Bond ING Groep 2.9% ( XS2104016444 ) in USD

Issuer ING Groep
Market price 100 %  ⇌ 
Country  Netherlands
ISIN code  XS2104016444 ( in USD )
Interest rate 2.9% per year ( payment 2 times a year)
Maturity 17/01/2030 - Bond has expired



Prospectus brochure of the bond ING Bank XS2104016444 in USD 2.9%, expired


Minimal amount 1 000 000 USD
Total amount 10 000 000 USD
Detailed description ING Bank is a multinational banking and financial services corporation headquartered in Amsterdam, offering a wide range of banking products and services to individuals and businesses globally.

The Bond issued by ING Groep ( Netherlands ) , in USD, with the ISIN code XS2104016444, pays a coupon of 2.9% per year.
The coupons are paid 2 times per year and the Bond maturity is 17/01/2030







ING Bank N.V.
(Incorporated in The Netherlands with its statutory seat in Amsterdam)
25,000,000,000
Global Issuance Programme
Base Prospectus for the issuance of Medium Term Notes and Inflation Linked Notes
Under this Global Issuance Programme (the "Programme"), (i) ING Bank N.V. (the "Issuer", which expression shall include any Substituted Debtor (as
defined in Condition 17 of the Terms and Conditions of the Notes), "ING Bank" or the "Bank") may from time to time issue notes (the "Notes", as more fully
defined herein).
This Base Prospectus was approved by the Netherlands Authority for the Financial Markets (the "AFM") for the purposes of the Prospectus Directive
(Directive 2003/71/EC), as amended or superseded (the "Prospectus Directive"), on 6 May 2019 in respect of the issue by the Issuer of PD Notes (as defined
below). The AFM has provided the competent authorities in each of Belgium, France, Luxembourg and Poland with a certificate of approval attesting that this Base
Prospectus has been drawn up in accordance with the Prospectus Directive.
Notes to be issued under the Programme during the period of twelve months from the date of this Base Prospectus, which are:
(a) offered to the public in the European Economic Area in circumstances which require the publication of a prospectus under the Prospectus Directive,
whether or not such Notes are listed and admitted to trading on any market; or
(b) (i) admitted to trading on Euronext in Amsterdam, a regulated market of Euronext Amsterdam N.V. ("Euronext Amsterdam"); (ii) admitted to the
official list of the Luxembourg Stock Exchange (the "Official List"); (iii) admitted to trading on the regulated market of the Luxembourg Stock Exchange (the
"Luxembourg Stock Exchange"); (iv) admitted to trading on the parallel market of the Warsaw Stock Exchange (Gielda Papierów Wartociowych w Warszawie
S.A.) ("Warsaw Stock Exchange"); (v) admitted to trading on the regulated market of Euronext Paris S.A. ("Euronext Paris"); (vi) admitted to trading on another
regulated market within the European Economic Area or (vii) admitted to trading on an unregulated market as defined under Directive 2014/65/EU of the European
Parliament and of the Council on markets in financial instruments, as amended from time to time ("MiFID II"),
are hereinafter referred to as "PD Notes". PD Notes may be issued in any denomination as agreed between the Issuer and the relevant Dealer(s) (as defined herein),
and any PD Notes which have a denomination of less than 100,000 (or its equivalent in any other currency) are referred to hereinafter as "Non-Exempt PD Notes"
and any PD Notes which have a denomination of at least 100,000 (or its equivalent in any other currency at the date of issue of the Notes) are referred to hereinafter
as "Exempt PD Notes".
The Issuer may also issue unlisted Notes and/or Notes not admitted to trading on any regulated market within the European Economic Area and, where such
Notes are, in addition, issued with a minimum denomination of at least 100,000 (or its equivalent in any other currency at the date of issue of the Notes) or
otherwise fall within an exemption from the requirement to publish a prospectus under the Prospectus Directive, such Notes are hereinafter referred to as "Exempt
Notes".
The Issuer may from time to time issue PD Notes (which may be Non-Exempt PD Notes or Exempt PD Notes) and Exempt Notes.
The AFM has neither approved nor reviewed information contained in this Base Prospectus in connection with the issue of any Exempt Notes.
Prospective investors should have regard to the factors described under the section headed "Risk Factors" of this Base Prospectus.
Amounts payable under the Notes may be calculated by reference to the Euro Interbank Offered Rate ("EURIBOR") which is provided by the European
Money Markets Institute ("EMMI"), London Interbank Offered Rate ("LIBOR") which is provided by the ICE Benchmark Administration Limited ("ICE"), or any
other benchmark, in each case as specified in the applicable Final Terms. As at the date of this Base Prospectus, ICE is included the in register of administrators and
benchmarks established and maintained by the European Securities and Markets Authority ("ESMA") pursuant to Article 36 of the Benchmarks Regulation
(Regulation (EU) 2016/1011) (the "Benchmark Regulation"). EMMI is not included in the register of administrators and benchmarks established and maintained
by ESMA pursuant to Article 36 of the Benchmark Regulation.
As far as the Issuer is aware, the transitional provisions in Article 51 of the Benchmark Regulation apply, such that EMMI is not currently required to obtain
authorisation or registration (or, if located outside the European Union, recognition, endorsement or equivalence).
If a benchmark (other than EURIBOR or LIBOR) is specified in the applicable Final Terms, the applicable Final Terms will indicate whether or not the
benchmark is provided by an administrator included in the register of administrators and benchmarks established and maintained by ESMA pursuant to Article 36 of
the Benchmark Regulation.
The registration status of any administrator under the Benchmark Regulation is a matter of public record and, save where required by applicable law the
Issuer does not intend to update the Base Prospectus or any applicable Final Terms to reflect any change in the registration status of the administrator.
This Base Prospectus should be read and construed in conjunction with the Issuer Registration Document (as defined herein).
Arranger
ING
BASE PROSPECTUS (LEVEL 1)
Dated 6 May 2019


TABLE OF CONTENTS
Page
SUMMARY RELATING TO NON-EXEMPT PD NOTES ............................................................................... 2
RISK FACTORS ............................................................................................................................................... 63
DOCUMENTS INCORPORATED BY REFERENCE ..................................................................................... 94
OVERVIEW OF THE PROGRAMME ............................................................................................................. 99
CONSENT TO USE OF THIS BASE PROSPECTUS ................................................................................... 109
NOMINAL AMOUNT OF THE PROGRAMME ........................................................................................... 114
FORM OF THE NOTES ................................................................................................................................. 115
DTC INFORMATION ­ REGISTERED NOTES ISSUED BY THE ISSUER .............................................. 122
GENERAL TERMS AND CONDITIONS OF THE NOTES ......................................................................... 124
TERMS AND CONDITIONS OF INFLATION LINKED NOTES................................................................ 197
FORM OF FINAL TERMS OF THE NOTES ................................................................................................ 215
USE OF PROCEEDS ...................................................................................................................................... 299
TAXATION ..................................................................................................................................................... 300
ERISA AND CERTAIN OTHER U.S. CONSIDERATIONS ......................................................................... 331
SUBSCRIPTION AND SALE ........................................................................................................................ 333
GENERAL INFORMATION .......................................................................................................................... 355
1


SUMMARY RELATING TO NON-EXEMPT PD NOTES
This summary applies only to Non-Exempt PD Notes issued by ING Bank N.V. (the "Issuer").
Summaries are made up of disclosure requirements known as "Elements". These Elements are numbered
in Sections A to E (A.1 to E.7). This summary contains all the Elements required to be included in a summary for
the Notes and the Issuer. Because some Elements are not required to be addressed, there may be gaps in the
numbering sequence of the Elements. Even though an Element may be required to be inserted in a summary
because of the nature of the Notes and the Issuer, it is possible that no relevant information can be given regarding
the Element. In this case, a short description of the Element should be included in the summary with the mention of
"Not Applicable".
Section A­ Introduction and warnings
Element
A.1
Warning and
This summary must be read as an introduction to the Base Prospectus. Any
introduction
decision to invest in the Notes should be based on a consideration of the Base
Prospectus as a whole, including any documents incorporated by reference.
Where a claim relating to the information contained in the Base Prospectus is
brought before a court, the plaintiff may, under the national legislation of
Member States of the European Economic Area where the claim is brought, be
required to bear the costs of translating the Base Prospectus before the legal
proceedings are initiated. Civil liability attaches only to those persons who have
tabled the summary, including any translation thereof, but only if the summary is
misleading, inaccurate or inconsistent when read together with the other parts of
the Base Prospectus or it does not provide, when read together with the other
parts of the Base Prospectus, key information in order to aid investors when
considering whether to invest in the Notes.
A.2
Consent by the
Programme summary
Issuer to the use
The Issuer may provide its consent to the use of the Base Prospectus and the
of the Base
applicable Final Terms for subsequent resale or final placement of Notes by
Prospectus for
financial intermediaries to whom the Issuer has given its consent to use the Base
subsequent resale
Prospectus (an "Authorised Offeror"), provided that the subsequent resale or
or final placement final placement of Notes by such financial intermediaries is made during the
by financial
Offer Period specified in the applicable Final Terms. Such consent may be
intermediaries
subject to conditions which are relevant for the use of the Base Prospectus.
during the offer
In the context of any Public Offer of Notes, the Issuer accepts responsibility, in
period indicated,
each of the Public Offer Jurisdictions, for the content of the Base Prospectus in
and the
relation to any person (an "Investor") who purchases any Notes in a Public
conditions
Offer made by a Dealer or an Authorised Offeror, where that offer is made
attached to such
during the Offer Period (as specified in the applicable Final Terms).
consent
Consent
The Issuer consents and (in connection with paragraph (D) below) offers to grant
its consent to the use of the Base Prospectus (as supplemented at the relevant
time, if applicable) in connection with any Public Offer of a Tranche of Notes in
the Public Offer Jurisdictions specified in the applicable Final Terms during the
2


Element
Offer Period specified in the applicable Final Terms by:
Specific consent
(A) the Dealer or Managers specified in the applicable Final Terms;
(B) any financial intermediaries specified in the applicable Final Terms; and
(C) any other financial intermediary appointed after the date of the applicable
Final Terms and whose name is published on the Issuer's website
(https://www.ingmarkets.com/en-nl/ing-markets/) and identified as an
Authorised Offeror in respect of the relevant Public Offer; and
General consent
(D) if General Consent is specified in the applicable Final Terms as applicable,
any other financial intermediary which (a) is authorised to make such offers
under MiFID II; and (b) accepts such offer by publishing on its website a
statement that it agrees to use the Base Prospectus in accordance with the
Authorised Offeror Terms and subject to the conditions to such consent.
Common conditions to consent
The conditions to the Issuer's consent are (in addition to the conditions
described in paragraph (D) above if Part B of the Final Terms specifies "General
Consent" as "Applicable") that such consent:
(a) is only valid in respect of the relevant Tranche of Non-Exempt PD
Notes;
(b) is only valid during the Offer Period specified in the applicable Final
Terms; and
(c) only extends to the use of the Base Prospectus to make Public Offers
of the relevant Tranche of Non-Exempt PD Notes in one or more of
the Public Offer Jurisdictions, as specified in the applicable Final
Terms.
Issue specific summary
[Consent: Subject to the conditions set out below, the Issuer consents to the use
of the Base Prospectus in connection with a Public Offer (as defined below) of
Notes by the [Dealer][Manager][s][Issuer], [], [and] [each financial
intermediary whose name is published on the Issuer's website
(https://www.ingmarkets.com/en-nl/ing-markets/)
and
identified
as
an
Authorised Offeror in respect of the relevant Public Offer] [and any financial
intermediary which is authorised to make such offers under the applicable
legislation implementing Directive 2014/65/EU ("MiFID II") and publishes on
its website the following statement (with the information in square brackets
duly completed with the relevant information):
"We, [specify legal name of financial intermediary], refer to the offer of
[specify title of relevant Notes] (the "Notes") described in the Final Terms
dated [specify date] (the "Final Terms") published by ING Bank N.V. (the
"Issuer"). In consideration of the Issuer offering to grant its consent to our use
of the Base Prospectus (as defined in the Final Terms) in connection with the
3


Element
offer of the Notes in [Belgium, France, Luxembourg, Poland and The
Netherlands] during the Offer Period in accordance with the Authorised
Offeror Terms (as specified in the Base Prospectus), we accept the offer by the
Issuer. We confirm that we are authorised under MiFID II to make, and are
using the Base Prospectus in connection with, the Public Offer accordingly.
Terms used herein and otherwise not defined shall have the same meaning as
given to such terms in the Base Prospectus."
A "Public Offer" of Notes is an offer of Notes (other than pursuant to Article
3(2) of the Prospectus Directive) in [Belgium, France, Luxembourg, Poland
and The Netherlands] during the Offer Period specified below. Those persons
to whom the Issuer gives its consent in accordance with the foregoing
provisions are the "Authorised Offerors" for such Public Offer.
Offer Period: The Issuer's consent referred to above is given for Public Offers
of Notes during the period from [] to [] (the "Offer Period").
Conditions to consent: The conditions to the Issuer's consents [(in addition to
the conditions referred to above)] are such that consent: (a) is only valid in
respect of the relevant Tranche of Notes; (b) is only valid during the Offer
Period; [and] (c) only extends to the use of the Base Prospectus to make Public
Offers of the relevant Tranche of Notes in [Belgium, France, Luxembourg,
Poland and The Netherlands,] [; and (d) []].
An investor intending to acquire or acquiring Notes in a Public Offer from an
Authorised Offeror other than the Issuer will do so, and offers and sales of such
Notes to an investor by such Authorised Offeror will be made, in accordance
with any terms and other arrangements in place between such Authorised
Offeror and such investor, including as to price, allocations, expenses and
settlement arrangements.
Each investor must look to the relevant Authorised Offeror at the time of
any such Public Offer for the provision of information regarding the terms
and conditions of the Public Offer and the Authorised Offeror will be solely
responsible for such information.]
Section B ­ Issuer
Element
Title
B.1
Legal
and ING Bank N.V. (the "Issuer")
commercial
name of the
Issuer
4


Element
Title
B.2
The
domicile ING Bank N.V. is a public limited company (naamloze vennootschap)
and legal form incorporated under the laws of The Netherlands on 12 November 1927, with its
of the Issuer, corporate seat (statutaire zetel) in Amsterdam, The Netherlands.
the legislation
under which the
Issuer operates
and its country
of incorporation
B.4b
A description of The results of operations of ING Bank N.V. are affected by demographics,
any
known regulations and by a variety of market conditions, including economic cycles,
trends affecting
the Issuer and banking industry cycles and fluctuations in stock markets, interest and foreign
the industries in exchange rates, political developments and client behaviour changes.
which
it
operates
Financial environment
Global economic growth more uneven
Brexit negotiations took place throughout 2018 and the year ended without an
agreement on how the UK would leave the EU. ING Bank continued to take
steps throughout 2018 to prepare for various options, such as applying for a
banking licence in the UK, taking actions for contract continuity and working to
establish alternatives in the EU for those euro clearing activities that are
expected to move from London following Brexit.
Economic growth in some key emerging markets (China, Turkey, Argentina)
slowed as trade-restrictive measures increased, financial conditions tightened,
and in light of country-specific and geo-political factors.
Financial conditions slightly tighter
As economic momentum in the U.S. remained strong, the Federal Reserve
continued hiking interest rates. The European Central Bank reduced its asset
purchase programme.
Given differences in monetary policy stances and economic developments,
longer-term yields increased in the U.S. and, on balance, moved sideways in the
eurozone. However, in Italy, uncertainty about the forthcoming budget led to a
considerable increase in sovereign spreads. Given ING Bank's geographical
footprint, eurozone rate developments have a larger impact than rate
developments in the U.S.
There was little progress on eurozone reform in 2018 given the diverse political
interests involved. It's clear that the debate on the Economic and Monetary
Union is difficult, and progress on the completion of the banking union is slow.
ING Bank is hoping for progress on the European Deposit Insurance Scheme
("EDIS"), as it is an absolute requirement for finishing the Banking Union.
Furthermore, ING Bank has concerns about making a `sovereign debt
restructuring mechanism' part of the criteria for support from the European
Stability Mechanism.
The review of EU prudential rules, via CRR2/CRD5 (Capital Requirements
5


Element
Title
Regulation/Capital Requirements Directive) and BRRD2 (Bank Recovery and
Resolution Directive), was discussed during 2018 by the Council and the
European Parliament. The package includes the introduction of new rules, for
instance regarding NSFR (net stable funding ratio), a G-SIB (global
systemically important bank) surcharge for the leverage ratio, interest rate risk
in the banking book and internal MREL (minimum own funds and eligible
liabilities).
U.S. dollar on the rise
Strong economic growth and an associated increase in interest rates contributed
to a general U.S. dollar appreciation. Currencies of emerging economies with
weaker macroeconomic fundamentals and greater political uncertainty have
come under downward pressure, e.g. the Turkish lira. ING Bank must ensure
that this volatility does not impact the profitability of its operations in such
emerging markets.
Fluctuations in equity markets
ING Bank is exposed to fluctuations in equity markets. ING Bank maintains an
internationally diversified and mainly client-related trading portfolio.
Accordingly, market downturns are likely to lead to declines in securities
trading and brokerage activities which ING Bank executes for customers and
therefore to a decline in related commissions and trading results. In addition to
this, ING Bank also maintains equity investments in its own non- trading books.
Fluctuations in equity markets may affect the value of these investments.
Fluctuations in interest rates
ING Bank is exposed to fluctuations in interest rates. Mismatches in the interest
re-pricing and maturity profile of assets and liabilities in ING Bank's balance
sheet can affect the future interest earnings and economic value of the bank's
underlying banking operations. In addition, changing interest rates may impact
the (assumed) behaviour of ING Bank's customers, impacting the interest rate
exposure, interest hedge positions and future interest earnings, solvency and
economic value of the bank's underlying banking operations. In the current low
(and in some cases negative) interest rate environment in the Eurozone, the
stability of future interest earnings and margin also depends on the ability to
actively manage pricing of customer assets and liabilities. Especially, the pricing
of customer savings portfolios in relation to re-pricing customer assets and other
investments in ING Bank's balance sheet is a key factor in the management of
the bank's interest earnings.
Fluctuations in exchange rates
The Issuer is exposed to fluctuations in exchange rates. The Issuer's
management of exchange rate sensitivity affects the results of its operations
through the trading activities and because it prepares and publishes its
consolidated financial statements in euros. Because a substantial portion of ING
6


Element
Title
Bank's income, expenses and foreign investments is denominated in currencies
other than euros, fluctuations in the exchange rates used to translate foreign
currencies, particularly the U.S. Dollar, Pound Sterling, Turkish Lira, Chinese
Renminbi, Australian Dollar, Japanese Yen, Polish Zloty, Korean Won, the
Indian Rupee, Brazilian Real and Russian Ruble into euros will impact the
Issuer's reported results of operations, cash flows and reserves from year to
year. Fluctuations in exchange rates will also impact the value (denominated in
euro) of the Issuer's investments in its non-euro reporting subsidiaries. The
impact of these fluctuations in exchange rates is mitigated to some extent by the
fact that income and related expenses, as well as assets and liabilities, of each of
ING Bank's non-euro reporting subsidiaries are generally denominated in the
same currencies. FX translation risk is managed by taking into account the
effect of translation results on the core Tier-1 ratio.
Critical Accounting Policies
A number of new or amended standards became applicable for the current
reporting period. The Issuer changed its accounting policies as a result of
adopting IFRS 9 `Financial Instruments'. The amounts for the period ended 31
December 2018 have been prepared in accordance with IFRS 9. The Issuer has
applied the classification, measurement, and impairment requirements of IFRS 9
retrospectively as of 1 January 2018 by adjusting the opening balance sheet and
opening equity at 1 January 2018. The Issuer decided not to restate comparative
periods as permitted by IFRS 9.
The other standards and amendments, including IFRS 15, did not have any
impact on the group's accounting policies and did not require retrospective
adjustments.
Except for the amendment to IFRS 9 regarding prepayment features with
negative compensation, the Issuer has not early adopted any standard,
interpretation or amendment which has been issued, but is not yet effective.
For detailed information regarding ING Bank's accounting policies, including
changes in accounting policies, reference is made to Note 1 `Accounting
policies' to the Issuer consolidated financial statements for the year ended 31
December 2018, which are incorporated by reference herein.
Consolidated result of operations
ING Bank's management evaluates the results of its segments using a non-IFRS
financial performance measure called underlying result. To give an overview of
the underlying result measure, ING Bank also presents consolidated underlying
result before tax and underlying net result. Underlying figures are derived from
figures determined in accordance with IFRS-EU by excluding the impact of
divestments and special items. Special items include items of income or expense
that are significant and arise from events or transactions that are clearly distinct
from ordinary operating activities.
While items excluded from underlying result are significant components in
understanding and assessing ING Bank's consolidated financial performance,
ING Bank believes that the presentation of underlying net result is relevant and
7


Element
Title
useful for investors because it allows investors to understand the primary
method used by management to evaluate ING Bank's operating performance
and make decisions about allocating resources. In addition, ING Bank believes
that the presentation of underlying net result helps investors compare its
segment performance on a meaningful basis by highlighting result before tax
attributable to ongoing operations and the underlying profitability of the
segment businesses. For example, ING Bank believes that trends in the
underlying profitability of its segments can be more clearly identified by
disregarding the effects of the big restructuring provisions and realized
gains/losses on divestures as the timing of such events is largely subject to the
Company's discretion and influenced by market opportunities and ING Bank
does not believe that they are indicative of future results. ING Bank believes
that the most directly comparable GAAP financial measure to underlying net
result is net result. However, underlying net result should not be regarded as a
substitute for net result as determined in accordance with IFRS-EU. Because
underlying net result is not determined in accordance with IFRS-EU, underlying
net result as presented by ING Bank may not be comparable to other similarly
titled measures of performance of other companies. In addition, ING Bank's
definition of underlying net result may change over time.
B.5
A description of ING Bank N.V. is part of ING Groep N.V. ("ING Group"). ING Group is the
the
Issuer's holding company of a broad spectrum of companies (together called "ING")
group and the
Issuer's
offering banking services to meet the needs of a broad customer base. ING Bank
position within N.V. is a wholly-owned, non-listed subsidiary of ING Group and currently
the group
offers retail banking services to individuals, small and medium-sized enterprises
and mid-corporates in Europe, Asia and Australia and wholesale banking
services to customers around the world, including multinational corporations,
governments, financial institutions and supranational organisations.
B.9
Profit forecast Not Applicable. ING Bank N.V. has not made any public profit forecasts or
or estimate
profit estimates.
B.10
Qualifications
Not Applicable. The audit reports on the audited financial statements of ING
in the Auditors' Bank N.V. for the years ended 31 December 2017 and 31 December 2018 are
report
unqualified.
B.12
Selected
Key Consolidated Figures ING Bank N.V.(1)
historical key
financial
(EUR millions)
2018
2017
information
/ Balance sheet(3)
Significant or
material
Total assets
887,012
846,318
adverse change
Total equity
44,976
44,377
Deposits and funds borrowed(4)
719,783
679,743
Loans and advances
592,328
574,899
Results(5)
Total income
18,102
17,876
8


Element
Title
Operating expenses
10,695
9,795
Additions to loan loss provisions
656
676
Result before tax

6,751
7,404
Taxation
2,036
2,303
Net result (before non-controlling
4,715
5,101
interests)
Attributable to Shareholders of the
4,607
5,019
parent

Ratios (in per cent.)
BIS ratio(6)
17.22
18.19
Tier-1 ratio(7)
14.56
14.62
Notes:
(1) These figures have been derived from the 2018 audited consolidated financial
statements of ING Bank N.V. in respect of the financial years ended 31
December 2017 and 2018 respectively.
(2) The amounts for the period ended 31 December 2018 have been prepared in
accordance with IFRS9, the adoption of IFRS9 led to new presentation
requirements; prior period amounts have not been restated.
(3) At 31 December.
(4) Figures including Banks and Debt securities.
(5) For the year ended 31 December.
(6) BIS ratio = BIS capital as a percentage of Risk Weighted Assets (based on
Basel III phased-in). The year 2017 includes the interpretation of the EBA
Q&A published on 3 November 2017.
(7) Tier-1 ratio = Available Tier-1 capital as a percentage of Risk Weighted
Assets (based on Basel III phased-in).
Significant or Material Adverse Change
At the date hereof, there has been no significant change in the financial position
of ING Bank N.V. and its consolidated subsidiaries since 31 March 2019.
At the date hereof, there has been no material adverse change in the prospects of
ING Bank N.V. since 31 December 2018.
B.13
Recent material Not Applicable. There are no recent events particular to ING Bank N.V. which
events
are to a material extent relevant to the evaluation of the solvency of ING Bank
particular to the
Issuer's
N.V.
solvency
B.14
Dependence
The description of the group and the position of ING Bank N.V. within the
upon
other group is given under B.5 above.
group entities
Not Applicable. ING Bank N.V. is not dependent upon other entities within ING
9