ING Direct 2015 Annual Report Download - page 214

Contents
Who we are
Report of the
Management
Board
Corporate
Governance
Consolidated
annual accounts
Parent company
annual accounts
Other
information
Additional
information
Notes to the Consolidated annual accounts of ING Bank - continued
In cases where an employee from ING Bank suspects a breach of external laws and regulations, internal policies and minimum
standards and/or the Orange Code they are encouraged to (anonymously) speak up in line with the Whistleblower policy using the
most appropriate channel, e.g. the (external) ethics line.
Financial Economic Crime (‘FEC’) policy
The ING Bank FEC Policy directly reflects relevant national and international laws, regulations and industry standards. The ING Bank
FEC Policy is mandatory and applies to all ING banking entities, majority owned ING business, businesses under management control,
staff departments, product lines and to all client engagements and transactions.
Management of ING Bank entities maintain appropriate local procedures that enable them to comply with local laws, regulations and
the relevant ING Bank FEC Policy. Where local laws and regulations are more stringent, the local laws and regulations are applied.
Likewise the FEC Policy prevails when the standards therein are stricter than stipulated in local laws and regulations and if not
specifically forbidden (data privacy or bank secrecy).
The ING Bank FEC Policy provides a clear statement of what is required by all ING Bank entities in order to guard against any
involvement in criminal activity, and to participate in international efforts to combat money laundering and the funding of terrorist
and criminal activities. The requirements in the ING Bank FEC Policy cover minimum standards and controls related to: money
laundering, terrorist financing, export trade controls, proliferation financing, sanctions (economic, financial and trade) and countries
designated by ING Bank as Ultra High Risk Countries (UHRC). The effectiveness of those controls is reviewed periodically.
As a result of frequent evaluation of all businesses from economic, strategic and risk perspective ING Bank continues to believe that for
business reasons doing business involving certain specified countries should be discontinued. In that respect, ING has a policy not to
enter into new relationships with clients from these countries and processes remain in place to discontinue existing relationships
involving these countries. At present these countries are North Korea, Sudan, Syria, Iran and Cuba. Each of these countries is subject to
a variety of EU, US and/or other sanctions regimes. Iran, Sudan, and Syria are identified by the US as state sponsors of terrorism and
are subject to U.S. economic sanctions and export controls.
ING Bank has a robust FEC control framework in place to mitigate the risks related to Financial Economic Crime, and the framework is
embedded in the day-to-day processes. Amongst other controls the Sanctions Risk Assessment (SRA) procedure is a strong control to
mitigate the risks related to sanctions.
Also in 2015, the Ukraine-related sanctions as imposed earlier by both the US and the EU remained in force. Those sanctions restrict
amongst others the dealing in specific (financial) products with certain named parties. Management of ING Bank entities use their
existing control framework to ensure compliance with these sanctions.
Main developments in 2015
Compliance Conduct Risk Monitoring
The Bank Compliance Risk Management function enhanced its control framework by assessing the operation of soft controls in
relation to compliance risks in addition to hard controls. The aim of conduct risk monitoring is to assess the risks that might influence
the conduct and risk culture, promoting the individual integrity of all employees and enhancing the overall culture that is led by
integrity.
Bribery and/or corruption risk
ING Bank further enhanced its statutory framework in respect of sound and ethical operations, designed to prevent bribery and/or
corruption in whatever way, e.g. in the form of conflicts of interest. Bad press related to client related corruption is an intrinsic part of
ING Bank’s Customer Due Diligence/Know Your Customer process.
Regulator relationships
The Bank Compliance Risk Management function continued its policy of investing in pro-active relationship building with regulators in
the jurisdictions where ING Bank operates, by striving for an open two-way approach to communication and cooperation in identifying
and mitigating compliance risks for ING Bank as well as seeking to contribute to the regulatory debate going forward.
Review processes for setting benchmark rates
In 2015 ING Bank has reviewed its internal processes for contributing to setting various benchmark rates. Possible irregularities have
been investigated and remedial actions have been taken. ING Bank is cooperating with information requests and/or investigations of
regulators and other authorities concerning ING Bank’s contribution to setting various benchmark rates. It is at this moment not
possible to assess whether ING Bank will be subject to monetary or other penalties, or the amount and nature thereof if they should
arise.
ING Bank Annual Report 2015 212