ING MAR Disclosures
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Sales and Trading – MAR Investment Recommendation Disclosures

The Market Abuse Regulation (MAR) imposes requirements on certain communications to clients. Where a communication constitutes an ‘Investment Recommendation’, certain disclosures must be provided. These disclosures include statements as to certain potential conflicts of interest and as to changes to previous recommendations.


The ING Sales and Trading Investment Recommendations are prepared pursuant to ING policies, procedures and internal rules of conduct for managing conflicts of interest including information barriers and, where appropriate, establishing specific restrictions on sales and trading activity. Information concerning the management of conflicts of interest are available on request.


You will find the relevant disclosures below and/or attached to the communications you receive from ING when required. This website is updated on a daily basis with Investment Recommendations disseminated on the previous working day. This website also provides information on historical Investment Recommendations that have been issued by ING on in scope financial instruments or the issuers of those instruments during the previous 12 months.


No action is needed from you in regards to these disclosures. Should you have any questions, please speak to your usual ING contact


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Investment Recommendations expressed by Sales & Trading messages are those of the author or individual sender and may differ from the opinions expressed by other ING departments, including Research. For further information regarding the author of an Investment Recommendation please contact your ING representative. All Investment Recommendations and information stated in the list are based on the author’s opinion of the relevant market conditions as at the date and time the Investment Recommendation was disseminated and all Investment Recommendations may change at any time without prior notice. Unless stated otherwise, all Investment Recommendations are produced as an ad-hoc publication and there is no plan to update the recommendation. Investment Recommendations produced by one producer may be different or contradictory to those produced by another producer or even by the same producer at different times. The Investment Recommendations are provided for information purposes only and do not constitute an offer to sell or a solicitation to buy any security or other financial instrument. The Investment Recommendations may not be suitable for the specific investment objectives, financial situation or individual needs of any recipient and should not be relied upon in substitution for the exercise of your independent judgement. ING acts neither as an adviser to, nor owes any fiduciary duty to, any recipient and Investment Recommendations produced by ING are not intended to be and must not be relied upon as investment advice.


ING and its respective affiliates, connected companies, employees or clients may have an interest in financial instruments of the type described in this document and/or in related financial instruments. Such interest may include dealing in, trading, holding or acting as market-makers or liquidity providers in such instruments and may include providing banking, credit and other financial services to any company or issuer of securities or financial instruments referred to herein. Issuers mentioned in any material may be investment banking clients of ING and ING may have provided in the past, and may provide in the future, financing, advice, and securitization and underwriting services to these clients in connection with which it has received or will receive compensation. Accordingly, information included in or excluded from this material is not independent from the proprietary interests of ING, which may conflict with your interests.


ING does not, as a matter of policy, permit pre-arrangements with the issuers to produce recommendations nor permit issuers to review or see unpublished recommendations.


ING personnel (including the author(s) responsible for the Investment Recommendation) receive compensation based upon, among other factors, the overall profitability of ING Bank N.V., including profits derived from revenues for services of investment firms.


For the basis of valuations or methodologies or further information, and the underlying assumptions used to evaluate financial instruments or issuers or to set price targets please contact your ING representative. Access to confidential information is restricted to those who have a proper requirement for the information consistent with the legitimate interest of a client or the bank.


Definitions of ING Investment Recommendations: "Buy" means recommending an investor to buy a financial instrument. "Sell" means recommending an investor to sell a financial instrument. "Hold" means recommending an investor to keep a financial instrument.


The producing legal entity ING Bank N.V. is authorised by the Dutch Central Bank and supervised by the European Central Bank (ECB), the Dutch Central Bank and the Dutch Authority for the Financial Markets (AFM). ING Bank N.V. is incorporated in the Netherlands (Trade Register no. 33031431 Amsterdam). In the United Kingdom this information is approved and/or communicated by ING Bank N.V., London Branch. ING Bank N.V., London Branch is subject to limited regulation by the Financial Conduct Authority (FCA). ING Bank N.V., London branch is registered in England (Registration number BR000341) at 8-10 Moorgate, London EC2R 6DA. ING Bank N.V. London Branch.


Distribution: Any Investment Recommendation is issued: 1) in the United Kingdom only to persons described in Articles 19, 47 and 49 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 and is not intended to be distributed, directly or indirectly, to any other class of persons (including private investors); 2) in Italy only to persons described in Article No. 58 and in Annex No. 3 of Consob Regulation No. 16190/07. In EEA jurisdictions the material is addressed to MIFID Eligible and MIFID Professional counterparties.


[United States: Any person wishing to discuss this report or effect transactions in any security discussed herein should contact ING Financial Markets LLC, which is a member of the NYSE, FINRA and SIPC and part of ING, and which has accepted responsibility for the distribution of this report in the United States under applicable requirements. The distribution of this report in other jurisdictions may be restricted by law or regulation and persons into whose possession this document comes should inform themselves about, and observe, any such restrictions.]

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