Business Continuity Disclosure

In keeping with ING Investment Management’s commitment to safeguard the interests of its customers and employees in the event of an emergency or significant business disruption, the firm has developed a comprehensive approach to planning for the protection of its employees and the resumption of its critical business operations.

Overview

ING Investment Management’s Business Resumption Plan summarizes efforts to mitigate risks inherent with unforeseen business interruptions. The plan consists of three components.

A Crisis Management Plan addresses various crisis situations (i.e., electrical power outage, fire, bomb threat, inclement weather, etc.). The plan establishes a crisis committee to respond and implement an appropriate course of action in the event of a business disruption. Additionally, facilities are secured by restricted card key access as well as extensive other physical security measures undertaken by the property management office.

Second is the Business Continuity Plan which addresses business unit actions to be undertaken in a number of different disaster scenarios - from a wide scale disaster to the loss of a single building. All business unit activities are assessed and determined to be either critical (activities to be resumed within 24 hours) or non-critical (activities to be resumed after 24 hours). Documentation of how, by whom, where and with what tools critical activities will be resumed are included. Employees have a variety of options, as agreed with their management, for off-site work locations including other ING Investment Management sites, third party service recovery sites (Sungard), and residential locations.

The third component is the Disaster Recovery Plan, an information technology plan that addresses the recovery of systems and data. ING Investment Management’s disaster recovery site for data center services is 800 miles from its primary data center. Both sites have uninterruptible electrical power systems and electrical power generators in the event of any disruption of electrical service.

ING Investment Management continually refines its Business Resumption Plan through ongoing evaluation of the risk management aspects related to business conditions, local/regional events, national security level and other factors influencing the safety of employees and the ability to conduct business as required by customers and regulatory agencies.