BY REGISTERED MAIL TO:]

ING Group N.V.

attn. Steven van Rijswijk

Bijlmerdreef 106

1102 CT Amsterdamthe Netherlands

and

ING Bank N.V.

attn. Steven van Rijswijk

Bijlmerdreef 1061

102 CT Amsterdamthe Netherlands

Subject: notice of liability for unlawful climate policy

January 19th, 2024

Dear Steven van Rijswijk,

The association Milieudefensie (Friends of the Earth - Netherlands) is addressing this letter to you as the Chairman of the Board of ING Group N.V. and ING Bank N.V. (hereinafter collectively: 'ING').1 Milieudefensie has established that ING is in breach of its legal societal standard of care by contributing to dangerous climate change.2 ING's current climate policy is flawed and leads to unacceptable greenhouse gas emissions. ING is consequently undermining achieving the 1.5°C target required by the Paris Agreement. This poses a great danger to society, the environment and nature. It also leads to human rights violations in the Netherlands and in the rest of the world, for current and future generations. In this letter Milieudefensie explains that ING's current policy is unlawful with regard to the public interest that Milieudefensie seeks to protect. Milieudefensie holds ING liable for this and requests that it eradicate this unlawful situation urgently. ING must see to it that ING's climate policy, financing and services be brought in accordance with the 1.5°C target of the Paris Agreement. In this letter we will explain and present the basis for our claims. We will explain the legal obligations and ING's breach of these obligations.3