ING Direct 2013 Annual Report Download - page 81

Internal control over financial reporting
Due to the listing of ING shares on the New York Stock Exchange,
ING Group is required to comply with the SEC regulations adopted
pursuant to Section 404 of the Sarbanes-Oxley Act, or SOX 404.
These regulations require that the CEO (the chairman of the
Executive Board) and the CFO of ING Group report and certify on
an annual basis on the effectiveness of ING Group’s internal
controls over financial reporting. Furthermore, the external auditors
are required to provide an opinion on the effectiveness of ING
Group’s internal controls over financial reporting. ING Group has
long-established Business Principles and a strong internal control
culture, which all staff must adhere to. SOX 404 activities are
organised along the lines of the governance structure, and involve
the participation of senior management across ING. Following the
SOX 404 process, ING is in the position to publish an unqualified
statement which denotes that the Company’s internal control over
financial reporting is effective as of 31 December 2013. The SOX
404 statement by the Executive Board is included on this page,
followed by the report of the external auditor.
REPORT OF THE EXECUTIVE BOARD ON INTERNAL CONTROL
OVER FINANCIAL REPORTING
The Executive Board is responsible for establishing and maintaining
adequate internal control over financial reporting. ING’s internal
control over financial reporting is a process designed under the
supervision of our principal executive and principal financial
officersto provide reasonable assurance regarding the reliability
offinancial reporting and the preparation of financial statements
for external purposes in accordance with generally accepted
accounting principles.
Our internal control over financial reporting includes those policies
and procedures that:
• pertain to the maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and dispositions of
the assets of ING;
• provide reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in
accordance with generally accepted accounting principles, and
that our receipts and expenditures are being made only in
accordance with authorisations of our management and
directors; and
• provide reasonable assurance regarding prevention or timely
detection of unauthorised acquisition, use or disposition of our
assets that could have a material effect on our financial
statements.
Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also,
projections of any evaluation of effectiveness to future periods are
subject to the risk that controls may become inadequate because of
changes in conditions, or that the degree of compliance with the
policies or procedures may deteriorate.
The Executive Board assessed the effectiveness of our internal
control over financial reporting as of 31 December 2013. In making
this assessment, the Executive Board performed tests based on
the criteria of the Committee of Sponsoring Organizations of the
Treadway Commission (“COSO”) in Internal Control – Integrated
Framework (1992 framework). Based on the Executive Board’s
assessment and those criteria, the Executive Board concluded that
the Company’s internal control over financial reporting is effective
as of 31 December 2013.
Our independent registered public accounting firm has audited and
issued their report on ING’s internal control over financial reporting,
which appears on the following page.
AMSTERDAM, 17 MARCH 2014
R.A.J.G. (Ralph) Hamers
CEO, CHAIRMAN OF THE EXECUTIVE BOARD
P.G. (Patrick) Flynn
CFO, MEMBER OF THE EXECUTIVE BOARD
79ING Group Annual Report 2013
1 Who we are 2 Report of the Executive Board 3 Corporate governance 4 Consolidated annual accounts 5 Parent company annual accounts 6 Other information 7 Additional information
Section 404 Sarbanes-Oxley Act