A Conflict of Interest may occur in any situation where a Bank’s Employee uses its role for personal or other benefit.

Corruption

Corruption is dishonest or illegal behaviour.

Corruption means any abuse of a position of trust, influence or power in order to gain an undue advantage. This involves the conduct of both sides: that of the person who abuses his position as well as that of the person who (e.g. through Bribery) seeks to gain an undue advantage by this abuse.

Corruption can occur in relation to Public Officials as well as between companies or private persons. It is particularly prevalent in certain kinds of transactions (for example, when awarding public or private contracts or government licenses), in certain economic sectors, and in certain countries.

Corrupt practices can range from small favours in anticipation of a future advantage, or providing educational or employment opportunities for friends and relatives, to the payment of large sums of money to senior members of governments or companies.

Bribery

Unacceptable actions involving the direct or indirect offering, obtaining or possibility of obtaining a benefit, or making a promise to offer a benefit in order to:

  • induce the person receiving the benefit to take actions contrary to the law, internal regulations or rules of professional ethics, including the omission or dishonest performance of official duties
  • or influence the content of decisions taken by public officials or induce such persons to take unlawful actions.