Division b)

Commitments regarding ING’s balance sheet reduction;

• ING continues to reduce its balance sheet by approximately 45 % compared to Q3 2008 via divestments^f1 or other measures aimed at reducing the size of the balance sheet (such as run down of portfolios)^f2 until 31 December 2015. The committed balance sheet reduction is based on ‘Q3 2008 data and does not take into account the possible impact of organic growth, FX changes, interest rate changes or additional increases due to potential new regulatory requirements, such as for example if banks are required to hold significantly larger liquidity buffers due to new EU-wide regulations.

• ING will not have a restriction on organic (that is to say not related to acquisitions) growth of the balance sheet of its businesses. ING continues to have a general policy to use its growth in funds entrusted by customers mainly to increase lending to the real economy (corporates and consumers) and continues to decrease its exposure to higher risk asset classes within CMBS and RMBS. It will not start new initiatives that increase its direct real estate exposure^f3, in line with ING’s general de-risking policy.

• ING commits to divest more than 50 % of ING Insurance/Investment Management (IM) Asia operations before 31 December 2013, more than 50 % of ING Insurance/IM US operations before 31 December 2014 and more than 50 % of ING Insurance/IM Europe operations before 31 December 2015^f4, in addition to the entities/business activities which ING already has divested/placed in run-off/completed as listed in Recital 77 of the 2012 Commission Decision and the latest bi-annual progress report^f5. In addition, for the US Insurance/IM business, ING commits to divest at least 25 % of the business before 31 December 2013^f6.

• Divesting control of more than 50 % of ING’s interest (i.e. measured in shares) in a business qualifies as meeting the divestment requirement. In such a case, ING will lose the majority in the board and will deconsolidate the business (in line with IFRS accounting rules). ING will divest its remaining interests in (i) ING Insurance/IM Europe before 31 December 2018, (ii) ING Insurance/IM US before 31 December 2016, and (iii) ING Insurance/IM Asia before 31 December 2016.