ING’s Corporate Access (CA) Policy

ING offers Corporate Access to clients on the basis that it is considered a minor non-monetary benefit provided under Article 24(7) of Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments (MiFID II). As noted by the European Securities and Markets Authority, it is the responsibility of the regulated firm consuming corporate access to pay for it where required by their supervisory authority. The points set out below reflect ING’s understanding and position in relation to the consumption of corporate access under MiFID II and we will proceed on this basis unless you inform us otherwise. As a condition to attending any events or other corporate access, you represent that you will comply with and fulfil your obligations under applicable laws and regulations.

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. This website is updated with Investment Recommendations on a real time basis. This website also provides information on historical Investment Recommendations that have been issued by ING on companies under coverage. No action is needed from you in regards to these disclosures. Should you have any questions, please speak to your usual ING contact.

For clients authorised and regulated by the UK Financial Conduct Authority

If you are a firm authorised and/or regulated by the UK Financial Conduct Authority, in your consideration and compliance with the rules applicable to you regarding the use of dealing commissions, you may determine that you need to make a payment from your own funds for corporate access or ancillary services provided to you by ING to remain compliant with the rules applicable to your firm regarding inducements and payment for minor non-monetary benefits.

For clients authorised and regulated by a supervisor in the EU/EEA

ING provides corporate access pursuant to the guidance provided by the European Securities and Markets Authority and, therefore, does not normally require payment for such minor non-monetary benefits from regulated firms in the EU/EEA. However, it will be for the recipient investment firm to determine whether or not it can accept a benefit. We will continue to supply you with free corporate access as requested unless you require us to invoice you.

For Corporate Access originated on behalf of ING’S corporate clients

ING may provide corporate access services which have been originated on behalf of a corporate client. In such instances ING does not require payment in relation to such corporate access. Such services may include roadshows, meetings, telephone calls and other means to bring together our corporate clients with current and potential investors. We continue to operate on the understanding that Shareholders of such Corporates will not be asked to pay for access.

Please ensure you contact ( to agree pricing where relevant to the aforementioned. We remain able to also discuss concierge fees should this also form an element of your CA policy. Our Rate Card can be shared and we are able to utililse yours upon receipt.