ISIM encourages and protects employees, former employees, candidates, and parties with whom ISIM has or had a business relationship who spear up when they encounter behavior by or within ISIM that is/seems unethical, illegal or goes against the values we promote.

The whistleblowing channel applies to concerns about, suspected or actual criminal conduct, unethical conduct or other misconduct including a (suspected) breach of (EU) law by or within ING / ISIM, including but not limited to:

• Accounting, internal accounting controls or auditing matters
• Money laundering or terrorist financing
• Financing clients who violate human rights or commit environmental crimes
• Market manipulation
• Insider trading
• Confidentiality or privacy breaches
• Theft
• Fraud
• Bribery or corruption
• Undesirable behaviours
• Violations of any other laws, regulations or ING/ISIM policies

ISIM’s whistleblowing channel (e.g. via email or post to ISIM's Whistleblower reporting officer) can be used to raise these concerns (anonymously or not), without fear of retaliation. It alerts management to allegations of crimes or other suspected misconduct and helps ensure appropriate and adequate action is taken to address the situation.