ING (L) Renta Fund

Open-ended Investment Companywith Variable Capital (SICAV)

FULL PROSPECTUS LULUXEMBOURG – SEPTEMBER 2009

INVESTMENT MANAGEMENT

ING (L) RentaFund

VISA 2009/53139-6-0-PCL'apposition du visa ne peut en aucun cas servird'argument de publicitéLuxembourg, le 09/09/2009Commission de Surveillance du Secteur Financier

For additional information please contact:

ING Investment ManagementP.O. Box 904702509 LL The HagueThe NetherlandsTel. +31 70 378 1800e-mail: [email protected] www.ingim.com

This prospectus has been produced using the 'Publication Management System'developed for the Investment Fund Industry by Imprimerie Centrale S.A. - Financial Services in Luxembourg.

ING (L) RENTA FUND LUXEMBOURG - SEPTEMBER 2009 FULL PROSPECTUS

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Table of contentsNote . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

PART I: ESSENTIAL INFORMATION REGARDING THE COMPANY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

I. Information on investments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

II. Subscriptions, redemptions and conversions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

III. Fees, expenses and taxation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

IV. Risk factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

V. Information and documents available to the public . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

PART II: SUB-FUND FACTSHEETS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

ING (L) Renta Fund Asian Debt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

ING (L) Renta Fund Corporate USD. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

ING (L) Renta Fund Dollar . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

ING (L) Renta Fund Emerging Markets Debt (Hard Currency) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

ING (L) Renta Fund Emerging Markets Debt (Local Currency) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

ING (L) Renta Fund Emerging Markets Debt (Local Bond) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

ING (L) Renta Fund Euro . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

ING (L) Renta Fund Euro Inflation Linked. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

ING (L) Renta Fund Euro Liquidity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

ING (L) Renta Fund Euro Long Duration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

ING (L) Renta Fund Eurocredit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62

ING (L) Renta Fund Euromix Bond. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

ING (L) Renta Fund Global High Yield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

ING (L) Renta Fund International . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78

ING (L) Renta Fund Sustainable Fixed Income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83

ING (L) Renta Fund World . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87

ING (L) Renta Fund Yen. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

PART III: ADDITIONAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97

I. The Company . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97

II. Risks linked to the investment universe: detailed description. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97

III. Investment restrictions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98

IV. Techniques and instruments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101

V. Management of the Company. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102

VI. Portfolio Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103

VII. Custodian, Paying Agent, Registrar Transfer Agent and Administrative Agent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103

VIII. Shares. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104

IX. Net asset value . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104

X. Suspension of the calculation of the net asset value and/or the issue, redemption and conversion of shares. . . . . . . . . 106

XI. Periodic reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106

XII. General meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106

XIII. Dividends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107

XIV. Liquidations, mergers and contributions of sub-funds or share classes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107

XV. Dissolution of the Company . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107

XVI. Stopped securities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108

XVII. Prevention of money laundering and the financing of terrorism. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108

XVIII. Conflicts of Interests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108

ING INVESTMENT MANAGEMENT 3

FULL PROSPECTUS LUXEMBOURG - SEPTEMBER 2009 ING (L) RENTA FUND


XIX. Nominees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108

4 ING INVESTMENT MANAGEMENT




NoteSubscriptions to the Company’s shares are only valid if they are madein accordance with the provisions of the current prospectus (simplified orfull prospectus) accompanied by the most recent annual report availableand, in addition, by the most recent semi-annual report if this waspublished after the most recent annual report. No parties are authorisedto provide information other than that which appears in the fullprospectus, simplified prospectus or in the documents referred to ineither prospectus as being available to the public for consultation.

This prospectus details the general framework applicable to all thesub-funds and should be read in conjunction with the factsheetsfor each sub-fund. These factsheets are inserted each time a newsub-fund is created and form an integral part of both the simplifiedand full prospectuses. Potential investors are requested to refer tothese factsheets prior to making any investment.

The prospectus (simplified and full) will be regularly updated to includeany significant modifications. Investors are advised to confirm with theCompany that they are in possession of the most recent prospectus. Inaddition, the Company will provide, free of charge, the most recentversion of the simplified prospectus to any shareholder or potentialinvestor.

The Company is established in Luxembourg and has obtained theapproval of the competent Luxembourg authority. This approval shouldin no way be interpreted as an approval by the competent Luxembourgauthority of either the contents of the prospectus or the quality of theshares of the Company or the quality of the investments that it holds.The Company's operations are subject to the prudential supervision ofthe competent Luxembourg authority.

Furthermore, the Company has not been registered under the UnitedStates Investment Company Act of 1940, as amended, or any similarregulation in any other jurisdiction except as described herein.Moreover, the shares of the Company have not been registered underthe United States Securities Act of 1933, as amended, or any similarregulation in any other jurisdiction except as described herein.

The shares of the Company may not be offered for sale or sold,transferred or delivered in the United States of America, its territories orpossessions or to any “US Person", as defined in Regulation S underthe US Act of 1933 (a definition which may change from time to time byvirtue of legislation, rules, regulations or administrative interpretations),except in a transaction which does not breach US laws on transferablesecurities.

Investors may be required to declare that they are not a “US Person”and that they are not subscribing in the name of or on behalf of a “USPerson”.

It is recommended that investors obtain information on the laws andregulations (in particular, those relating to taxation and exchangecontrols) applicable in their country of origin, residence or domicile asregards an investment in the Company and that they consult their ownfinancial or legal advisor or accountant on any issue relating to thecontents of this prospectus.

The Company confirms that it fulfils all the legal and regulatoryrequirements applicable to Luxembourg regarding the prevention ofmoney laundering and the financing of terrorism.

The Board of Directors is responsible for the information contained inthis prospectus on the date of its publication. Insofar as it canreasonably be aware, the Board of Directors certifies that theinformation contained in the prospectus has been correctly andaccurately represented and that no information has been omitted which,if it had been included, would have altered the significance of thisdocument. The value of the Company’s shares is subject to fluctuationsin a large number of elements. Any return estimates given or indicationsof past performance are provided for information purposes only and inno way constitute a guarantee of future performance. The Board of

Directors therefore warns that, under normal circumstances and takinginto consideration the fluctuation in the prices of the securities held inthe portfolio, the redemption price of shares may be higher or lower thanthe subscription price.

The official language of this prospectus is English. It may be translatedinto other languages. In the event of a discrepancy between the Englishversion of the prospectus and versions written in other languages, theEnglish version will take precedence, except in the event (and in thisevent alone) that the law of a jurisdiction where the shares are availableto the public stipulates otherwise. In this case, the prospectus willnevertheless be interpreted according to Luxembourg law. Anysettlement of disputes or disagreements with regard to investments inthe Company shall also be subject to Luxembourg law.

THIS PROSPECTUS IN NO WAY CONSTITUTES AN OFFER ORSOLICITATION TO THE PUBLIC IN JURISDICTIONS IN WHICH SUCHAN OFFER OR SOLICITATION TO THE PUBLIC IS ILLEGAL. THISPROSPECTUS IN NO WAY CONSTITUTES AN OFFER ORSOLICITATION TO A PERSON TO WHOM IT WOULD BE ILLEGAL TOMAKE SUCH AN OFFER OR SOLICITATION.




PART I: ESSENTIAL INFORMATIONREGARDING THE COMPANYBrief overview of the Company

Place, form and date of establishment

Established in Luxembourg, Grand Duchy of Luxembourg, as an open-ended investment company with variable share capital (Sociétéd’investissement à capital variable (“SICAV”)) with multiple sub-funds,on 25 January 1989.

Registered office

52, route d’Esch – L-1470 Luxembourg

Trade and Companies Register

No. B 29.732

Luxembourg supervisory authority

Commission de Surveillance du Secteur Financier (CSSF)

Board of Directors

Chairman:

- Mr Michel van ElkChairmanDirector and Head of Marketing and SalesING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

Directors:

- Mr Jonathan AtackChief Financial and Risk OfficerING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

- Mr David EckertChief Operating OfficerING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

- Mr Bruno SpringaelManaging DirectorING Investment Management Belgium24 avenue Marnix, Brussels 1050, Belgium

- Mrs Maaike van MeerHead of Legal ServicesING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

Independent Auditors

Ernst & Young S.A., société anonyme (public limited company)7 Parc d'activité Syrdall, L-5365 Munsbach(BP 780 - L-2017 Luxembourg)

Management Company

ING Investment Management Luxembourg S.A.52 route d'Esch, L-1470 Luxembourg

Portfolio Managers

ING Asset Management B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

ING Investment Management Asia Pacific (Hong Kong) Ltd39/F One International Finance Centre,1 Harbour View Street, Central, Hong Kong

ING Investment Management Belgium24 avenue Marnix, Brussels 1050, Belgium

ING Investment Management Co.230 Park Avenue, New York, NY 10169, United States

Custodian

ING Luxembourg S.A., société anonyme (public limited company)52 route d’Esch, L-1470 Luxembourg

Central administration

ING Investment Management Luxembourg S.A., société anonyme(public limited company)52 route d'Esch, L-1470 Luxembourg

Transfer agent and registrar

ING Luxembourg S.A., société anonyme (public limited company)52 route d’Esch, L-1470 Luxembourg

Promoter

ING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

Subscriptions, redemptions, conversions, financialservices

ING Luxembourg S.A. or any other establishment whose name appearsin the annual or semi-annual reports.

Financial year

From 1 April to 31 March of the following year

Date of the ordinary general meeting

The second Thursday of July at 10:40 (Luxembourg time)

(if this is not a bank business day in Luxembourg, the first followingbank business day)




I. Information on investments

General

The Company's sole object is to invest funds available to it intransferable securities and/or other liquid financial assets listed in Article41 (1) of the Law of 20 December 2002, with a view to enabling itsshareholders to benefit from the results of its portfolio management. TheCompany must comply with the investment limits as laid out in part I ofthe Law of 20 December 2002.

In the context of its objectives, the Company may offer a choice ofseveral sub-funds, which are managed and administered separately.The investment policies specific to each sub-fund are set out in thefactsheets relating to each sub-fund. In the context of its investments,the assets of any given sub-fund are only liable for the debts, liabilitiesand obligations concerning this sub-fund. In relations betweenshareholders, each sub-fund is treated as a separate entity.

The Board of Directors may issue one or more share classes for eachsub-fund. The fee structures, the minimum set out for the initialinvestment, the currency in which the net asset value is expressed andthe eligible investor categories may differ depending on the differentshare classes. The various share classes may also be differentiatedaccording to other objective elements as determined by the Board ofDirectors.

Information particular to each sub-fund

The investment objectives and policies to be followed for each sub-fundare described in the factsheet for each sub-fund.

II. Subscriptions, redemptions and conversions

Shares may be subscribed, redeemed and converted through INGLuxembourg S.A. and financial services companies. Fees and expensesrelating to subscriptions, redemptions and conversions are indicated ineach sub-fund factsheet.

Bearer shares and/or registered shares may be issued, as stipulated ineach sub-fund factsheet. The Board of Directors may decide to createfractions of shares.

The subscription, redemption or conversion price is subject to any taxes,levies and stamp duty payable by virtue of the subscription, redemptionor conversion.

If in any country in which the Shares are offered, local law or practicerequires subscription, redemption and/or conversion orders and relevantmoney flows to be transmitted via local paying agents, additionaltransaction charges for any individual order, as well as for additionaladministrative services and for Share Certificates delivery, may becharged to the investors by such local paying agents.

In certain countries in which the Shares are offered, Saving plans couldbe allowed. The characteristics (minimum amount, duration, etc.) andcost details about that Saving plans are available nearby the companyupon request or in the legal offering documentation valid for the specificcountry in which the Saving plan is offered.

In the event of the suspension of the net asset value calculation and/orthe suspension of subscription, redemption and conversion requests,the requests received will be executed at the first applicable net assetvalue upon the expiry of the suspension period.

The Company does not authorise practices associated with MarketTiming and reserves the right to reject subscription and conversionrequests from an investor that it suspects of employing such practicesand, where applicable, to take the measures necessary to protect theinterests of the Company and other investors.

Subscriptions

The Company accepts subscription requests on each bank businessday in Luxembourg unless otherwise stated in the sub-fund factsheets.Investors whose requests have been accepted will receive shares whichwill be issued on the basis of the applicable net asset value set out inthe sub-fund factsheets.

The amount due may be subject to a subscription fee payable to therelevant sub-fund and/or the distributor as more described in the sub-fund factsheets. Under no circumstances will the rate exceed the limitsstated in each of the sub-fund factsheets.

The subscription amount is payable in the reference currency of therelevant share class. Shareholders requesting to make the payment inanother currency must bear the cost of any foreign exchange charges.This amount is payable within the stated time limit for each sub-fund inthe sub-fund factsheets.

Shares are delivered within ten days of the date of the calculation of thenet asset value applicable to the subscription.

The Board of Directors of the Company will be entitled at any time tostop the issuance of shares. It may limit this measure to certaincountries, sub-funds or share classes.

The Company may limit or prohibit the acquisition of its shares by anynatural or legal person.

Redemptions

Each shareholder has the right to request the redemption of its shares.The redemption request is irrevocable.

The Company accepts redemption requests on each bank business dayin Luxembourg. The redemption amount will be set on the basis of theapplicable net asset value specified in each sub-fund factsheet.

The amount due may be subject to a redemption fee payable to therelevant sub-fund and/or the distributor as more described in the sub-fund factsheets. Under no circumstances will the rate exceed the limitsstated in each sub-fund factsheet.

When applying for the redemption of shares, shareholders must supply,where applicable, (i) the bearer shares (physical certificates) or (ii) theregistered share certificates, together with (iii) all unmatured coupons inthe case of distribution (bearer or registered) shares.

The usual taxes, fees and administrative costs will be borne by theshareholder.

The redemption amount is payable in the reference currency of therelevant share class. Shareholders requesting payment in anothercurrency must bear the cost of any foreign exchange charges.

Neither the Board of Directors nor the custodian may be responsible forany lack of payment resulting from the application of any exchangecontrol or other circumstances beyond their control which may limit orprevent the transfer abroad of the proceeds of the redemption of theshares.

The Company may proceed with the compulsory redemption of all theshares if it appears that a person who is not authorised to hold shares inthe Company (e.g. a US person), either alone or together with otherpersons, is the owner of shares in the Company, or proceed with thecompulsory redemption of part of the shares, if it emerges that one orseveral persons own(s) a proportion of the shares in the Company tothe extent that the Company may be subject to the tax laws of ajurisdiction other than Luxembourg.

Conversions

Shareholders may apply for any shares of any sub-fund to be convertedinto shares of another sub-fund, provided that the conditions foraccessing the target class of shares, type or sub-type are fulfilled withrespect to this sub-fund, on the basis of their respective net assetvalues calculated on the Valuation Day following receipt of theconversion request . Nevertheless, in the case of conversion requests in




a sub-fund for which the limit for receiving requests differs from thatapplicable to a subscription to the target sub-fund, the conversionapplication will be treated as a redemption request followed by asubscription request for the target sub-fund, without any additional costscharged to the shareholder.

Fractions of physical shares remaining following the conversion arebought back by the Company. This part is reimbursed to the shareholderat the applicable net asset value.

The redemption and subscription costs connected with the conversionmay be charged to the shareholder as indicated in each sub-fund'sfactsheet.

When applying for a conversion, shareholders must supply, whereapplicable, the bearer shares (physical certificates) together with allunmatured coupons, in the case of distribution shares, or the registeredshare certificates.

Subscriptions and redemptions in kind

The Company may, should a shareholder so request, agree to issueshares of the Company in exchange for a contribution in kind of eligibleassets, subject to compliance with Luxembourg law and in particular theobligation to produce an independent auditor's evaluation report. Thenature and type of eligible assets will be determined by the Board ofDirectors on a case by case basis, provided that the securities complywith the investment policy and objectives of the relevant sub-fund. Costsarising from such subscriptions in kind will be borne by the shareholderswho apply to subscribe in this way.

The Company may, following a decision taken by the Board of Directors,make redemption payments in kind by allocating investments from thepool of assets with respect to the share class or classes concerned upto the limit of the value calculated on the Valuation Day on which theredemption price is calculated. Redemptions other than those made incash will be the subject of a report drawn up by the Company’sindependent auditor. A redemption in kind is only possible provided that(i) equal treatment is afforded to shareholders, (ii) the shareholdersconcerned have so agreed and (iii) the nature and type of assets to betransferred are determined on a fair and reasonable basis and withoutharming the interests of the other shareholders of the relevant shareclass or classes. In this case, the costs arising from these redemptionsin kind will be borne by the pool of assets with respect to the shareclass or classes concerned.

III. Fees, expenses and taxation

A. FEES PAYABLE BY THE COMPANY

1. The Company shall bear the expenses relating to its formation andoperation and it may also cover promotional expenses. Theseexpenses may, in particular and without being limited to thefollowing, include the remuneration of the custodian, the Company’sdesignated management company and the auditor, the costs ofprinting, distributing and translating prospectuses and periodicreports, brokerage, fees, taxes and expenses connected with themovement of securities or cash, the Luxembourg “taxed'abonnement” (subscription tax) and any other taxes relating to theCompany's business, the costs of printing share certificates,translations and legal publications in the press, the financial servicescosts of its securities and coupons, the costs, where applicable, ofobtaining a listing on the stock exchange or of publishing the priceof its shares, the costs of official deeds, legal costs and legal advicecosts relating thereto and any directors’ fees. In certain cases, theCompany may also cover sums due to the authorities of countrieswhere its shares are available to the public, as well as any costsincurred in registering abroad. The Company may bear the cost ofthe remuneration of portfolio managers, investment advisors, theadministrative agent and other service providers, where applicable,

subject to the provision that the sums thus paid will be deductedfrom the remuneration allocated to the management companyappointed by the Company.

2. The Company will pay the custodian a custodian fee asremuneration, together with transaction fees, in accordance with theterms and conditions of the custodian agreement. This remunerationand the fees are payable monthly and are paid to the custodian bythe relevant sub-funds in arrears. The remuneration stipulated forcustodian services will be a maximum of 0.07% per year, calculatedon the basis of the value of the portfolio at the end of each month,with the exception of potential positions held on the emergingmarkets, for which the custodian is entitled to charge the sub-fundssub-custody and/or correspondent bank costs in addition.

3. In remuneration for its asset management services provided, theappointed management company, ING Investment ManagementLuxembourg S.A., will receive a management fee as stipulated ineach sub-fund factsheet and in the collective portfolio managementagreement concluded between the Company and ING InvestmentManagement Luxembourg S.A. For administrative managementservices provided to the Company, ING Investment ManagementLuxembourg S.A. will receive a fee calculated on the basis of theaverage net assets of each sub-fund, as stipulated in the collectiveportfolio management agreement concluded between the Companyand ING Investment Management Luxembourg S.A. Thisremuneration will not exceed 0.15% per year. These fees arepayable monthly in arrears. ING Investment ManagementLuxembourg S.A. is moreover entitled to pass on transfer agent feesto each sub-fund at cost. Should the central administrative agent orany other service provider appointed by the management companyreceive remuneration charged directly to the assets of the relevantsub-fund(s) of the Company, such payments will be deducted fromthe remuneration payable to ING Investment ManagementLuxembourg S.A..

4. The assets of a given sub-fund will be liable only for the debts,liabilities and obligations of that sub-fund. In relations betweenshareholders, each sub-fund is treated as a separate entity.

B. FEES AND EXPENSES PAYABLE BY INVESTORS

Where applicable, depending on the particular information stipulated inthe sub-fund factsheets, investors may be required to bear fees andexpenses arising from subscriptions, redemptions or conversions.

C. TAXATION

1. Taxation of the Company in Luxembourg

No fee or tax is payable in Luxembourg on the issue of Companyshares, with the exception of the fixed fee payable on theCompany's incorporation, which covers the raising of capital. Thisfee amounted to EUR 1,250 at the time of incorporation.

The Company is, in principle, subject to a taxe d'abonnement(subscription tax), at the annual rate of 0.05% per year on the netassets. However, this tax is reduced to 0.01% per year on the netassets of money market sub-funds and on the net assets of sub-funds and/or share classes reserved for institutional investors asprescribed by Article 129 of the Law of 20 December 2002. The taxis not applied to the portion of assets invested in other Luxembourgundertakings for collective investment. Under certain conditions,some sub-funds and/or share classes reserved for institutionalinvestors may be totally exempt from the taxe d'abonnement wherethese sub-funds invest in money market instruments and in depositswith credit institutions.

However, certain types of dividend and interest income on theCompany's portfolio may be subject to withholding taxes at varyingrates in the country of origin.




2. Taxation of investors

Investors are encouraged to seek advice from professionals on thelaws and regulations (in particular those relating to taxation andexchange controls) applicable to the subscription, purchase,ownership and sale of shares in their country of origin, residence ordomicile

Under the current tax system, corporate shareholders (with theexception of legal entities domiciled in Luxembourg for tax purposesor which are permanently established there) are not subject to anytaxation or withholding tax in Luxembourg on their income, realisedor unrealised capital gains, the transfer of shares or the distributionof income in the event of dissolution.

Under the current system, shareholders who are natural personsdomiciled in Luxembourg for tax purposes are not subject towithholding tax on income distributed by the Company. However,resident investors are taxable on distributions effected by theCompany. They may be taxable in the event of capital gainsrealised through the sale, reimbursement or redemption of shareswhere the holding period has not exceeded 6 months and/or theyhold over 10% of the shares issued by the Company.

The description of the current Luxembourg tax system does notpresume any possible future modifications whatsoever.

In the context of the system set up by the Council Directive 2003/48/ECon the taxation of savings income in the form of interest payments, non-resident natural persons may, from 1 July 2005, be subject towithholding tax on income from interest payments, regardless ofwhether this income comes from the distribution of Company dividendsor from income realised through the sale, reimbursement or redemptionof Company shares.

IV. Risk factors

Potential investors must be aware that the investments of each sub-fundare subject to normal and exceptional market fluctuations as well asother risks inherent in the investments described in the factsheet foreach sub-fund. The value of investments and the income generatedthereof may fall as well as rise and there is a possibility that investorsmay not recover their initial investment.

In particular, investors’ attention is drawn to the fact that if the objectiveof the sub-fund is long-term capital growth, depending on the investmentuniverse, elements such as exchange rates, investments in theemerging markets, the yield curve trend, changes in issuers' creditratings, the use of derivatives, investments in companies or theinvestment sector may influence volatility in such a way that the overallrisk may increase significantly and/or trigger a rise or fall in the value ofthe investments. A detailed description of the risks referred to in eachsub-fund factsheet can be found in the full prospectus.

It should also be noted that the investment manager may, in compliancewith the applicable investment limits and restrictions imposed,temporarily adopt a more defensive attitude by holding more cash in theportfolio when he believes that the markets or the economy in countriesin which the sub-fund invests are experiencing excessive volatility, apersistent general decline or other negative conditions. In suchcircumstances, the sub-fund concerned may prove to be incapable ofpursuing its investment objective, which may affect its performance.

V. Information and documents available to the public

1. Information

The net asset value of the shares of each class is made available tothe public at the Company's registered office, the custodian andother establishments responsible for financial services as of the firstbank business day following the calculation of the aforementionednet asset values. The Board of Directors will also publish the net

asset value using all the means that it deems appropriate, at leasttwice a month and at the same frequency as its calculation, in thecountries where the shares are offered to the public.

2. Documents

On request, before or after a subscription of shares of the Company,the prospectus, the simplified prospectus, the annual and semi-annual report may be obtained free of charge at the office of thecustodian bank and other establishments designated by it as well asat the Company’s registered office.




PART II: SUB-FUND FACTSHEETSShare classes:

''P'': Ordinary share class intended for individual investors.

''X'': Ordinary share class intended for individual investorsyet differing from class “P” in that it attracts a highermanagement fee and is distributed in certain countrieswhere market conditions require a higher fee structure.

“I”: Share class reserved for institutional investors and, inprinciple, issued in registered form only. "I" share classwill only be issued to subscribers who have completedtheir subscription form in compliance with theobligations, representations and guarantees to beprovided regarding their status as an institutionalinvestor, as provided for under Article 129 of the Law of20 December 2002. Any subscription application forclass “I” will be deferred until such time as the requireddocuments and supporting information have been dulycompleted and provided.

“S”: Share class intended for corporate beneficial ownerswith a minimum subscription amount of EUR 1,000,000subject to subscription tax of 0.05% per year on netassets.

“P Hedged”: Share class offered to retail investors and denominatedin a currency other than the reference currency of thesub-fund. This class of shares differs from the otherclasses in that it uses hedging techniques against theexposure on the reference currency of the sub-fund. Theinvestment manager may then use any type of financialderivative instruments linked to currency fluctuations,such as currency forward contracts, call or put option oncurrencies, currency swaps, forward foreign exchangetransactions and the technique whereby the investmentmanager effects a hedge of the currency of the classagainst exposure on the reference currency of the sub-fund by selling or purchasing another currency closelyrelated to it ("proxy hedging").

“I Hedged”: Share class offered to institutional investors anddenominated in a currency other than the referencecurrency of the sub-fund. This class of shares differsfrom the other classes in that it uses hedging techniquesagainst the exposure on the reference currency of thesub-fund. The investment manager may then use anytype of financial derivative instruments linked to currencyfluctuations, such as currency forward contracts, call orput option on currencies, currency swaps, forwardforeign exchange transactions and the techniquewhereby the investment manager effects a hedge of thecurrency of the class against exposure on the referencecurrency of the sub-fund by selling or purchasinganother currency closely related to it ("proxy hedging”).

“V”: Share class reserved for institutional investors and, inprinciple, issued in registered form only yet differing fromclass “I” in that it attracts a higher management fee.

Caption for diagram under “Investor risk profile” ineach factsheet.

ING uses a methodology named Risk Rating (EVAL©) that is based onthe historical observation of fluctuations in returns expressed in euro,especially their volatility (statistical standard deviation) with respect tothe average. There are 7 different risk classes (from 0, the lowest risk,to 6, the highest risk) identified by increasing volatility brackets. For sub-funds with no fixed term and no capital protection, the risk is calculated

on the basis of variations in the monthly returns of the net asset valueover the past 5 years or for a shorter period in case the sub-fund doesnot yet exist for 5 years. For sub-funds of less than one year, the risk iscalculated on the basis of variations in the monthly returns of thebenchmark index in the past 5 years.

For fixed-term sub-funds with capital protection, the risk is calculated onthe basis of variations in monthly returns, in cases where a history oftwo and a half years or over is available, and bi-monthly returns where aminimum 1-year history is available. For new sub-funds or sub-fundswith a history of under a year, the risk is calculated on the basis ofsimilar products in the absence of sufficient information for the relevantsub-fund.

The investment horizon of each sub-fund is defined as the duration intime (expressed in an entire number of years) during which theinvestment should last (from 1 year to more than 5 years) in order not tohistorically encounter any negative returns. For sub-funds denominatedin a currency other than the euro, the risk and horizon are alsocalculated in the investment currency.

Classification of sub-funds on the basis of their riskprofile.

The Company is authorised to adapt the method of calculation of theglobal exposure of each of its sub-funds to the risk profile resulting fromthe sub-funds’ investment policy and to the risk management’s level ofsophistication.

More specifically, the Company has conducted a self-assessment of thesub-funds’ risk profile and has classified each of them, on the basis ofthis analysis, either as a non-sophisticated sub-fund or as asophisticated sub-fund.

For that purpose, the following elements have been taken into account:

- A sophisticated sub-fund is a sub-fund using, for an important part,derivative financial instruments and/or making use of more complexstrategies or instruments.

- A non-sophisticated sub-fund is a sub-fund with less and lesscomplex positions on derivative financial instruments or withderivative financial instruments used solely for hedging purposes.

The risk profile of each sub-fund is mentioned in the sub-funds’factsheet. In the case where the Company wants to change the riskprofile of one or several sub-funds, this prospectus must be adaptedaccordingly.

Determination of the global exposure: non-sophisticated sub-funds

In the case of non-sophisticated sub-funds, the global exposure relatedsolely to positions on derivative financial instruments (including thoseembedded in transferable securities or money market instruments)must, in principle, be determined on the basis of the commitmentapproach.

On the basis of this approach, the positions on derivative financialinstruments must be converted into equivalent positions on theunderlying assets.

The sub-fund’s total commitment to derivative financial instruments,limited to 100% of the portfolio’s total net value, is then quantified as thesum, as an absolute value, of the individual commitments, afterconsideration of the possible effects of netting and coverage.




Determination of the global exposure: sophisticatedsub-funds

All sub-funds pursuing a sophisticated investment strategy are requiredto use an approach based on a model of the Value-at-Risk («VaR»)type, taking into consideration all the sources of global exposure, whichmight lead to a significant change in the portfolio’s value.

The purpose of a VaR model is the quantification of the maximumpotential loss which might be generated by the sub-fund in normalmarket conditions. This loss is estimated on the basis of a given timeperiod and a certain confidence interval as more described in therelevant sub-funds’ factsheets.




ING (L) Renta Fund Asian Debt

Introduction

This sub-fund was launched on 18 November 1996.

Investment objective and policy

This sub-fund aims to generate returns by actively managing a portfoliocomprised primarily (minimum 2/3) of bonds and money marketinstruments issued by Asian issuers (e.g. Singapore, Malaysia,Thailand, Indonesia, South Korea, Taiwan, the Philippines, India, HongKong and China) and denominated mainly in US dollars (minimum 2/3).Other countries in the same geographical area may be taken intoconsideration as long as their bond and money markets have reachedmaturity.

It is stipulated that any liquid assets held on an ancillary basis will notbe taken into account when calculating the above-mentioned limit of twothirds.

The sub-fund may also invest, on an ancillary basis, in othertransferable securities (including warrants on transferable securities upto 10% of the sub-fund’s net assets), money market instruments, Rule144 A securities, units of UCITS and other UCIs and deposits asdescribed in Chapter III “Investment restrictions”, section A “Eligibleinvestments” of Part III of the full prospectus. However, investments inUCITS and UCIs may not exceed a total of 10% of the net assets.Where the sub-fund invests in warrants on transferable securities,please note that the net asset value may fluctuate more than if the sub-fund were invested in the underlying assets because of the highervolatility of the value of the warrant.

With a view to achieving the investment objectives, the sub-fundmay also use derivative financial instruments including, but not limitedto, the following:

- options and futures on transferable securities or money marketinstruments

- futures and options on stock exchange indices

- futures, options and interest rate swaps

- performance swaps

- forward currency contracts and currency options.

This sub-fund is intended for well-informed investors seeking to investpart of their portfolio in growing Asian markets offering attractive long-term investment opportunities. However, these markets involve anabove-average degree of risk.

Securities lending and repurchase agreements(opérations à réméré)

The sub-fund may also engage in securities lending and repurchaseagreements.

Risk profile of the sub-fund

The market risk associated to the bonds used to reach investmentobjectives is considered as high. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in emerging market bondsare higher than investments in corporate issues located in developedmarket. The sub-fund’s liquidity risk is set to medium. Moreover, thecurrency exposure may impact the sub-fund’s performance. Noguarantee is provided as to the recovery of the initial investment. The

risk associated with the financial derivative instruments is detailed in thefull prospectus Part III, Chapter II: Risk linked to the investmentuniverse: detailed description.

The Company has classified this sub-fund as a non-sophisticated sub-fund.

Typical investor profile:

Eval® listing (based on P shares)

Risk Low High Minimum horizon

Euro 0 1 2 3 4 5 6 5 years

Fund currency 0 1 2 3 4 5 6 5 years

Fund type

Investments in fixed income instruments

Reference currency

American dollar (USD)

Manager of the sub-fund

ING Investment Management Asia Pacific (Hong Kong) Ltd



Class P - Capitalisation (USD)

Share class Class P

Type of shares Capitalisation

Form of shares – Bearer share without certificate (book entry)

Fraction of shares Up to three decimal places (only for shares issued in book entry form)

Denomination 1, 5, 25 shares

Currency of the share class USD

Stock exchange listing Luxembourg Stock Exchange

Valuation day Each bank business day in Luxembourg

Subscription fee payable to the dis-tributor(s)

3% in Belgium, maximum 3% elsewhere

Cut-off time for receipt of subscription,redemption and conversion requests

Before 15:30 two bank business days prior to the applicable valuation day

Payment date of subsequent subscrip-tion, redemption and conversionrequests

Maximum five bank business days following the applicable valuation date

Management fee Maximum 1.00% per year

Subscription tax 0.05% per year

Historical performance Past performance is not an indication of future results.Past performances are calculated on the basis of the fiscal year.

Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-11.96

12.96

9.19

10.07

14.96

10.91

11.97

2.67

7.07

9.13

1.37

Class P - Distribution (USD)

Share class Class P

Type of shares Distribution



Denomination 1, 5 shares



Dividend payment (distribution sharesonly)

AnnuallyIn cash, in principle payable within 2 months following the ordinary general meeting







1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-15

-10

-5

0

5

10

15

%









Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-12.99

6.73

3.42

3.84

8.16

5.08

7.48

-0.18

4.13

3.60

-3.82

Class X - Capitalisation (USD)

Share class Class X


Form of shares Bearer share without certificate (book entry)


Denomination Share certificates will not be issued












1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-15

-10

-5

0

5

10

%







Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-12.40

12.40

8.64

9.52

14.39

10.34

11.42

2.18

6.60

8.64

0.88

Class I (reserved for institutional investors) - Capitalisation (USD)

Share class Class I (reserved for institutional investors)


Form of shares Registered share without certificate (book entry)





Initial subscription period When first subscriptions received.

Initial subscription price USD 5000

Minimum subscription amount Equivalent in USD of EUR 250,000; no minimum required for additional subscriptions


Maximum 2%





Management fee 0.72% per year


Historical performance Historical performance not available

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-15

-10

-5

0

5

10

15

%







ING (L) Renta Fund Corporate USD

Introduction

This sub-fund was launched on 4 May 1998.


This sub-fund aims to generate returns via the active assetmanagement of a portfolio of debt securities and money marketinstruments issued mainly by financial institutions and companies anddenominated primarily (minimum 2/3) in US dollars.







- performance swaps


Potential investors should note that the type of investments carried outin this sub-fund involve a relatively higher level of risk than investmentsin similar sub-funds investing in government bonds.




The market risk associated to the bonds used to reach investmentobjectives is considered as medium. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in corporate issues is higherthan investments in government issues from Euro zone. No guarantee isprovided as to the recovery of the initial investment. The risk associatedwith the financial derivative instruments is detailed in the full prospectusPart III, Chapter II: Risk linked to the investment universe: details.


Typical investor profile:



Euro 0 1 2 3 4 5 6 More than 5 years


Fund type


Reference currency



ING Asset Management B.V. until September 14, 2009

ING Investment Management Co. as of September 15, 2009




Share class Class P











Before 15:30 each bank business day in Luxembourg prior to the applicable valuation day






Year

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-0.21

12.01

4.03

11.58

6.62

0.30

0.40

5.80

3.06


Share class Class P








AnnuallyIn cash, in principle payable within 2 months following the ordinary general meeting







2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

15

%


%








Year

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-4.60

5.96

-1.35

5.82

2.00

-3.64

-2.28

0.40

-2.13


Share class Class X

















Year

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-0.46

11.74

3.62

11.17

6.35

0.07

0.19

5.56

2.85

2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

%


%

2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

15

%


%

















Maximum 2%





Management fee 0.36% par year








ING (L) Renta Fund Dollar

Introduction

The sub-fund was launched on 25 January 1989.


This sub-fund aims to generate returns via the active management of aportfolio of bonds and money market instruments by investing primarily(minimum 2/3) in bonds and money market instruments denominated inUS dollars.







- performance swaps







Typical investor profile



Euro 0 1 2 3 4 5 6 5 years


Fund type


Reference currency



ING Investment Management Belgium




Share class Class P

















Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

9.64

6.31

0.93

13.03

3.35

7.08

3.81

0.22

1.13

5.21

9.77


Share class Class P








AnnuallyIn cash, in principle payable within two months following the annual general meeting







1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 20080

5

10

15

%


%








Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

2.21

0.40

-3.94

7.12

-1.77

1.79

-0.37

-3.25

-1.67

1.07

5.92


Share class Class X
















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

%


%






Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

9.57

6.21

0.83

12.92

3.20

6.93

3.71

0.13

1.09

5.16

9.77









Initial subscription price The initial price of Class I - Capitalisation (USD) will be the net asset value per share of ClassP - Capitalisation (USD) applicable to the first subscription, multiplied by 20

Minimum subscription amount Equivalent in USD of EUR 250,000 (which may be spread over all SICAV's sub-funds at theinvestor's request); no minimum required for additional subscriptions


Maximum 2%








Class S - Capitalisation (USD)

Share class Class S







Initial subscription price The initial price of Class S - Capitalisation (USD) will be the net asset value per share of ClassP - Capitalisation (USD) applicable to the first subscription, multiplied by 20

Minimum subscription amount Equivalent in USD of EUR 1,000,000; no minimum required for additional subscriptions

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 20080

5

10

15

%


%






Maximum 2%













ING (L) Renta Fund Emerging MarketsDebt (Hard Currency)Introduction

The sub-fund was launched following a contribution of assets of the INGInternational (II) Emerging Markets Debt (Hard Currency) sub-fund(launched on 12 February 1993) with effect on 28 March 2003.


The aim of this sub-fund is to make diversified investments, mainly(minimum 2/3 of the portfolio) in transferable securities and fixed incomemoney market instruments issued by public or private issuers in low ormiddle-income developing countries. These countries are often referredto as the "emerging markets". The majority of investments are to becarried out in South and Central America (including the Caribbean),Central Europe, Eastern Europe, Asia, Africa and the Middle East. Morespecifically, investments will be made in countries where the manager isable to assess the specific political and economic risks and in countriesthat have undertaken certain economic reforms and which have reachedcertain growth objectives. It is stipulated that any liquid assets held onan ancillary basis will not be taken into account when calculating theabove-mentioned limit of two thirds.

Transferable securities, issued by the public and/or private sector,primarily include fixed rate bonds, floating rate bonds, bonds withwarrants and convertible bonds, bonds resulting from the restructuringof syndicated loans or bank loans (e.g. "Brady" bonds) andsubordinated bonds. The term “money market instruments” mainly, butnot exclusively, includes investments in deposits, commercial papers,short-term bonds, treasury certificates and securitised bonds. This list isnot exhaustive.

The sub-fund will not invest in Russian shares, bonds or money marketinstruments whose settlement/delivery can only be carried out via aRussian system. However, the sub-fund may invest in Russian bondsand money market instruments whose settlement/delivery can becarried out via Clearstream or Euroclear.

Investments shall only be made in the currencies of OECD membercountries. However, the manager shall, in principle, hedge the currencyrisk inherent in these investments in relation to the sub-fund's referencecurrency (the euro). This may be carried out by hedging the currencyrisk in relation to the euro of assets denominated in currencies otherthan the euro, through the use of the techniques and financialinstruments described in Part III, Chapter IV of the full prospectus.

"Hard Currency" refers to the sub-fund's investment currencies. Theassets in which the sub-fund invests are denominated in the currenciesof economically developed and politically stable countries which aremembers of the OECD.

The sub-fund may also invest, on an ancillary basis, in othertransferable securities (including warrants on transferable securities upto a maximum of 10% of the sub-fund’s net assets), money marketinstruments, Rule 144A transferable securities, units of UCITS and otherUCIs and deposits as described in Chapter III “Investment Restrictions”,A) “Eligible investments” of Part III of the full prospectus. However,investments in UCITS and UCIs may not exceed a total of 10% of thenet assets. Where the sub-fund invests in warrants on transferablesecurities, note that the net asset value may fluctuate more than if thesub-fund were invested in the underlying assets because of the highervolatility of the value of the warrant.

As these investments are subject to specific factors, they cannot becompared to investments made in the major industrialised countries. Inthe past, some developing countries have suspended or halted thepayment of their external debt, including both the interest and thecapital, with respect to issuers from the public and private sectors.

These factors may also result in the positions held by the sub-fundbecoming less liquid, or even illiquid.

Only investors capable of assessing the risks should consider investingin this sub-fund.


The market risk associated to the bonds used to reach investmentobjectives is considered as high. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in emerging market bondsis higher than investments in corporate issues located in developedmarket. The sub-fund’s liquidity risk is set to medium. Moreover, thecurrency exposure may impact highly the sub-fund’s performance.Investments in specific theme area are more concentrated thaninvestments in various themes. No guarantee is provided as to therecovery of the initial investment. The risk associated with the financialderivative instruments is detailed in the full prospectus Part III, ChapterII: Risk linked to the investment universe: details.

The Company has classified this sub-fund as a sophisticated sub-fund.




Euro 0 1 2 3 4 5 6 5 years


Fund type


Reference currency

Euro (EUR)


ING Asset Management B.V.



Class P - Capitalisation (EUR)

Share class Class P





Currency of the share class EUR




3% in Belgium, maximum 3% elswhere








Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

13.05

-25.07

38.01

3.03

18.88

12.10

26.81

7.02

17.28

7.82

-2.04

Class P - Distribution (EUR)

Share class Class P















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-30-20-10

010203040

%


%

ING (L) Renta Fund Emerging Markets Debt (Hard Currency)







Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

4.53

-31.60

22.90

-4.17

13.14

4.82

18.81

1.49

12.72

2.16

-7.01

Class X - Capitalisation (EUR)

Share class Class X
















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-40

-30

-20

-10

0

10

20

%


%






Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

12.71

-25.30

37.61

2.72

19.33

11.01

26.44

6.69

16.96

7.52

-2.30

Class I (reserved for institutional investors) - Capitalisation (EUR)








Minimum subscription amount EUR 250,000 (which may be spread over all SICAV's sub-funds at the investor's request); nominimum required for additional subscriptions


Maximum 2%








Year

2006

2007

2008

%

18.08

8.53

-1.37

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-30-20-10

010203040

%


%

2006 2007 2008-5

0

5

10

15

20

%

Class I - Capitalisation (EUR)

%





Class I (reserved for institutional investors) - Distribution (EUR)










Minimum subscription amount EUR 250,000 (which may be spread over all SICAV's sub-funds at the investor's request); nominimum required for additional subscription


Maximum 2%








Year

2008

%

-2.62

Class S - Capitalisation (EUR)

Share class Class S







Initial subscription price The initial price of Class S - Capitalisation (EUR) will be the net asset value per share of ClassI - Capitalisation (EUR) applicable to the first subscription

Minimum subscription amount EUR 1,000,000 ; no minimum required for additional subscription


Maximum 2%



2008-3

-2

-1

0

1

2

3

%

Class I - Distribution (EUR)

%






ING (L) Renta Fund Emerging MarketsDebt (Local Currency)Introduction

This sub-fund was launched following a contribution of the assets of theING International Emerging Markets Debt (Local Currency) sub-fund(launched on 6 October 2000) of the ING International SICAV, witheffect from 26 November 2001.


The aim of this sub-fund is to make diversified investments in fixedincome transferable securities, money market instruments, derivativesand deposits , mainly denominated in or having exposure (minimum 2/3)to the currencies of low or middle-income developing countries("emerging markets") in Latin America, Asia, Central Europe, EasternEurope and Africa.

The sub-fund may be exposed to various exchange rate risks linked toinvestments in securities denominated in currencies other than that ofthe sub-fund or in derivative instruments with underlying exchange ratesor currencies.

Furthermore, a maximum of 1/3 of the net assets of the sub-fund maybe invested in fixed income transferable securities, money marketinstruments, derivatives and deposits denominated in or having anexposure to hard currencies (e.g. Euro, US dollar).


The sub-fund may invest directly, up to 25% of its net assets, insecurities traded on the Russian markets – the “Russian TradingSystem Stock Exchange” (RTS Stock Exchange) and the “MoscowInterbank Currency Exchange” (MICEX) as well as indirectly in Russiansecurities and Eurobonds traded on Regulated Markets as defined inthe Part III, Chapter III of the full prospectus.

The term "fixed income transferable securities" mainly, but notexclusively, includes fixed interest bonds, variable interest bonds, bondswith warrants, convertible bonds and subordinated bonds. The term“money market instruments” mainly, but not exclusively, includescommercial papers, short-term bonds, treasury certificates andsecuritised bonds. Furthermore, the fund may invest in structuredproducts, i.e. transferable securities as defined in Article 41 (1) of theLaw of 20 December 2002, in order to access certain specific marketsand to overcome problems linked to taxation and custody which arisewhen investing in the markets of developing countries.

The fund may hold cash and similar assets on an ancillary basis.

The sub-fund may also invest, on an ancillary basis, in othertransferable securities (including warrants on transferable securities upto a maximum of 10% of the sub-fund’s net assets), , asset backsecurities up to a maximum of 20% of the sub-fund’s nets assets, Rule144A transferable securities, units of UCITS and other UCIs anddeposits as described in Chapter III “Investment Restrictions”, A)“Eligible investments” of Part III of the full prospectus. However,investments in UCITS and UCIs may not exceed a total of 10% of thenet assets. Where the sub-fund invests in warrants on transferablesecurities, note that the net asset value may fluctuate more than if thesub-fund were invested in the underlying assets because of the highervolatility of the value of the warrant.

The sub-fund may have recourse to financial derivative instruments forhedging purposes, for efficient portfolio management and/or as part ofthe investment strategy of the sub-fund. The sub-fund may thereforeinvest in all derivative financial instruments authorised by Luxembourglaw, including (not exclusively):

- Derivative financial instruments linked to market fluctuations such ascall and put options, swaps and securities futures contracts, indices,baskets of securities or any other financial instruments, and TotalReturn Swaps that are derivative financial instruments linked to aswap agreement in which one party makes payments based on aset rate, either fixed or variable, while the other party makespayments based on the return of an underlying asset, whichincludes both the income it generates and any capital gains.

- Derivative financial instruments linked to exchange rate or currencyfluctuations of all types, such as currency futures contracts orcurrency call and put options, currency swaps, currency futurestransactions and false risk cover through which the sub-fund carriesout a cover transaction in its reference currency (index or referencecurrency) against exposure in a single currency by selling or buyinganother currency closely linked to its reference currency.

- Derivative financial instruments linked to interest rate risks, such ascall and put options on interest rates, interest rate swaps, future rateagreements, interest rate futures transactions, swaptions whereby acounterparty receives a fee in exchange for processing a futureswap at a rate previously agreed should a certain contingent eventarise, for example where future rates are set according to areference index, caps and floors and for which the seller, inexchange for a premium paid in advance agrees to compensate thebuyer if interest rates go above or below a strike price at certain pre-defined dates during the lifetime of the agreement.

Investments in emerging markets are subject to specific factors, theycannot be compared to investments made in the major industrialisedcountries. In the past, some developing countries have suspended orhalted the payment of their external debt, including both the interest andthe capital, with respect to issuers from the public and private sectors.






The market risk associated to the bonds used to reach investmentobjectives is considered as high. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in emerging market bondsis higher than investments in corporate issues located in developedmarket. The sub-fund’s liquidity risk is set to medium. Moreover, thecurrency exposure may impact highly the sub-fund’s performance.Investments in specific theme area are more concentrated thaninvestments in various themes. No guarantee is provided as to therecovery of the initial investment. The risk associated with the financialderivative instruments is detailed in the full prospectus Part III, ChapterII: Risk linked to the investment universe: details.








Euro 0 1 2 3 4 5 6 4 years


Fund type


Reference currency







Share class Class P

















Year

2002

2003

2004

2005

2006

2007

2008

%

12.24

12.06

17.38

11.50

6.75

9.55

16.70


Share class Class P















2002 2003 2004 2005 2006 2007 20080

5

10

15

20

%


%

ING (L) Renta Fund Emerging Markets Debt (Local Currency)







Year

2005

2006

2007

2008

%

11.51

6.57

4.70

10.36


Share class Class X

















Year

2002

2003

2004

2005

2006

2007

2008

%

11.83

11.49

16.81

10.95

6.21

9.02

16.17

2005 2006 2007 20080

5

10

15

%


%

2002 2003 2004 2005 2006 2007 20080

5

10

15

20

%


%













Minimum subscription amount Equivalent in USD of EUR 250,000 (which may be spread over all Company sub-funds at theinvestor's request); no minimum required for additional subscriptions


Maximum 2%








Year

2006

2007

2008

%

7.20

10.01

17.25

Class I (reserved for institutional investors) - Distribution (USD)










Initial subscription price The initial price of Class I - Distribution (USD) will be the net asset value per share of Class I -Capitalisation (USD) applicable to the first subscription

Minimum subscription amount Equivalent in USD of EUR 250,000 (which may be spread over all Company sub-funds at theinvestor's request); no minimum required for additional subscriptions


Maximum 2%



2006 2007 20080

5

10

15

20

%

Class I - Capitalisation (USD)

%










Year

2008

%

15.56

Class P hedged - Capitalisation (EUR)

Share class Class P hedged







Initial subscription period Upon decision of the Board of Directors

Initial subscription price EUR 250Subscriptions can only be in amount of money









Additional information The costs and expenses incurred in connection with any currency transactions enteredinto the hedge currency exchange risks associated with hedged share class, will be borneexclusively by the hedged share class.


20080

5

10

15

20

%

Class I - Distribution (USD)

%





Class I hedged - Capitalisation (EUR)

Share class Class I hedged







Initial subscription period Upon decision of the Board of Directors


Minimum subscription amount EUR 250,000 (which may be spread over all Company sub-funds at the investor's request); nominimum required for additional subscriptions


Maximum 2%







Additional information The costs and expenses incurred in connection with any currency transactions enteredinto the hedge currency exchange risks associated with hedged share class, will be borneexclusively by the hedged share class



Share class Class S







Initial subscription price The initial price of Class S - Capitalisation (USD) will be the net asset value per share of ClassI - Capitalisation (USD) applicable to the first subscription



Maximum 2%












ING (L) Renta Fund Emerging MarketsDebt (Local Bond)Introduction

The sub-fund will be launched upon decision of the board of directors.


The aim of this sub-fund is to invest in a diversified portfolio (minimum2/3) of fixed income securities, money market instruments, derivativesand deposits, with strategic emphasis on emerging market interest rateduration exposure and/or emerging market currency risk exposure.Fixed income securities and money market instruments will be mainlyissued by and/or denominated or having exposure in the currencies ofdeveloping countries (“emerging markets”) in Latin America, Asia,Central Europe, Eastern Europe and Africa.

The sub-fund may be exposed to various exchange rate risks linked toinvestments in securities denominated in currencies other than that ofthe sub-fund or in derivative instruments with underlying exchange ratesor currencies.


Furthermore, a maximum of 1/3 of the net assets of the sub-fund maybe invested in fixed income transferable securities, derivatives andmoney market instruments issued by other countries, including OECDmember states. These investments will be denominated and haveexposure to hard currencies (e.g. Euro, US dollar).

The sub-fund may invest directly, up to 25% of its net assets, insecurities traded on the Russian markets – the “Russian TradingSystem Stock Exchange” (RTS Stock Exchange) and the “MoscowInterbank Currency Exchange” (MICEX) as well as indirectly in Russiansecurities and Eurobonds traded on Regulated Markets as defined inthe Part III, Chapter III of the full prospectus.

Furthermore, the fund may invest in structured products, i.e. transferablesecurities as defined in Article 41 (1) of the Law of 20 December 2002,in order to access certain specific markets and to overcome problemslinked to taxation and custody which arise when investing in the marketsof developing countries.

The sub-fund may also invest, on an ancillary basis, in othertransferable securities (including warrants on transferable securities upto a maximum of 10% of the sub-fund’s net assets) and asset-backsecurities up to a maximum of 20% of the sub-fund’s net assets, Rule144A transferable securities, units of UCITS and other UCIs anddeposits as described in Chapter III “Investment Restrictions” of Part IIIof the full prospectus. However, investments in UCITS and UCIs maynot exceed a total of 10% of the net assets. Where the sub-fund investsin warrants on transferable securities, note that the net asset value mayfluctuate more than if the sub-fund were invested in the underlyingassets because of the higher volatility of the value of the warrant.

The sub-fund may have recourse to financial derivative instruments forhedging purposes, for efficient portfolio management and/or as part ofthe investment strategy of the sub-fund. The sub-fund may thereforeinvest in all derivative financial instruments authorised by Luxembourglaw, including (not exclusively):

- Derivative financial instruments linked to market fluctuations such ascall and put options, swaps and securities futures contracts, indices,baskets of securities or any other financial instruments, and TotalReturn Swaps that are derivative financial instruments linked to aswap agreement in which one party makes payments based on a

set rate, either fixed or variable, while the other party makespayments based on the return of an underlying asset, whichincludes both the income it generates and any capital gains.

- Derivative financial instruments linked to exchange rate or currencyfluctuations of all types, such as currency futures contracts orcurrency call and put options, currency swaps, currency futurestransactions and false risk cover through which the sub-fund carriesout a cover transaction in its reference currency (index or referencecurrency) against exposure in a single currency by selling or buyinganother currency closely linked to its reference currency.

- Derivative financial instruments linked to interest rate risks, such ascall and put options on interest rates, interest rate swaps, future rateagreements, interest rate futures transactions, swaptions whereby acounterparty receives a fee in exchange for processing a futureswap at a rate previously agreed should a certain contingent eventarise, for example where future rates are set according to areference index, caps and floors and for which the seller, inexchange for a premium paid in advance agrees to compensate thebuyer if interest rates go above or below a strike price at certain pre-defined dates during the lifetime of the agreement.




The market risk associated with the bonds used to reach investmentobjectives is considered high. These instruments are impacted byvarious factors, including, but not limited to, the development of thefinancial market, the economic development of issuers who arethemselves affected by the general world economic situation and theeconomic and political conditions prevailing in each country. Theexpected credit risk of underlying investments in emerging marketsbonds is higher than that of investments in corporate issues located indeveloped markets. The sub-fund’s liquidity risk is set to medium.Moreover, currency exposure may impact highly the sub-fund’sperformance. Investments in specific theme are more concentrated thaninvestments in various themes. No guarantee is provided as to therecovery of the initial investment. The risk associated with financialderivative instruments is detailed in the complete prospectus Part III,Chapter II: “Risks linked to the investment universe”.





Euro 0 1 2 3 4 5 6 2 years


Fund type


Reference currency





Share class Class P







Initial subscription period Upon decision of the board of directors












Share class Class P








AnnuallyIn cash, in principle payable within two months following the ordinary general meeting












ING (L) Renta Fund Emerging Markets Debt (Local Bond)





Share class Class X






























Maximum 2%












Class P hedged - Capitalisation (EUR)

Share class Class P hedged







Initial subscription period Open for subscription as from March 23, 2009










Additional information The costs and expenses incurred in connection with any currency transactions enteredinto the hedge currency exchange risks associated with hedged share class, will be borneexclusively by the hedged share class.


Class I hedged - Capitalisation (EUR)

Share class Class I hedged







Initial subscription period Open for subscription as from March 23, 2009

Initial subscription price EUR 5000Subscriptions can only be in amount of money.

Minimum subscription amount EUR 250,000; no minimum required for additional subscriptions


Maximum 2%











Additional information The costs and expenses incurred in connection with any currency transactions enteredinto the hedge currency exchange risks associated with hedged share class, will be borneexclusively by the hedged share class



Share class Class S











Maximum 2% per year













ING (L) Renta Fund Euro

Introduction

Initially launched on 10 March 1997, the sub-fund merged with the"EMU Bond" and "EMU Money" sub-funds of the ING InternationalSICAV (launched on 4 January 1999 and 2 October 2000 respectively)on 19 November 2001.


This sub-fund aims to generate returns via the active management of aportfolio of bonds and money market instruments by investing primarily(minimum 2/3) in bonds and money market instruments denominated ineuro.


The sub-fund may also invest, on an ancillary basis, in othertransferable securities (including warrants on transferable securities upto 10% of the sub-fund’s net assets), money market instruments, Rule144 A securities, units of UCITS and other UCIs and deposits asdescribed in Chapter III “Investment restrictions”, section A “Eligibleinvestments” of Part III of the full prospectus. However, investments inUCITS and UCIs may not exceed a total of 10% of the net assets.Where the sub-fund invests in warrants on transferable securities, notethat the net asset value may fluctuate more than if the sub-fund wereinvested in the underlying assets because of the higher volatility of thevalue of the warrant.





- performance swaps










Euro 0 1 2 3 4 5 6 4 years


Fund type


Reference currency

Euro (EUR)






Share class Class P

















Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

4.48

9.22

-1.95

6.71

2.63

9.35

4.77

4.34

1.21

0.99

0.45


Share class Class P















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

%


%








Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

4.48

3.65

-6.20

1.60

-2.29

4.18

1.05

1.23

-1.06

-2.20

-2.81


Share class Class X
















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-10

-5

0

5

10

%


%






Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

4.39

9.11

-2.04

6.61

2.48

9.20

4.66

4.24

1.15

0.93

0.38









Minimum subscription amount EUR 250,000 (which may be spread over all Company sub-funds at the investor's request); nominimum required for additional subscription


Maximum 2%








Year

2006

2007

2008

%

1.71

1.48

0.93

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

%


%

2006 2007 20080

1

2

%


%






Share class Class S










Maximum 2%








Class V - Capitalisation (EUR)

Share class Class V







Initial subscription period When first subscription received

Initial subscription price EUR 100


Maximum 2%













ING (L) Renta Fund Euro InflationLinkedIntroduction

This sub-fund was launched on 21 February 2005.


This sub-fund aims to generate returns via the active management of aportfolio of inflation-linked bonds and money market instrumentsdenominated in euro by investing primarily (minimum 2/3 of the netassets) in government bonds and money market instruments as well asbonds and money market instruments issued by the local publicauthorities of OECD countries, or by international public bodies to whichone or more EU Member States belong, or by companies and financialinstitutions established in one or more OECD Member States.

These are generally bonds and money market instruments which pay arate of interest, but whose nominal value adjusts according to the rate ofinflation encountered. These instruments therefore offer protectionagainst movements linked to inflation.

Bonds and money market instruments issued by governments, localpublic authorities of countries in the OECD or international public bodiesto which one or more EU Member States belong may represent over35% of the sub-fund's net assets.

The sub-fund may also invest, on an ancillary basis, in othertransferable securities (including warrants on transferable securities upto 10% of the sub-fund’s net assets), money market instruments, Rule144 A securities, units of UCITS and other UCIs and deposits asdescribed in Chapter 3 “Investment restrictions”, section A “Eligibleinvestments” of Part III of the full prospectus. However, investments inUCITS and UCIs may not exceed a total of 10% of the net assets.Where the sub-fund invests in warrants on transferable securities, notethat the net asset value may fluctuate more than if the sub-fund wereinvested in the underlying assets because of the higher volatility of thevalue of the warrant.





- performance swaps





The market risk associated to the bonds used to reach investmentobjectives is considered as medium. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in corporate issues is higherthan investments in government issues from Euro zone. No guarantee is

provided as to the recovery of the initial investment. The risk associatedwith the financial derivative instruments is detailed in the full prospectusPart III, Chapter II: Risk linked to the investment universe: details.





Euro 0 1 2 3 4 5 6 4 years


Fund type


Reference currency

Euro (EUR)






Share class Class P


Form of shares – Bearer share without certificate (book entry) – –














Year

2006

2007

2008

%

1.10

-0.29

4.79


Share class Class P


Form of shares – Bearer share without certificate (book entry) – –















2006 2007 2008-1

0

1

2

3

4

5

%


%

ING (L) Renta Fund Euro Inflation Linked





Year

2006

2007

2008

%

1.10

-1.40

3.40


Share class Class X


Form of shares Bearer share without certificate (book entry) –














Year

2007

2008

%

-0.32

4.76






2006 2007 2008-2

-1

0

1

2

3

4

%


%

2007 2008-1

0

1

2

3

4

5

%


%










Maximum 2%








Year

2006

2007

2008

%

1.69

0.23

5.35


Share class Class S










Maximum 2%








2006 2007 20080

1

2

3

4

5

6

%


%






ING (L) Renta Fund Euro Liquidity

Introduction

This sub-fund is launched on 15 November 2007.


The investment objective of this sub-fund is to achieve an attractivereturn in relation to the euro money market rate by investing in moneymarket instruments and deposits with credit institutions, as set outbelow. The recommended investment horizon is at least two months,with the intention of maintaining liquidity and protecting the capitalinvested. In order to achieve this objective, the sub-fund may invest in:

- all types of money market instruments, whether or not they areclassified as transferable securities, including floating rate notes,short-term bonds and money market instruments rated investmentgrade by S&P or Moody’s at the time of purchase, issued in euroand/or one or more other currencies and whose initial or residualmaturity does not exceed twelve months at the time of purchase,taking into account all the underlying financial instruments, or whoseinterest rate, by virtue of the issuing conditions governing thesesecurities, is subject to at least one adjustment per year dependingon the market conditions;

- deposits denominated in euro and/or in one or more othercurrencies, in accordance with the specifications stated in Part III ofthe full prospectus, Chapter III “Investment restrictions”, point A, 1,g;

- regulated asset backed securities (ABS) having a residual maturityof up to and including 397 days and asset backed commercialpapers (ABCP) up to a maximum of 20% of the net assets;

- UCITS and other Luxembourg UCIs investing in the assets listedabove (i.e. money market instruments and deposits), up to amaximum of 10% of the net assets;

- derivative financial instruments, in order to efficiently managecurrency risk as well as interest rate risk and the fluctuation of thisrisk on the yield curve.

This sub-fund may also hold cash on an ancillary basis.

Shareholders’ attention is drawn to the risks linked to these investmentsand, more particularly, the risks linked to investments in bonds, moneymarket instruments, deposits, UCITS and other UCIs, derivatives andcash. A description of the risks incurred is set out in Part III, Chapter II“Risks linked to the investment universe: detailed description” of the fullprospectus.

This sub-fund is intended for investors seeking an investment with a lowrisk profile. However, the “marked to market” valuation of the sub-fundmeans that the net asset value will fluctuate in line with the movementsof the money market curve and any changes in issuers’ credit quality.There is therefore no capital guarantee and investors may notnecessarily recover the amount initially invested.


The market risk associated to the money market instruments used toreach investment objectives is considered as low. Those instrumentsare impacted by various factors, of which, without being exhaustive, thedevelopment of the financial market, as well as the economicdevelopment of issuers who are themselves affected by the generalworld economic situation, as well as economic and political conditionsprevailing in each country. The sub-fund’s liquidity risk is set to medium.No guarantee is provided as to the recovery of the initial investment.The risk associated with the financial derivative instruments is detailedin the full prospectus Part III, Chapter II: Risk linked to the investmentuniverse: details.


Typical Investor Profile



Euro 0 1 2 3 4 5 6 1 year

Fund currency 0 1 2 3 4 5 6 1 year

Fund type

Investments in money market instruments

Reference currency

Euro (EUR)






Share class Class P







Initial subscription period 15/11/2007 – 21/11/2007


Payment date of the initial subscription 23/11/2007











Share class Class P









Initial subscription period when first subscription received

Initial subscription price The initial price of Class P - Distribution (EUR) will be the net asset value per share of Class P- Capitalisation (EUR) multiplied by 4, applicable to the first subscription















Share class Class X








Initial subscription price The initial price of Class X - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR), applicable to the first subscription



















Initial subscription price The initial price of Class I - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) multiplied by 20, applicable to the first subscription

Minimum subscription amount EUR 2,500,000; no minimum required for additional subscription


Maximum 2%













Share class Class S












Maximum 2%













ING (L) Renta Fund Euro Long Duration

Introduction

The sub-fund has been launched on 15 August 2007.


This sub-fund aims to generate returns by actively managing a portfolioinvested primarily (minimum 2/3) in long-duration debt securitiesdenominated in euro.


The sub-fund may also invest in other transferable securities (includingwarrants on transferable securities up to 10% of the sub-fund’s netassets), money market instruments, Rule 144 A securities and shares/units of UCITS and other UCIs as described in Chapter III “Investmentrestrictions”, section A “Eligible investments” of Part III of the fullprospectus. However, investments in UCITS and UCIs may not exceeda total of 10% of the net assets. Where the sub-fund invests in warrantson transferable securities, note that the net asset value may fluctuatemore than if the sub-fund were invested in the underlying assetsbecause of the higher volatility of the value of the warrant.





- performance swaps










Euro 0 1 2 3 4 5 6 2 years


Fund type


Reference currency

Euro (EUR)






Share class Class P




















Share class Class P


























Share class Class X
































Maximum 2%













Share class Class S












Maximum 2%













ING (L) Renta Fund Eurocredit

Introduction

The sub-fund has been launched on 26 November 2001.


This sub-fund aims to generate returns via the active management of aportfolio of bonds and money market instruments issued mainly byfinancial institutions and companies by investing a minimum of 2/3 inbonds and money market instruments denominated in euro.

When selecting investments, and on the basis of assessments carriedout by the ING Group, the portfolio manager shall analyse, maintain andupdate the credit rating of future investments and shall ensure that animplicit average percentage of the portfolio is invested in A-rated bonds.The manager will always take the quality and diversity of issuers andsectors, along with the maturity date, into consideration.







- performance swaps


Potential investors should note that the type of investments carried outin this sub-fund involve a relatively higher level of risk than investmentsin similar sub-funds investing in government bonds and money-marketinstruments.




The market risk associated to the bonds used to reach investmentobjectives is considered as medium. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in corporate issues is higherthan investments in government issues from Euro zone. No guarantee is

provided as to the recovery of the initial investment. The risk associatedwith the financial derivative instruments is detailed in the full prospectusPart III, Chapter II: Risk linked to the investment universe: details.






Fund currency 0 1 2 3 4 5 6 More than 5 years

Fund type


Reference currency

Euro (EUR)






Share class Class P




Denomination 1, 5, 10, 25, 100 shares













Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

17.78

8.24

-2.16

6.55

3.19

8.55

6.99

4.70

0.73

1.36

-5.41


Share class Class P




Denomination 1, 5, 10, 100 shares











1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-10

-5

0

5

10

15

20

%


%








Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

9.36

3.11

-6.86

1.87

-1.13

3.29

3.14

1.32

-1.50

-2.81

-9.15


Share class Class X

















Year

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-2.40

6.47

2.90

8.15

6.74

4.44

0.53

1.14

-5.59

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-10

-5

0

5

10

%


%

2000 2001 2002 2003 2004 2005 2006 2007 2008-10

-5

0

5

10

%


%















Maximum 2%








Year

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-2.16

6.62

3.81

8.98

7.63

5.27

1.38

1.95

-4.83











Maximum 2%





2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

%

Class I - Capitaliation (EUR)

%








Year

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-2.16

6.62

0.25

3.78

3.15

1.24

-1.48

-2.89

-9.12


Share class Class S







Initial subscription price The initial price of Class S - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) applicable to the initial subscription, multiplied by 20



Maximum 2%









Share class Class V









2000 2001 2002 2003 2004 2005 2006 2007 2008-10

-5

0

5

10

%

Class I - Distribution (EUR)

%






Maximum 2%













ING (L) Renta Fund Euromix Bond

Introduction

This sub-fund was launched following a contribution of the assets of theING International Euromix Bond sub-fund (launched on 4 January 1999)of the ING International SICAV, with effect from 19 November 2001.


This sub-fund aims to generate returns via the active management of aportfolio of bonds and money market instruments by investing primarily(minimum 2/3) in bonds and money market instruments issued byissuers established in European States and denominated in theircurrency or in euro. These countries include Member States of theEuropean Union (EU) as well as those considered European as regardstheir geographical location.







- performance swaps





The market risk associated to the bonds used to reach investmentobjectives is considered as medium. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in corporate issues is higherthan investments in government issues from Euro zone. Moreover, thecurrency exposure may impact the sub-fund’s performance. Noguarantee is provided as to the recovery of the initial investment. Therisk associated with the financial derivative instruments is detailed in thefull prospectus Part III, Chapter II: Risk linked to the investmentuniverse: details.





Euro 0 1 2 3 4 5 6 4 years


Fund type


Reference currency

Euro (EUR)






Share class Class P

















Year

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

0.14

7.35

2.90

9.47

3.81

4.85

1.42

1.08

1.03


Share class Class P















2000 2001 2002 2003 2004 2005 2006 2007 20080

2

4

6

8

10

12

%


%








Year

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-7.36

3.41

-0.62

4.99

0.11

1.87

-1.16

-2.51

-3.05


Share class Class X


Form of shares Bearer share without certificate (book entry) –















Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

13.67

6.38

-0.44

7.31

2.80

9.34

3.70

4.76

1.37

1.01

0.98

2000 2001 2002 2003 2004 2005 2006 2007 2008-10

-5

0

5

10

%


%

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

15

%


%













Initial subscription price The initial price of Class I - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) applicable to first subscription, multiplied by 20



Maximum 2%









Share class Class S







Initial subscription price The initial price of Class S - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) applicable to first subscription, multiplied by 20



Maximum 2%













ING (L) Renta Fund Global High Yield

Introduction

The sub-fund was launched on 23 April 2001.


This sub-fund shall invest primarily (minimum 2/3) in high yield bondsissued anywhere in the world. These bonds are different from traditional“Investment Grade” bonds in that they are issued by companiespresenting a risk in terms of their ability to fully honour theircommitments, which explains why they offer a higher return.







- performance swaps


Note: ratings are awarded by reputable credit rating agencies to fixedincome instruments that can be traded on the markets. These ratingsgive a fair idea of the credit risk associated with the issuing entities: thelower the rating, the higher the credit risk. To compensate for this risk,however, a company with such a rating will offer high-yield bonds.Ratings awarded by ratings agencies range from AAA (almost no risk)to CCC (very high risk of defaulting). The rating varies from BB+ to CCCfor the high yield markets. With this in mind, this sub-fund is intended forwell-informed investors who are aware of the degree of risk linked totheir chosen investments.




The market risk associated to the bonds used to reach investmentobjectives is considered as high. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in high yield bonds is higherthan investments in corporate issues located in developed market. The

sub-fund’s liquidity risk is set to medium. Investments in specific themeare more concentrated than investments in various themes. Noguarantee is provided as to the recovery of the initial investment. Therisk associated with the financial derivative instruments is detailed in thecomplete prospectus Part III, Chapter II: Risk linked to the investmentuniverse: detailed description.






Fund currency 0 1 2 3 4 5 6 More than 5 years

Fund type


Reference currency

Euro (EUR)






Share class Class P

















Year

2003

2004

2005

2006

2007

2008

%

3.22

16.42

5.99

6.06

7.70

-10.22


Share class Class P








AnnuallyIn cash in principle payable within two months following the ordinary general meeting









2003 2004 2005 2006 2007 2008-15-10-505

101520

%







Year

2003

2004

2005

2006

2007

2008

%

-1.89

11.27

1.86

3.62

1.05

-15.43


Share class Class X

















Year

2003

2004

2005

2006

2007

2008

%

2.92

16.07

5.67

5.80

7.43

-10.44

2003 2004 2005 2006 2007 2008-20-15-10-505

1015

%


%

2003 2004 2005 2006 2007 2008-15-10-505

101520

%


%





Class X - Distribution (EUR)

Share class Class X


Form of shares Bearer share with certificate




Valuation day Each bank business day in Luxembourg ;First valuation day: after the first subscription is received.


Monthly.In principle, dividends are payable in July. The Board of Directors can decide interin dividendto be paid on a monthly basis.

Initial subscription period No initial period.

Initial subscription price 1000 EUR

Payment date of the initial subscription Maximum five bank business days following the applicable valuation date.


5% in Belgium, maximum 5% elsewhere.



Management fee Maximum 1,50%

Historical performance

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

%

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

Index

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00

0.00









Initial subscription price The initial price of Class I - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) applicable to the first subscription



Maximum 2%



1997 1998 1999 2000 2001 2002 2003 2004 2005 20060

5

10

15

20

25

%










Year

2008

%

-9.60











Initial subscription price The initial price of Class I - Distribution (EUR) will be the net asset value per share of Class I -Capitalisation (EUR) applicable to the first subscription



Maximum 2%









Share class Class S




2008-10

-5

0

5

%


%








Initial subscription price The initial price of Class S - Capitalisation (EUR) will be the net asset value per share of ClassI - Capitalisation (EUR) applicable to first subscription



Maximum 2%













ING (L) Renta Fund International

Introduction

The sub-fund was launched on 25 January 1989.


This sub-fund aims to generate returns through a diversification of itsinvestments in international bonds and money market instruments fromacross the globe, denominated in various currencies, yet clearly gearedtoward the eurozone, by investing primarily (minimum 2/3) in bonds andmoney market instruments.







- performance swaps





The market risk associated to the bonds used to reach investmentobjectives is considered as medium. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in corporate issues is higherthan investments in government issues from Euro zone. Moreover, thecurrency exposure may impact highly the sub-fund’s performance. Noguarantee is provided as to the recovery of the initial investment. Therisk associated with the financial derivative instruments is detailed in thefull prospectus Part III, Chapter II: Risk linked to the investmentuniverse: detailed description.





Euro 0 1 2 3 4 5 6 4 years


Fund type


Reference currency

Euro (EUR)






Share class Class P

















Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

14.88

6.08

7.30

5.79

3.22

1.11

1.44

1.44

3.36

-1.40

-0.99


Share class Class P















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

15

%


%








Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

7.62

0.37

2.43

0.85

-1.64

-3.69

-1.78

-1.20

1.01

-5.28

-4.40


Share class Class X
















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-10

-5

0

5

10

%


%






Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

14.79

5.97

7.19

5.69

3.05

0.97

1.33

1.33

3.32

-1.44

-1.03









Initial subscription price The initial price of Class I - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) applicable to first subscription, muliplied by 20



Maximum 2%









Share class Class S







Initial subscription price The inital price of Class S - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) applicable to first subscription, multiplied by 20


1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

15

%


%






Maximum 2%













ING (L) Renta Fund Sustainable FixedIncomeIntroduction

This sub-fund has been launched on 23 May 2007.


This sub-fund aims to generate returns by actively managing a portfolioof debt securities and money market instruments. It will invest primarily(minimum 2/3) in euro-denominated debt securities and money marketinstruments from issuers (considered to be investment grade) pursuingpolicies of sustainable development that combine the observance ofsocial and environmental principles with sound financial performance.


The sub-fund may also invest in other transferable securities (includingwarrants on transferable securities up to 10% of the sub-fund’s netassets), Rule 144 A securities and shares/units of UCITS and otherUCIs as described in Chapter III “Investment restrictions”, section A“Eligible investments” of Part III of the full prospectus. However,investments in UCITS and UCIs may not exceed a total of 10% of thenet assets. Where the sub-fund invests in warrants on transferablesecurities, note that the net asset value may fluctuate more than if thesub-fund were invested in the underlying assets because of the highervolatility of the value of the warrant.





- performance swaps





The market risk associated to the bonds used to reach investmentobjectives is considered as medium. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in corporate issues is higherthan investments in government issues from Euro zone. No guarantee isprovided as to the recovery of the initial investment. The risk associatedwith the financial derivative instruments is detailed in the full prospectusPart III, Chapter II: Risk linked to the investment universe: detaileddescription.





Euro 0 1 2 3 4 5 6 1 years


Fund type


Reference currency

Euro (EUR)






Share class Class P




















Share class Class P





















ING (L) Renta Fund Sustainable Fixed Income





Share class Class X




























Initial subscription price EUR 5,000




Maximum 2%













Share class Class S












Maximum 2%













ING (L) Renta Fund World

Introduction

The sub-fund has been launched on 25 January 1989.


This sub-fund aims to generate returns through a diversification of itsinvestments in international bonds and money market instruments fromacross the globe, denominated in various currencies. The aim is to offersignificant monetary diversification at an international level.






- performance swaps


This sub-fund may invest directly or indirectly in transferable securitiesor instruments issued by low or middle-income developing countries,known as the "emerging markets".

As these investments are subject to specific factors, they cannot becompared to investments made in the major industrialised countries. Inthe past, some developing countries have suspended or halted thepayment of their external debt, including both the interest and thecapital, with respect to issuers from the public and private sectors.






The market risk associated to the bonds used to reach investmentobjectives is considered as medium. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in corporate issues is higherthan investments in government issues from Euro zone. Moreover, thecurrency exposure may impact highly the sub-fund’s performance. No

guarantee is provided as to the recovery of the initial investment. Therisk associated with the financial derivative instruments is detailed in thefull prospectus Part III, Chapter II: Risk linked to the investmentuniverse: detailed description.





Euro 0 1 2 3 4 5 6 5 years


Fund type


Reference currency

Euro (EUR)






Share class Class P

















Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

15.74

5.65

3.76

6.70

2.06

-9.65

-1.46

-2.06

4.28

-2.31

-3.15


Share class Class P













1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-10

-5

0

5

10

15

%


%











Share class Class P








AnnuallyIn cash, in principle two months following the ordinary general meeting










Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

8.16

-0.29

-1.22

1.40

-3.01

-14.25

-4.15

-4.38

2.22

-4.83

-5.69


Share class Class P






1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-15

-10

-5

0

5

10

%


%







QuarterlyIn cash. Dividends will be calculated at the end of March, June, September and December.













Share class Class X

















Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

15.67

5.54

3.65

6.60

1.91

-10.10

-1.57

-2.15

4.21

-2.38

-3.21

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-15-10-505

101520

%


%













Initial subscription price The initial price of Class I - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) applicable to the first subscription, multiplied by 20



Maximum 2%









Share class Class S







Initial subscription price The initial price of Class S - Capitalisation (EUR) will be the net asset value per share of ClassP - Capitalisation (EUR) applicable to the first subscription, multiplied by 20



Maximum 2%













Share class Class V










Maximum 2%













ING (L) Renta Fund Yen

Introduction

The sub-fund has been launched on 25 January 1989.


This sub-fund aims to generate returns via the active management of aportfolio of bonds and money market instruments by investing primarily(minimum 2/3) in bonds and money market instruments denominated inJapanese yen.


The sub-fund may also invest, on an ancillary basis, in othertransferable securities (including warrants on transferable securities upto 10% of the sub-fund’s net assets), money market instruments, Rule144 A securities, units of UCITS and other UCIs and deposits asdescribed in Chapter 3 “Investment restrictions”, section A “Eligibleinvestments” of Part III of the full prospectus. However, investments inUCITS and UCIs may not exceed a total of 10% of the net assets.Where the sub-fund invests in warrants on transferable securities, notethat the net asset value may fluctuate more than if the sub-fund wereinvested in the underlying assets because of the higher volatility of thevalue of the warrant.





- performance swaps





The market risk associated to the bonds used to reach investmentobjectives is considered as medium. Those instruments are impacted byvarious factors, of which, without being exhaustive, the development ofthe financial market, as well as the economic development of issuerswho are themselves affected by the general world economic situation,as well as economic and political conditions prevailing in each country.Expected credit risk underlying investments in corporate issues is higherthan investments in government issues from Euro zone. No guarantee isprovided as to the recovery of the initial investment. The risk associatedwith the financial derivative instruments is detailed in the full prospectusPart III, Chapter II: Risk linked to the investment universe: detaileddescription.





Euro 0 1 2 3 4 5 6 5 years


Fund type


Reference currency

Japan Yen (JPY)





Class P - Capitalisation (JPY)

Share class Class P





Currency of the share class JPY



Minimum subscription amount 3% in Belgium, maximum 3% elsewhere








Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

3.00

-0.26

2.65

6.37

-0.12

2.12

-2.11

1.01

-1.71

0.51

1.65

Class P - Distribution (JPY)

Share class Class P















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-5

0

5

10

%

Class P - Capitalisation (JPY)

%








Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

-0.90

-3.25

-0.35

3.72

-2.03

0.73

-2.11

1.01

-1.72

0.44

1.29

Class X - Capitalisation (JPY)

Share class Class X
















1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-4

-2

0

2

4

%

Class P - Distribution (JPY)

%






Year

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

%

2.93

-0.36

2.54

6.27

-0.26

1.99

-2.20

0.91

-1.76

0.39

1.56

Class I (reserved for institutional investors) - Capitalisation (JPY)









Initial subscription price JPY 500,000

Minimum subscription amount Equivalent in JPY of EUR 250,000; no minimum required for additional subscriptions


Maximum 2%





Management fee 0.36% per year



1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008-4

-2

0

2

4

6

%

Class X - Capitalisation (JPY)

%






PART III: ADDITIONAL INFORMATIONI. The Company

The Company was set up on 25 January 1989 under the Law of 30March 1988 on undertakings for collective investment. The Articles ofAssociation (the “Articles”) of the Company were amended for the lasttime on 15 September 2005, in order to bring the Company intocompliance with the Law of 20 December 2002 on undertakings forcollective investment and the coordinated Articles were registered in theLuxembourg Trade and Companies Register, where they can beconsulted and where copies can be obtained against payment of therelevant fees.

The share capital of the Company will, at all times, be equal to the valueof the net assets of the sub-funds. It is represented by bearer orregistered shares, all fully paid up, without par value.

Share capital variations are fully legal and there are no provisionsrequiring publication and entry in the Trade and Companies Register asprescribed for increases and decreases in the share capital of publiclimited companies (sociétés anonymes).

The Company may issue additional shares at any time at a price set incompliance with the contents of Chapter VIII “Shares”, without anypreference right being reserved for existing shareholders.

The minimum capital is laid down in the Luxembourg Law of 20December 2002.

The consolidation currency of the Company is the euro.

II. Risks linked to the investment universe: detaileddescription

General remarks regarding risks

Investments in the Company’s shares are exposed to risks, which mayinclude or be linked to equity, bond, currency, interest rate, credit,volatility and political risks. Each of these risks may also occur inconjunction with other risks. Some of these risk factors are describedbriefly below. Potential investors must have experience in investing ininstruments used in the context of the investment policy described.

Investors must also be fully aware of the risks linked to investments inthe Company’s shares and ensure that they consult their legal, tax andfinancial adviser, auditor or other adviser in order to obtain completeinformation on (i) the appropriate nature of an investment in shares,depending on their personal financial and tax situation and on theirparticular circumstances, (ii) the information contained herein and (iii)the investment policy of the sub-fund (as described in the relevantfactsheet for each sub-fund), before making any investment decision.

Apart from potential stock exchange profit, it is important to note that aninvestment in the Company also involves the risk of incurring stockexchange losses. Company shares are securities whose value isdetermined on the basis of fluctuations in the price of the transferablesecurities held by the Company. The value of shares may therefore goup or down in relation to their initial value.

There is no guarantee that the aims of the investment policy will beachieved.

Market Risk

This is a general risk which affects all types of investment. Price trendsfor transferable securities are determined mainly by financial markettrends and by the economic development of the issuers, who are

themselves affected by the overall situation of the global economy andby the economic and political conditions prevailing in each relevantcountry (market risk).

Interest rate

Investors must be aware that an investment in the shares of theCompany may be exposed to interest rate risks. These risks occur whenthere are fluctuations in the interest rates of the main currencies of eachtransferable security or of the Company.

Currency risk

The value of investments may be affected by exchange rate fluctuationsin the sub-funds where investments are allowed in a currency other thanthe sub-fund’s reference currency.

Credit risk

Investors must be fully aware that any such investment may involvecredit risks. Bonds and debt securities effectively involve issuer creditrisk, which can be calculated using the issuer’s solvency rating. Bondsand debt securities issued by entities with a low rating are generallyconsidered to have higher credit risk and issuer default probability thanthose issued by issuers with a higher rating. If the issuer of bonds ordebt securities runs into financial or economic difficulty, the value of thebonds or debt securities (which may become null and void) and thepayments made on account of these bonds or debt securities (whichmay become null and void) may be affected.

Risk of issuer default

In parallel to the general trends prevailing on the financial markets,developments particular to each issuer can affect the value of aninvestment. Even a careful selection of transferable securities cannot,for example, eliminate the risk of losses caused by a decline in theassets of an issuer.

Liquidity risk

Liquidity risks arise when a particular security is difficult to sell. Inprinciple, only securities that can be sold at any time are added to afund. Similarly, some transferable securities may be difficult to sell at thedesired moment during particular periods or on particular segments ofthe stock exchange. Finally, there is a risk that securities traded in anarrow market segment are subject to high price volatility.

Risk of flexibility

Lack of flexibility of investment product and restrictions which may limitthe possibility to change the counterparts/providers. Difficulties may inparticular exist to find another counterparty with similar conditions forover-the-counter (OTC) derivatives.

Counterparty risk

When OTC contracts are entered into, the Company may find itselfexposed to risks arising from the solvency of its counterparts and fromtheir ability to respect the conditions of these contracts. The Companymay thus enter into futures, options and swap contracts, or use otherderivative techniques, each of which involves the risk that thecounterpart will fail to respect its commitments under the terms of eachcontract.




Risk arising from 144A securities

Rule 144A securities are not registered with the US Securities andExchange Commission (SEC) in accordance with the stipulations of theCode of Federal Regulations, Title 177, Par. 230, 144A.

These Rule 144A securities are considered as newly issued transferablesecurities (see Part III, Chapter III, Section A, point 1, letter e of theprospectus) and may only be purchased by qualified professionalinvestors.

Risk arising from investments in the emergingmarkets

Suspension of payments from the developing countries can be due tovarious factors, such as political instability, poor economic management,a lack of currency reserves, capital flight, internal conflicts or a lack ofpolitical willingness to continue servicing the previously contracted debt.

The capacity of private sector issuers to meet their obligations may alsobe affected by these factors. Moreover, these issuers are subject todecrees, laws and regulations enacted by government authorities.Examples include modification of exchange controls and amendmentsto the legal and regulatory system, expropriations and nationalisationsand the introduction of, or increase in, taxes, such as withholding tax.

Uncertainty with regard to an unclear legal environment or incapacity toestablish definitive and legal ownership rights are another determiningfactor. Added to this are the lack of reliable sources of information inthese countries, the non-compliance of accounting methods withinternational standards and the lack of financial or commercial controls.

Investors’ attention is drawn to the fact that, at present, investments inRussia are subject to increased risk as regards the ownership andcustody of transferable securities: market practice for the custody ofbonds is such that these bonds are deposited with Russian institutionsthat do not always have adequate insurance to cover the risk of lossarising from the theft, destruction or disappearance of instruments ondeposit.

Derivatives

The Company may use derivative financial instruments within theframework of the investment policy outlined in each sub-fund factsheet.In addition to being used for hedging purposes, these instruments mayalso form an integral part of the investment strategy in order to optimisereturns. Recourse to financial derivatives may be restricted by marketconditions and applicable regulations and may involve risks and costsfor the sub-fund to which it would not otherwise be exposed. Risksinherent in the use of options, foreign currency contracts, swaps, futurescontracts and options on these contracts include: a) the fact thatsuccess depends on the ability of the portfolio manager(s) to accuratelypredict trends in interest rates, prices of transferable securities and/ormoney market instruments and currency markets; (b) the imperfectcorrelation between the price of options and futures contracts andoptions on these contracts and movements in the prices of thesecurities, money market instruments or currencies being hedged; (c)the fact that the skills needed to use these instruments are different fromthose needed to select portfolio securities; (d) the possibility of a non-liquid secondary market for a particular instrument at a given time; and(e) the risk that a sub-fund may not be able to purchase or sell aportfolio security during a favourable period, or the risk that a sub-fundmay have to sell a portfolio security during an unfavourable period.When a sub-fund enters into a swap transaction, it is exposed tocounterpart risk. The use of derivative financial instruments alsoinvolves leverage risk. Leverage occurs when a modest capital sum isinvested in the purchase of derivatives in comparison with the cost ofdirectly acquiring the underlying assets. The higher the leverage, thegreater the variation in the price of the derivative in the event of afluctuation in the price of the underlying asset (in comparison with thesubscription price determined according to the conditions of thederivative). The potential and risks of derivatives thus increase in

parallel with an increase in the leverage effect. Finally, there is noguarantee that the objective sought through the use of these derivativefinancial instruments will be achieved.

Please refer to the factsheet of the relevant sub-fund for moreinformation on the risk(s) relating to investments in a particular sub-fund.

The above list shows the most commonly encountered risks and is notan exhaustive list of all potential risks.

III. Investment restrictions

In the interests of shareholders and in order to ensure a widediversification of the risks, the Company undertakes to comply with thefollowing rules:

A. Eligible investments

1. The Company may invest the assets of each sub-fund in:

a. transferable securities and money market instruments listed ortraded on a regulated market within the meaning of Article 1(13) of the Council Directive 93/22/EEC of 10 May 1993 oninvestment services in the securities field;

b. transferable securities and money market instruments traded onanother market of a Member State of the European Union (a“Member State”) which is regulated, operates regularly, isrecognised and open to the public;

c. transferable securities and money market instruments admittedto official listing on a stock exchange in a country which is not amember of the EU or traded on another market of a countrywhich is not a Member State and that is regulated, operatesregularly, is recognised and open to the public, insofar as thestock exchange or market is located in a member state of theOrganisation for Economic Cooperation and Development(OECD) or in any other country in Europe, North America,South America, Africa, Asia and Oceania;

d. newly issued transferable securities and money marketinstruments, provided that:

i. the issue conditions include an undertaking that anapplication will be made for official listing on a stockexchange or another regulated market that operatesregularly, is recognised and open to the public and providedthat it is located in a member state of the Organisation forEconomic Cooperation and Development (OECD) or in anyother country in Europe, North America, South America,Africa, Asia and Oceania;

ii. the listing is secured within one year of issue at the latest;

e. Rule 144A transferable securities, as described in the provisionsof the US Code of Federal Regulations, Title 17, Par 230, 144A,provided that:

i. the Rule 144A transferable securities are traded before theexchange on the US OTC fixed income market;

ii. the securities include an exchange contract registeredunder the Securities Act of 1933 that foresees a right toexchange the 144A for similar registered securities that aretraded on the US OTC fixed income market;

iii. where the exchange contract has not been asserted withinone year after the acquisition of the securities, the securitieswill be subject to the limit described in point 2 (a) hereunder;




f. units of UCITS authorised according to the Directive 85/611/EEC and/or other UCIs within the meaning of the first andsecond indent of Article 1 Par (2) of Directive 85/611/EECwhether located in a Member State or otherwise, provided that:

i. these UCIs are authorised in accordance with the legislationrequiring that such undertakings are subject to supervisionwhich the Luxembourg Financial Supervisory Authority(Commission de Surveillance du Secteur Financier – CSSF)considers equivalent to that prescribed under EU legislation,and that cooperation between the authorities is sufficientlyguaranteed;

ii. the level of protection for unitholders of these other UCIs isequivalent to that provided for unitholders of a UCITS and,in particular, that the rules on the segregation of assets,borrowing, lending and short sales of transferable securitiesand money market instruments are equivalent to therequirements of the Directive 85/611/EEC;

iii. the business of the other UCIs is reported in semi-annualand annual reports to enable an assessment to be made ofthe assets and liabilities, income and operations over thereporting period;

iv. the proportion of assets of these UCITS or other UCIs inwhich units are to be acquired, which, in accordance withtheir Articles can be globally invested in units of otherUCITS or UCIs, does not exceed 10%;.

g. deposits with credit institutions which are repayable on demandor which may be withdrawn, and maturing in no more than 12months, provided that the credit institution has its registeredoffice in a Member State of the European Union or, if theregistered office of the credit institution is located in anothercountry, provided that it is subject to prudential rules consideredby the CSSF as equivalent to those laid down in EuropeanCommunity law;

h. derivative financial instruments, including equivalent instrumentsinvolving cash settlements, traded on a regulated marketreferred to in (a), (b) and (c) above and/or derivative financialinstruments traded over-the-counter (“OTC derivatives”),provided that:

i. the underlying consists of instruments covered by this point1, or financial indices, interest rates, foreign exchange ratesor currencies, in which the UCITS may invest according toits investment objectives;

ii. the counterparties to OTC derivative transactions are first-class financial institutions specialised in these types oftransactions provided that they are also subject to prudentialsupervision; and

iii. the OTC derivatives are subject to reliable and verifiablevaluation on a daily basis and can be sold, liquidated orclosed by an offsetting transaction at any time at their fairvalue at the Company's initiative.

i. money market instruments other than those traded on aregulated market, which are liquid and have a value that can beaccurately determined at any time, provided that the issue orissuer of these instruments is subject to regulations intended toprotect investors and their savings, and provided that theseinstruments are:

i. issued or guaranteed by a central, regional or localgovernment authority, by a central bank of an EU MemberState, the European Central Bank, the European Union orthe European Investment Bank, a non-member State of theEU or, in the case of a Federal State, by a member of thefederation, or by an international public body to which oneor more EU Member States belong, or

ii. issued by a company whose securities are traded on theregulated markets referred to in (a), (b) and (c) above, or

iii. issued or guaranteed by an institution subject to prudentialsupervision, in accordance with criteria defined by EuropeanCommunity law, or by an institution which is subject to andcomplies with prudential rules which the CSSF considers tobe at least as stringent as those prescribed by EUlegislation, or

iv. issued by other entities belonging to categories approved bythe CSSF, provided that investments in such instrumentsare subject to rules for protecting investors which areequivalent to those stipulated above in bullets ( i, ii, iii) andprovided that the issuer is a company whose capital andreserves amount to at least ten million euro (EUR10,000,000) and which presents and publishes its annualaccounts in accordance with the Fourth Directive 78/660/EEC, or is an entity which, within a group of companies thatincludes one or more listed companies, is dedicated tofinancing the group, or is an entity which is dedicated tofinancing securitisation vehicles backed by bank financing.

2. In addition, the Company:

a. may invest up to a maximum of 10% of its net assets intransferable securities and money market instruments otherthan those referred to under point 1 above;

b. may acquire movable and immovable assets which areessential for the direct exercise of its activities;

c. may not acquire precious metals or certificates representingprecious metals;

3. The Company may, on an ancillary basis, hold cash for each sub-fund.

B. Investment limits

1. The Company may not invest:

a. more than 10% of the net assets of each sub-fund intransferable securities or money market instruments issued bythe same entity;

b. more than 20% of the net assets of each sub-fund in depositsplaced with the same entity.

2. The Company’s counterparty risk in an OTC derivative transactionmay not exceed 10% of the net assets of each sub-fund when thecounterparty is a credit institution referred to in point 1 (g) of SectionA “Eligible Investments” above, or 5% of the net assets of therelevant sub-fund in other cases.

3.

a. The total value of transferable securities and money marketinstruments of each issuer in which more than 5% of the netassets of a given sub-fund is invested may not exceed 40% ofthe value of these net assets; this restriction does not apply todeposits with credit institutions subject to prudential supervisionand to OTC derivative transactions with these institutions;

b. Notwithstanding the individual limits laid down in points 1 and 2above, the Company may not combine:

i. investments in transferable securities or money marketinstruments issued by a single entity,

ii. deposits made with a single entity, and/or

iii. risks arising from OTC derivative transactions undertakenwith a single entity,

that amount to more than 20% of the net assets of each sub-fund.

c. The limit of 10% laid down in point 1 (a) above may beincreased to a maximum of 35% if the transferable securities ormoney market instruments are issued or guaranteed by a




Member State of the European Union, by its local publicauthorities, by a non-member State or by an international publicbody to which one or more Member States belong.

d. The limit of 10% laid down in point 1 (a) above may beincreased to a maximum of 25% for certain bonds if they areissued by a credit institution which has its registered office in aMember State of the European Union and is subject by law tospecial public supervision designed to protect bondholders. Inparticular, the proceeds resulting from the issue of these bondsmust be invested, in accordance with the Law, in assets which,during the entire validity of the bonds, sufficiently cover theliabilities arising there from and that in the event of the issuer'sdefault are assigned with priority to the repayment of capital andthe payment of accrued interest. Where the Company investsmore than 5% of the net assets of a sub-fund in the bondsreferred to in this paragraph and issued by a single issuer, thetotal value of said investments may not exceed 80% of thevalue of the net assets of the relevant Company sub-fund.

e. The transferable securities and money market instrumentscovered by point 3 (c) and (d) above are not taken into accountin the 40% limit mentioned in point 3 (a);

f. The limits stipulated in points 1, 2 and 3 (a), (b), (c) and (d)above may not be combined; consequently, investments intransferable securities or money market instruments issued by asingle entity, in deposits or derivative instruments with this entityin compliance with points 1, 2 and 3 (a), (b), (c) and (d) abovemay not in aggregate exceed 35% of the net assets of therelevant Company sub-fund.

4. Companies grouped for the purpose of consolidating their accounts,within the meaning of Directive 83/349/EEC of 13 June 1983 or inaccordance with recognised international accounting rules, aretreated as a single entity when calculating the limits specified above.

5. The Company is authorised for each of its sub-funds to makecumulative investments in transferable securities and money marketinstruments within the same group up to a limit of 20% of its netassets.

6.

a. By derogation to the above limits , and without prejudice to thelimits laid down in point 9 below, the limits set out in points 1 to5 above are raised to a maximum of 20% for investments inequities and/or bonds issued by a single entity when the aim ofthe sub-fund’s investment policy is to replicate the compositionof a certain equity or bond index which is recognised by theCSSF on the following basis:

i. the composition of the index is sufficiently diversified;

ii. the index constitutes a representative benchmark of themarket to which it refers;

iii. it is published in an appropriate manner.

b. The limit set out above is raised to 35% when it proves to bejustified by exceptional market conditions, particularly inregulated markets where certain transferable securities ormoney market instruments are highly dominant. The investmentup to this limit is only permitted for a single issuer.

7. as an exception to the limits set out in points 1 to 5 above, theCompany is authorised to invest, following the principle of riskdiversification, up to 100% of the net assets of each sub-fund intransferable securities and money market instruments issuedor guaranteed by a Member State of the European Union or theOrganisation for Economic Cooperation and Development(OECD), by local public authorities of an EU Member State, orby international public bodies to which one or more EUMember States belong, provided that the transferable securitiesand money market instruments foreseen hereunder arecomprised of at least six different issues and that the

transferable securities and money market instruments of anysuch single issue do not exceed 30% of the net assets of therelevant sub-fund.

8.

a. The Company may, for each sub-fund, acquire the units ofUCITS and/or other UCIs referred to in Section A “EligibleInvestments” above, point 1 (f), provided that no more than 20%of its net assets are invested in a single UCITS or other UCI.For the purposes of applying this investment limit, each sub-fund of a UCI with multiple sub-funds is to be regarded as aseparate issuer, provided that the principle of segregation of theliabilities of the different sub-funds in relation to third parties isensured.

b. Investments made in units of UCIs other than UCITS may not inaggregate exceed 30% of the net assets of each sub-fund.Where the Company has acquired units of UCITS and/or otherUCIs, the assets of the respective UCITS or other UCIs are notcombined for the purposes of the limits laid down in points 1, 2,3, 4 and 5 above.

c. Where the Company invests in the units of other UCITS and/orother UCIs which are managed, directly or by delegation, by thesame management company or by any other company to whichthe management company is linked through commonmanagement or control, or through a substantial direct orindirect holding, the said management company or othercompany may not charge subscription or redemption fees onthe Company’s investment in the units of such other UCITSand/or UCIs.

9. For all the sub-funds, the Company may not acquire:

a. shares with voting rights that would enable it to exert asignificant influence on the management of an issuer;

b. moreover, the Company may not acquire more than:

i. 10% of the non-voting shares of a single issuer;

ii. 10% of the bonds of a single issuer;

iii. 25% of the units of a single UCITS and/or other UCI;

iv. 10% of the money market instruments of any single issuer.

The limits laid down above in bullets ( ii, iii, iv) may bedisregarded at the time of acquisition if, at that time, thegross amount of the bonds or money market instruments, orthe net amount of the securities issued, cannot becalculated.

The restrictions set out under letters a and b above do not applyto:

i. transferable securities and money market instrumentsissued or guaranteed by a Member State of the EuropeanUnion or its local public authorities;

ii. transferable securities and money market instrumentsissued or guaranteed by a State that is not a member of theEuropean Union;

iii. transferable securities and money market instrumentsissued by international public bodies of which one or moreEU Member States are members;

iv. shares held by the Company in the capital of a company ofa non-member State of the EU that primarily invests itsassets in the securities of issuers of that State where, underthe legislation of that State, such an investment constitutesthe only way in which the Company can invest in thesecurities of issuers of that state. This derogation onlyapplies, however, on condition that the investment policy ofthe company of the non-member EU State complies withthe limits laid down in the provisions contained in Section B,with the exception of points 6 and 7. Should the limits set




out in Section B be exceeded, with the exception of thelimits set out in points 6, 7 and 9, Article 49 of the Law of 20December 2002 will apply by analogy;

v. shares held by one or more investment companies in thecapital of subsidiary companies carrying out, exclusively ontheir behalf, management, advisory and marketing activitiesin the country in which the subsidiary is located, in regard tothe redemption of units at unitholders' request.

10. Regarding derivative transactions, the Company will comply with thelimits and restrictions set out in Chapter IV “Techniques andinstruments” hereafter.

The Company need not comply with the investment limits set outabove when exercising subscription rights attached to transferablesecurities or money market instruments which form part of theassets of its sub-funds.

If the limits are exceeded for reasons beyond the Company's controlor as a result of the exercise of subscription rights, the Companymust, through its sales transactions, have as its priority objective theregularisation of that situation, bearing shareholders’ interests inmind.

Insofar as an issuer is a legal entity with multiple sub-funds in whichthe assets of a sub-fund are exclusively liable for the rights ofinvestors in relation to this sub-fund and for those of creditorswhose financial claim arises from the creation, operation orliquidation of this sub-fund, each sub-fund is to be considered as aseparate issuing entity for the purposes of the application of therules of risk spreading specified in this title B, with the exception ofpoints 7 and 9.

The above investment limits generally apply insofar as the sub-fund factsheets do not stipulate more stringent rules.

C. Borrowings, loans and guarantees

1. The Company is not authorised to borrow. As an exception, theCompany may borrow:

a. up to 10% of its net assets provided that such borrowings are ofa temporary nature.

b. up to 10% of its net assets provided that the purpose of suchborrowings is to acquire real-estate assets required for thedirect exercise of its activities; in this case the total of suchborrowings and those referred to under (a) above may not underany circumstances exceed 15% of the net assets.

2. However, the Company may acquire foreign currency by means of aback-to-back loan for each sub-fund.

3. The Company may not enter into short sales of transferablesecurities, money market instruments or other financial instrumentsmentioned in Section A “Eligible Investments” point 1 (f), (g) and (h).

4. The Company may not grant credit or provide guarantees to thirdparties. This restriction will not prevent the relevant undertakingsfrom acquiring transferable securities, money market instruments orother financial instruments as referred to in Section A “EligibleInvestments” point 1 (f), (h) and (i) and which are not fully paid up.

IV. Techniques and instruments

A. General provisions

For the purpose of efficient portfolio management and/or in order toprotect the assets and undertakings of each sub-fund, the Companymay, for each sub-fund, use techniques and instruments related totransferable securities and money market instruments. Where thesetransactions involve the use of derivatives, in the meaning providedunder letter h of point 1 Section A Chapter III, the Company mustcomply with the following limits and conditions:

1. for each sub-fund, the Company may only invest in derivativesinsofar as the overall exposure to the underlying assets does notexceed the investment limits specified in points 1, 2, 3 and 5 ofSection B Chapter III; where the Company invests in index-basedderivative financial instruments, these investments will notnecessarily be combined with these limits;

2. the counterparty risk in an OTC derivative transaction may notexceed 10% of the relevant sub-fund’s net assets when thecounterparty is a credit institution referred to in point 1 letter gSection A Chapter III, or 5% of its net assets in other cases;

3. the Company will ensure that the overall risk to which each sub-fundis exposed arising from derivatives does not exceed the net value ofthe portfolios of the relevant sub-fund;

4. where a transferable security or money market instrument includesa derivative, this must be taken into account when complying withthe provisions relating to derivative products.

The Company will ensure that the overall risk arising from derivativesdoes not exceed the total net value of its assets.

The risks are calculated taking into account the current value of theunderlying assets, the counterparty risk, future market movements andthe time available to liquidate the positions.

Under no circumstances will the use of transactions with respectto derivative instruments or other techniques and financialinstruments cause the Company to deviate from the investmentpolicy set forth for each sub-fund.

B. Securities lending and borrowing transactions

The Company, the management company or the portfolio manager, asthe case may be and with respect to the assets of each sub-fund, mayengage in securities lending provided that these transactions complywith the regulations set forth in Circular 08/356 issued by theCommission de Surveillance du Secteur Financier (the “CSSF”)concerning the rules applicable to undertakings for collective investmentwhen they use certain techniques and instruments relating totransferable securities and money market instruments, as amendedfrom time to time.

Each sub-fund may lend the securities included in its portfolio to aborrower either directly or through a standardised lending systemorganised by a recognised clearing institution or through a lendingsystem organised by a financial institution subject to prudentialsupervision rules considered by the CSSF as equivalent to thoseprescribed by Community law and specialised in this type oftransactions. In all cases, the counterparty to the securities lendingagreement (i.e. the borrower) must be subject to prudential supervisionrules considered by the CSSF as equivalent to those prescribed byCommunity law. In case the aforementioned financial institution acts onits own account, it is to be considered as counterparty in the securitieslending agreement.

For each securities lending transaction, each sub-fund must receive, inprinciple, a guarantee the value of which is, during the lifetime of thelending agreement, at least equivalent to 90% of the global valuation(interests, dividends and other eventual rights included) of the securitieslent.

The Company must proceed on a daily basis to the valuation of theguarantee received.

The guarantee must normally take the form of:

1. liquid assets which include not only cash and short term bankcertificates, but also money market instruments such as definedwithin Directive 2007/16/EC of 19 March 2007 implementing CouncilDirective 85/611/EEC on the coordination of laws, regulations andadministrative provisions relating to certain UCITS as regards theclarification of certain definitions. A letter of credit or a guarantee atfirst-demand given by a first class credit institution not affiliated tothe counterparty are considered as equivalent to liquid assets;




2. bonds issued or guaranteed by a Member State of the OECD or bytheir local public authorities or by supranational institutions andundertakings with EU, regional or world-wide scope;

3. shares or units issued by money market UCIs calculating a daily netasset value and being assigned a rating of AAA or its equivalent;

4. shares or units issued by UCITS investing mainly in bonds/sharesmentioned in 5. and 6. below;

5. bonds issued or guaranteed by first class issuers offering anadequate liquidity, or

6. shares admitted to or dealt in on a regulated market of a MemberState of the OECD, on the condition that these shares are includedin a main index.

Such guarantee is not required in case of a standardised securitieslending system organised by a recognised clearing institution or in caseof a lending system organised by a financial institution subject toprudential supervision rules considered by the CSSF as equivalent tothose prescribed by Community law and specialised in this type oftransactions if the intermediary assures to the lender, through aguarantee or otherwise, the reimbursement of the value of the securitieslent.

Each sub-fund must ensure that the volume of the securities lendingtransactions is kept at an appropriate level or that it is entitled to requestthe return of the securities lent in a manner that enables it, at all times,to meet its redemption obligations and that these transactions do notjeopardise the management of the sub-fund’s assets in accordance withits investment policy.

Each sub-fund must make sure that it is able to claim its rights on theguarantee in case of the occurrence of an event requiring the executionthereof. Therefore, the guarantee must be available at all times, eitherdirectly or through the intermediary of a first class financial institution ora wholly-owned subsidiary of this institution, in such a manner that thesub-fund is able to appropriate or realise the assets given as guarantee,without delay, if the counterparty does not comply with its obligation toreturn the securities.

During the duration of the agreement, the guarantee cannot be sold orgiven as a security or pledged, except when the sub-fund has othermeans of coverage.

C. Repurchase transactions (opérations à réméré)

The Company may participate in repurchase agreements (opérations àréméré) which consist of the purchase and sale of securities, wherebythe clauses of the agreement entitle the seller to repurchase thesecurities sold from the buyer at a price and date agreed between thetwo parties upon the conclusion of the agreement.

The Company may act either as buyer or seller in repurchasetransactions. Their participation in such transactions is, however, subjectto the following rules:

1. The Company may only purchase or sell securities under arepurchase agreement if the counterparties in these transactions arefirst-rate financial institutions specialising in such transactions.

2. During the term of a repurchase agreement the Company may notsell the securities covered by the agreement before the counterpartyhas exercised its right to repurchase the securities or before therepurchase term has expired.

3. Where the Company is open to redemptions, it shall limit thenumber of repurchase agreements in which it participates in order toensure it can meet its redemption obligations at all times.

The Company may engage in repurchase agreements on a regularbasis.

D. Use of collateral

In order to reduce counterparty risk faced by the Company’s sub-funds,a guarantee ("collateral") system may be put in place for certain assetswith the counterparty. The Company will ensure that the followingconditions are met:

1. assets offered as collateral will be valued daily at the market priceand will exceed the value of the amount exposed;

2. assets offered as collateral will be liquid and will involve minimumrisk (e.g. first-class government bonds or cash);

3. assets offered as collateral will be kept by a third-party custodian (i.e. a legal entity distinct from the counterparty or entity granting thecollateral) that is legally protected from the consequences of thedefault of an associated party;

4. assets offered as collateral may be wholly mobilised by theCompany at any time.

V. Management of the Company

A. Designation of a management company

The Company designated ING Investment Management Luxembourg S.A. as its management company, within the meaning of the Law of 20December 2002 on undertakings for collective investment.

ING Investment Management Luxembourg S.A. has been incorporatedin the form of a public limited company (société anonyme) in compliancewith the Law of 10 August 1915 on commercial companies and the Lawof 20 December 2002 on undertakings for collective investment. INGInvestment Management Luxembourg S.A. was established for anindefinite period by deed dated 4 February 2004 and published in theMémorial C on 25 February 2004. Its registered office is situated at 52route d’Esch, Luxembourg. The Company was registered under numberB 98977 in the Trade and Companies Register of the District Court ofLuxembourg.

The Board of Directors of the management company is composed asfollows:

- Mr Michel van ElkChairmanDirector and Head of Marketing and SalesING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

- Mr Jonathan AtackChief Financial and Risk OfficerING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

- Mr David EckertChief Operating OfficerING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

- Mr Bruno SpringaelManaging DirectorING Investment Management Belgium24 avenue Marnix, Brussels 1050, Belgium

- Mrs Maaike van MeerHead of Legal ServicesING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands

The Board of Directors of the management company has appointed thefollowing persons as managers of the company:

- Mr Johannes BoltjesManager Account and Implementation ManagementING Investment Management (Europe) B.V.15 Prinses Beatrixlaan, The Hague 2595 AK, The Netherlands




- Mr Maurice HannonHead of Legal, Compliance & DomiciliationING Investment Management Luxembourg S.A.52 route d'Esch, L-1470 Luxembourg

The corporate object of ING Investment Management Luxembourg S.A.is the collective portfolio management of Luxembourg and/or foreignUCITS approved in accordance with Directive 85/611/EEC, asamended, as well as other Luxembourg or foreign UCIs which do not fallwithin the scope of this directive, with the management of its own assetsremaining an ancillary activity. The activities of collective portfoliomanagement of UCITS and UCIs include in particular:

1. Portfolio management: in this respect, ING Investment ManagementLuxembourg S.A. may, on behalf of the UCITS and/or other UCIsunder management, provide advice and recommendations regardingthe investments to be made, enter into contracts, purchase, sell,exchange and deliver any transferable securities and any otherassets, and may exercise the voting rights attached to thetransferable securities constituting the assets of such UCITS and/orother UCIs on their behalf. This list is not exhaustive but ratherindicative.

2. Central administration of UCITS and UCIs: this consists in carryingout the tasks listed in annex II of the Law of 20 December 2002 onundertakings for collective investment, in particular, valuating theportfolio and determining the value of shares and/or units of UCITSand UCIs, the issue and redemption of shares and/or units of UCITSand UCIs, maintaining the register of UCITS and UCIs and keepingrecords of transactions. This list is not exhaustive but ratherindicative.

3. Marketing shares/units of UCITS and UCIs in Luxembourg orabroad.

In compliance with the legislation and regulations currently in force andwith the approval of the Board of Directors of the Company, INGInvestment Management Luxembourg S.A. is authorised to delegate allor part of its duties to other companies that it deems appropriate, oncondition that ING Investment Management Luxembourg S.A. remainsresponsible for the acts and omissions of these delegates as regardsthe tasks entrusted to it, as if these acts and omissions had beencarried out by ING Investment Management Luxembourg S.A. itself. Thepresent prospectus will be updated in the event of any such delegation.In the event of special delegation that is not specified in the simplifiedprospectus or in the current Part III of the full prospectus, the sub-funds’factsheets will make specific reference to it.

B. Management fee

In accordance with the terms and conditions of the nomination of INGInvestment Management Luxembourg S.A. by the SICAV, the latter willpay ING Investment Management Luxembourg S.A. an annualmanagement fee calculated on the average net assets of the sub-fund,as described in the factsheet relating to each sub-fund. This fee ispayable monthly in arrears.

VI. Portfolio Managers

ING Investment Management Luxembourg S.A. may entrust, at its ownexpense, the management of the different Company sub-funds’ assetsto one or more of the portfolio managers listed below. The portfoliomanagers are listed in each sub-fund factsheet.

These may include:

- ING Asset Management B.V. , with registered office at PrincesBeatrixlaan 15, The Hague, has as its main object the managementof assets of undertakings for collective investment.

- ING Investment Management Asia Pacific (Hong Kong) Ltd is acompany that belongs to the ING Group which has its registeredoffice at 39/F One International Finance Centre, 1 Harbour ViewStreet, Central, Hong Kong. This company is a recognisedinvestment adviser and dealer.

- ING Investment Management Belgium , which has its registeredoffice at 24 Avenue Marnix, 1000 Brussels, is a Belgian publiclimited company (société anonyme). ING Investment ManagementBelgium is the new name, since 30 January 2003, of the assetmanagement company of ING Belgique SA, formerly Caisse PrivéeBanque (ING Investment Management (Brussels)). It is arecognised asset manager.

- ING Investment Management Co. (formerly called "AeltusInvestment Management, Inc.") is a company that belongs to theING Group which has its registered office at 230, Park Avenue, NewYork, NY 10169. This company provides analysis of the US capitalmarket, investment advice and the management of portfolios whichinvest primarily in securities issued by US companies.

VII. Custodian, Paying Agent, Registrar TransferAgent and Administrative Agent

A. Custodian and Paying Agent

On 1 June 2002, the Company entered into an agreement with INGLuxembourg S.A. for an unlimited period of time, under the terms ofwhich the latter was appointed as the custodian and main paying agentof the Company. Either party may terminate the agreement at any timesubject to prior written notice of 180 days.

Pursuant to the custodian agreement, ING Luxembourg S.A. will receivea fee payable by each of the Company sub-funds as indicated inChapter III “Fees, expenses and taxation” of Part I of this prospectus,under Section A “Fees payable by the Company”.

As the custodian, ING Luxembourg S.A. fulfils the customary obligationsand duties regarding the deposit of cash, transferable securities andother Company assets. It also performs the tasks provided for in Article34 of the Law of 20 December 2002 on undertakings for collectiveinvestment. The custodian may, under its own responsibility, entrust allor part of the assets held on deposit to other banking institutions orfinancial intermediaries.

In particular, the custodian must ensure that:

1. the sale, issue, redemption and cancellation of shares effected by oron behalf of the Company are executed in compliance with the lawand with its Articles;

2. in transactions involving the Company’s assets, the proceeds areremitted within the customary deadlines; and

3. Company profits are allocated in accordance with the Articles.

All assets and cash belonging to the Company are entrusted to thecustodian.

In accordance with normal banking practice, the custodian may, underits responsibility, entrust part of the Company’s assets tocorrespondents.

Any actions relating to the sale of the Company’s assets will beperformed by the custodian on the instructions of the Company.

As the main paying agent, ING Luxembourg S.A. is responsible for thedistribution of income and dividends to the shareholders.

ING Luxembourg S.A. is a credit institution incorporated on 15September 1960 for an indefinite period in the form of a public limitedcompany (société anonyme), whose registered office is located at 52route d'Esch, Luxembourg.




B. Registrar and transfer agent

ING Luxembourg S.A., as registrar and transfer agent, is, in particular,responsible for the issue and sale of Company shares, maintaining theregister of shareholders and the transfer of the Company’s shares toshareholders, agents and third parties.

C. Administrative agent

ING Investment Management Luxembourg S.A. has been entrusted withthe administration of the Company.

ING Investment Management Luxembourg S.A., in its capacity asadministrative agent, is responsible for ensuring the correct calculationof the net asset value in accordance with the prospectus and theArticles and for the execution of all the legal and administrativeformalities required by Luxembourg law and regulations.

VIII. Shares

The share capital of the Company is at all times equal to the assetsrepresented by the outstanding shares of the different Company sub-funds.

Any natural person or legal entity may acquire Company shares inaccordance with the provisions of Chapter II “Subscriptions,redemptions and conversions” of Part I of the prospectus.

The shares are issued without nominal value and must be fully paid upupon subscription. When new shares are issued, existing shareholdersdo not benefit from any preferential subscription rights.

The Board of Directors may issue one or more share classes for eachsub-fund. These may be reserved for a particular group of investors, e.g. investors from a specific country or region or institutional investors.

The share classes may differ from another one with regard to their coststructure, the initial investment amount, the currency in which the netasset value is expressed or any other feature. The Board of Directorsmay impose initial investment obligations with regard to investments in acertain share class, a specific sub-fund or in the Company.

Capitalisation and distribution shares may exist within each class.Details can be found in the sub-fund factsheets.

Other classes may be created by the Board of Directors which decideson their names and features. These other classes are specified in eachof the sub-fund factsheets containing these new classes.

Whenever dividends on distribution shares are distributed, the portion ofnet assets of the share class to be allocated to distribution shares willsubsequently be reduced by an amount equal to the amounts of thedividends distributed, thus leading to a decrease in the percentage ofnet assets allocated to distribution shares, whereas the portion of thenet assets allocated to capitalisation shares will remain the same.

Any payment of dividends results in an increase in the ratio between thevalue of capitalisation shares and the value of distribution shares of theshare class and sub-fund concerned. This ratio is known as parity.

Within a single sub-fund, all the shares have equal rights with regard todividends as well as liquidation and redemption proceeds (subject to therespective rights of distribution and capitalisation shares, taking theparity at the time into account).

The Company may decide to issue fractional shares. These fractionalshares do not confer any voting rights upon their holders, but do enablethem to participate pro rata in the net assets of the Company. Only fullshares, regardless of their value, carry a voting right. In the event thatbearer shares are issued, only certificates representing whole sharesmay be issued.

Shares are issued in registered or bearer form (physical or in book-entryform), depending on the choice of the shareholder, unless otherwisestated in the sub-fund factsheets and with the exception of shareclasses reserved for institutional investors, which are in principle issuedin registered form only.

Registered shares may be converted into bearer shares and vice versa,at the request and cost of the shareholder, with the exception of theregistered shares of classes reserved for institutional investors, whichmay not, in principle, be converted into bearer form.

Physical bearer shares may be issued in certificates of differentdenominations. If a holder of bearer shares wishes to obtaindenominations different from those already held, they may be requiredto pay the exchange cost.

IX. Net asset value

The net asset value of the shares of each share class for each sub-fundof the Company will be expressed in the currency decided upon by theBoard of Directors. In principle, this net asset value will be determinedat least twice a month.

The Board of Directors will decide the valuation days (hereinafter calledthe “Valuation Day”) and the methods used to publish the net assetvalue, in accordance with the legislation in force.

Valuation Day: for each sub-fund, is the day on which the net assetvalue per share of such sub-fund is determined.

A Valuation Day is a bank business day as more particularly describedin each sub-fund’s factsheet, for which the preceding bank business dayis not a day on which any exchange or market on which a substantialportion of the relevant sub-fund’s investments is traded, is closed orwhile dealings on any such exchange or market are restricted orsuspended. Requests for issue, redemption and conversion of shares ofany class are accepted by the Company on any bank business day inLuxembourg. A list of non Valuation Days will be available from theManagement Company on request.

Details of the frequency of calculation of the net asset value are given ineach sub-fund factsheet.

1. The Company's assets include:

a. all cash in hand or on deposit, including any interest accruedand outstanding;

b. all bills and promissory notes receivable and receivables,including any outstanding proceeds of sales of securities;

c. all securities, equities, bonds, term bills, preferred shares,options or subscription rights, warrants, money marketinstruments and any other investments and transferablesecurities held by the Company;

d. all dividends and distributions payable to the Company either incash or in the form of stocks and shares (the Company may,however, make adjustments to take account of any fluctuationsin the market value of transferable securities caused bypractices such as ex-dividend or ex-right trading);

e. all interest accrued and to be received on any interest-bearingsecurities belonging to the Company, unless this interest isincluded in the principal amount of such securities;

f. the Company's formation costs, to the extent that these havenot yet been amortised;

g. all other assets of whatever nature, including the proceeds ofswap transactions and advance payments.

2. The Company's liabilities include:

a. all borrowings, bills due and accounts payable;

b. all known liabilities, whether due or not, including all maturedcontractual liabilities payable either in cash or in the form ofassets, including the amount of any dividends declared by theCompany but not yet paid;

c. all provisions for capital gains tax and income tax up to theValuation Day and any other provisions authorised or approvedby the Board of Directors;




d. all of the Company’s other liabilities regardless of their naturewith the exception of those represented by shares of theCompany. In order to determine the amount of such liabilitiesthe Company will take into account all expenses payable by theCompany which will include formation costs, fees payable to themanagement company, fees payable to portfolio managers oradvisors, accountants, the custodian and correspondents, theadministrative agent, registrar, transfer agent and payingagents, distributors and permanent representatives based in thecountries in which the Company is registered and any otheragent employed by the Company, costs related to legalassistance and auditing services, promotion, printing, reportingand publishing expenses, including the cost of advertising,preparing and printing prospectuses, explanatory memoranda,registration statements, annual and semi-annual reports, taxesor other levies, and all other operating expenses, including feesfor buying and selling assets, interest, bank and brokeragecharges, postage, telephone and telex charges. The Companymay calculate administrative fees and other expenses of aregular or recurring nature in advance on the basis of anestimated figure for one year or other periods and may fix, inadvance, proportional fees for any such periods.

3. The value of assets will be determined as follows:

a. any cash in hand or on deposit, lists of bills for discount, billsand sight bills, receivables, prepaid expenses, cash dividendsand interest declared or accrued as aforesaid and not yetreceived will be valued taking their full value into account,unless it is unlikely that such amount will be paid or received infull, in which case the value thereof will be determined byapplying a discount that the Board of Directors deemsappropriate in order to reflect the true value of the asset;

b. the valuation of Company assets will, for transferable securitiesand money market instruments or derivatives admitted to anofficial stock exchange or traded on any other regulated market,be based on the last available price on the principal market onwhich these securities, money market instruments or derivativesare traded, as provided by a recognised listing service approvedby the Board of Directors. If such prices are not representativeof the fair value, these securities, money market instruments orderivatives as well as other authorised assets will be valued onthe basis of their foreseeable sale prices, as determined in goodfaith by the Board of Directors;

c. securities and money market instruments which are not listed ortraded on any regulated market will be valued based on the lastavailable price, unless such price is not representative of theirtrue value; in this case, the valuation will be based on theforeseeable sale price of the security, as determined in goodfaith by the Board of Directors;

d. the amortised cost valuation method may be used for short-termtransferable securities of certain sub-funds of the Company.This method involves valuing a security at its cost and thereafterassuming a constant amortisation to maturity of any discount orpremium regardless of the impact of fluctuating interest rates onthe market value of the security. While this method provides afair valuation, the value determined by amortised cost maysometimes be higher or lower than the price the sub-fund wouldreceive if it were to sell the securities. For some short-termtransferable securities, the return for a shareholder may differsomewhat from the return that could be obtained from a similarsub-fund which values its portfolio securities at their marketvalue.

e. the value of investments in investment funds is calculated onthe last available valuation. Generally, investments ininvestment funds will be valued in accordance with the methodslaid down for such investment funds. These valuations areusually provided by the fund administrator or the agent incharge of valuations of this investment fund. To ensureconsistency in the valuation of each sub-fund, if the time at

which the valuation of an investment fund was calculated doesnot coincide with the valuation day of the sub-fund in question,and such valuation is determined to have changed substantiallysince its calculation, the net asset value may be adjusted toreflect these changes as determined in good faith by the Boardof Directors.

f. the valuation of swaps is based on their market value, whichitself depends on various factors such as the level and volatilityof the underlying indices, market interest rates or the residualduration of the swap. Any adjustments required as a result ofissues and redemptions will be carried out by means of anincrease or decrease in the swaps, traded at their market value.

g. the valuation of derivatives traded over-the-counter (OTC), suchas futures, forwards or options not traded on a stock exchangeor another regulated market, will be based on their netliquidation value determined in accordance with the policiesestablished by the Board of Directors, in a manner consistentlyapplied for each type of contract. The net liquidation value of aderivative position corresponds to the unrealised profit/loss withrespect to the relevant position. This valuation is based on orcontrolled by the use of a model recognised and commonlypracticed on the market.

h. the value of other assets will be determined prudently and ingood faith by the Board of Directors in accordance withgenerally accepted valuation principles and procedures.

The Board of Directors may, at its complete discretion, authorise analternative valuation method to be used if it considers that such avaluation better reflects the fair value of any asset of the Company.

The valuation of the Company's assets and liabilities expressed inforeign currencies will be converted into the currency of the sub-fundconcerned, based on the last known exchange rate.

All regulations will be interpreted and valuations carried out inaccordance with generally accepted accounting principles.

Adequate provisions will be established for each sub-fund for theexpenses incurred by each sub-fund of the Company and any off-balance sheet liabilities shall be taken into account in accordance withfair and prudent criteria.

For each sub-fund and for each share class, the net asset value pershare will be determined in the calculation currency of the net assetvalue of the relevant class, by a figure obtained by dividing, on theValuation Day, the net assets of the share class concerned, comprisingthe assets of this share class less any liabilities attributable to it, by thenumber of shares issued and outstanding for the share classconcerned.

If both distribution and capitalisation shares are available for a shareclass, the net asset value of a distribution share of a given share classwill at all times be equal to the amount obtained by dividing the portionof net assets of this share class attributable to all the distribution sharesby the total number of distribution shares of this class issued andoutstanding.

Similarly, the net asset value of an capitalisation share of a given shareclass will at all times be equal to the amount obtained by dividing theportion of net assets of this share class attributable to all thecapitalisation shares by the total number of capitalisation shares of thisclass issued and outstanding.

Any share that is in the process of being redeemed pursuant to ChapterII “Subscriptions, redemptions and conversions” of Part I of theprospectus (“Essential information regarding the Company”) will betreated as an issued and existing share until the close of the ValuationDay applicable to the redemption of this share and, until such time asthe redemption is settled, it will be deemed a Company liability.




Any shares to be issued by the Company in accordance withsubscription requests received shall be treated as being issued witheffect from the close of the Valuation Day on which their issue price wasdetermined, and this price will be treated as an amount payable to theCompany until such time as it is received by the latter.

Insofar as possible, any purchases or sales of transferable securitiescontracted by the Company will be processed on the Valuation Day.

Large transactions in or out of a sub-fund can create “dilution” of afund’s assets because the price at which an investor buys or sellsshares in a sub-fund may not entirely reflect the dealing and other coststhat arise when the portfolio manager has to trade in securities toaccommodate large cash inflows and outflows. In order to counter thisand enhance the protection of existing shareholders, the mechanismknown as “Swinging Single Pricing” (SSP) may be applied as of netcapital movement is greater than a threshold determined by the board ofdirectors. Existing investors will no longer have to indirectly bear thesetransactions costs because with SSP the charge of the transaction costsis directly integrated into the calculation of the net asset value, withthese costs borne by incoming and outgoing investors. By using SSP,the net asset value of the relevant sub-fund is adjusted when thethreshold is reached by an amount, called the “swing factor”, tocompensate transactions costs resulting from the net capital flows(difference between in and outflows). Where there are net capitalinflows, the swing factor is added to the net asset value to take accountof subscriptions of fund shares, where there are net outflows, the swingfactor is deducted from the net asset value to take account of sharesredemptions. In both cases, the same net asset value applies to allincoming and outgoing investors on a particular date.

All sub-funds of the Company may be included in the Swinging SinglePricing.

The Company's net assets will be equal to the sum of the net assets ofall the sub-funds, where applicable converted into the Company’sconsolidation currency, on the basis of the last known exchange rates.

In the absence of bad faith, gross negligence or manifest error, anydecision regarding the calculation of the net asset value taken by theBoard of Directors, or by any bank, company or other organisationappointed by the Board of Directors for the purpose of calculating thenet asset value, shall be final and bind the Company and present,former or future shareholders.

X. Suspension of the calculation of the net assetvalue and/or the issue, redemption andconversion of shares.

The Board of Directors is authorised to temporarily suspend thecalculation of the value of the assets and of the net asset value pershare of one or several sub-funds and/or the issue, redemption andconversion of shares in the following cases:

1. in the event of the closure, for periods other than normal holidays, ofa stock exchange or other regulated market that operates regularly,is recognised and open to the public and provides the listings for asignificant portion of the assets of one or more sub-funds, or in theevent that transactions on such markets are suspended, subject torestrictions or impossible to execute in the required quantities;

2. where there is a breakdown in the methods of communicationnormally used to determine the value of investments of theCompany or the current value on any investment exchange orwhen, for any reason whatsoever, the value of investments cannotbe promptly and accurately ascertained;

3. where exchange or capital transfer restrictions prevent the executionof transactions on behalf of one or more sub-funds or wherepurchases and sales made on its behalf cannot be executed atnormal exchange rates;

4. where factors relating inter alia to the political, economic, military ormonetary situation, and which are beyond the control, responsibilityand operational ability of the Company, prevent it from disposing ofits assets and determining their net asset value in a normal orreasonable way;

5. following any decision to dissolve one, several or all sub-funds ofthe Company;

6. where the market of a currency in which a significant portion of theassets of one or more sub-funds is expressed is closed for periodsother than normal holidays, or where trading on such a market iseither suspended or subject to restrictions;

7. to establish exchange parities in the context of a merger,contribution of assets, split or any restructuring operation, within orby one or more sub-funds.

Furthermore, in order to prevent Market Timing opportunities arisingwhen a net asset value is calculated on the basis of market prices whichare no longer up-to-date, the Board of Directors is authorised totemporarily suspend the issue, redemption and conversion of shares ofone or several sub-funds when the stock exchanges or regulatedmarkets that provide the prices for a significant portion of the assets ofone or several sub-funds are closed.

In all the above cases, the requests received will be executed at the firstnet asset value applicable upon the expiry of the suspension period.

In exceptional circumstances which may have an adverse effect on theinterests of shareholders, in the event of large volumes of subscription,redemption or conversion requests or in the event of a lack of liquidityon the markets, the Board of Directors reserves the right to set the netasset value of the Company shares only after carrying out the requiredpurchases and sales of securities on behalf of the Company. In thiscase, any subscriptions, redemptions and conversions simultaneouslypending will be executed on the basis of a single net asset value.

The suspension of the calculation of the net asset value and/or theissue, redemption or conversion of shares of one or more sub-funds willbe announced by any appropriate means and more specifically bypublication in the press, unless the Board of Directors feels that such apublication is not useful in view of the short duration of the suspension.

Such a suspension decision will be notified to any shareholdersrequesting the subscription, redemption or conversion of shares.

XI. Periodic reports

Annual reports, including accounting data, will be certified by the Auditorand semi-annual reports will be made available to shareholders at theregistered offices of the custodian and other establishments responsiblefor financial services, as well as at the Company’s registered office.

The annual reports will be published within four months of the end of thefinancial year.

Semi-annual reports will be published within two months of the end ofthe half year.

These periodic reports contain all the financial information relating toeach of the Company sub-funds, the composition and evolution of theirassets and the consolidated situation of all the sub-funds, expressed ineuro.

XII. General meetings

The annual general meeting of shareholders will be held in Luxembourg,either at the Company's registered office or at any other location inLuxembourg specified in the convening notice, at the date and timeindicated in Part I: Essential information regarding the Company.

Other general meetings, for one or several sub-funds, may be held atthe place and date specified in the convening notice.




Convening notices of ordinary and extraordinary general meetings willbe published in the countries in which the shares are available to thepublic and are required by the legislation of these countries. InLuxembourg, in the case of ordinary meetings, the convening noticeswill be published in the Mémorial and in a Luxembourg newspaper and,in the case of extraordinary meetings, in the Mémorial and in aLuxembourg newspaper (first meeting) or in two Luxembourgnewspapers (if the first meeting is not competent to pass resolutions).Letters will be sent to registered shareholders at least eight days beforethe meeting, without having to prove that this formality has been fulfilled.When all the shares are registered shares, the meetings may beconvened by registered letter alone.

Notices to attend any general meeting will contain the agenda.

Each share, regardless of its value, confers the right to one vote.Fractional shares do not carry voting rights, but do entitle their holder todistribution and liquidation proceeds.

The participation, quorum and majority required for any general meetingare those stipulated by Articles 67 and 67-1 of the Luxembourg Law of10 August 1915 and in the Company’s Articles.

The meeting may be held abroad if the Board of Directors considers thatexceptional circumstances require it.

XIII. Dividends

For distribution shares, the payment of a dividend will be made incompliance with the stipulations of each of the sub-fund factsheets.

The general meeting will set the amount of the dividend on therecommendation of the Board of Directors, within the framework of thelegal limits and those of the Articles in this regard, it being understoodthat the Board of Directors may distribute interim dividends.

A dividend may be distributed regardless of any realised or unrealisedcapital gains or losses.

However, no distribution may have the effect of reducing the capital ofall the sub-funds of the Company to an amount below the minimumcapital specified by the Law of 20 December 2002.

In accordance with the Law, the Board of Directors will determine thedates and places where the dividends will be paid and the manner inwhich their payment will be announced to shareholders.

No interest will be paid to the shareholder on the dividend amounts tobe paid.

Dividends not claimed within five years of the payment date shall beforfeited and will revert to the relevant sub-fund of the Company.

XIV. Liquidations, mergers and contributions of sub-funds or share classes

If the value of the assets of a sub-fund or any share class within a sub-fund has decreased to, or has not reached, an amount determined bythe Board of Directors to be the minimum level needed for such a sub-fund or class to operate in an economically efficient manner, or in theevent of a substantial change in the political, economic or monetarysituation, or in the framework of an economic restructuring, the Board ofDirectors may decide to redeem all the shares of the relevant class orclasses at the net asset value per share (taking into account the saleprices of investments and expenses relating thereto) calculated on theValuation Day on which such decision takes effect. The Company willsend a notice to the shareholders of the relevant share class or classesprior to the effective date of the compulsory redemption. This notice willindicate the reasons for this redemption and the procedures to befollowed. Registered shareholders will be notified in writing. TheCompany will inform holders of bearer shares by publishing a notice inthe newspapers to be determined by the Board of Directors. Unlessotherwise decided in the interests of, or in order to ensure equaltreatment between shareholders, the shareholders of the sub-fund or

the share class or classes concerned may continue to request theredemption of their shares free of charge (but taking into account thesale prices of investments and expenses relating thereto) prior theeffective date of the compulsory redemption.

Notwithstanding the powers conferred on the Board of Directors by thepreceding paragraph, the general meeting of shareholders of the classor classes of shares issued in any sub-fund may, under allcircumstances and upon proposal by the Board of Directors, redeem allthe shares of the relevant class or classes issued in this sub-fund andrefund to the shareholders the net asset value of their shares (takinginto account the sale prices of investments and expenses relatingthereto) calculated on the Valuation Day on which such decision takeseffect. There will be no quorum requirements for such general meetingsof shareholders and resolutions may be passed by a simple majorityvote of those present or represented and voting at such meetings.

Assets which could not be distributed to their beneficiaries at the time ofthe redemption will be deposited with the custodian for a period of sixmonths following the redemption; after such period, the assets will bedeposited with the Caisse de Consignation on behalf of thebeneficiaries.

Under the same circumstances as those described in the first paragraphof this Chapter, the Board of Directors may decide to allocate the assetsof a given sub-fund to another sub-fund within the Company or toanother Luxembourg undertaking for collective investment createdaccording to the provisions of Council Directive 85/611/EEC, asamended, or a sub-fund of such other undertaking for collectiveinvestment (the "new sub-fund") and to re-designate the shares of theclass or classes concerned as shares of the new sub-fund (following asplit or consolidation, if necessary, and the payment of any amountscorresponding to fractional shares to shareholders). Such decision willbe published in the same manner as described in the first paragraph ofthis chapter one month before the effective date (and, in addition, thepublication will contain the characteristics of the new sub-fund), in orderto allow shareholders to request the redemption of their shares free ofcharge during such period. Shareholders who have not requested theredemption of their shares will be legally transferred to the new sub-fund.

Notwithstanding the powers conferred on the Board of Directors by thepreceding paragraph, the general meeting of shareholders of a sub-fundmay decide to contribute the assets and liabilities attributable to saidsub-fund to another sub-fund within the Company. There will be noquorum requirements for such general meetings and resolutions may bepassed by a simple majority vote of those present or represented andvoting at such meetings.

Furthermore, in circumstances other than those described in the firstparagraph of this Chapter, the contribution of the assets and liabilitiesattributable to a given sub-fund to another undertaking for collectiveinvestment referred to in the fourth paragraph of this Chapter or toanother sub-fund within such other undertaking for collective investmentmust be approved by a decision taken by the shareholders of the classor classes of shares issued in the relevant sub-fund. There will be noquorum requirements for such general meetings of shareholders andresolutions may be passed by a simple majority vote of those present orrepresented and voting at such meetings.

In the event that this merger is carried out with a contractualLuxembourg undertaking for collective investment (fonds commun deplacement) or with a foreign-based undertaking for collectiveinvestment, the resolutions passed by the meeting shall only bind theshareholders who voted in favour of the merger.

XV. Dissolution of the Company

The Company may be dissolved by a decision taken at the generalmeeting ruling in the same manner as for the amendment of theArticles, as provided for under the law.




Any decision to dissolve the Company, together with the liquidationprocedures, will be published in the Mémorial and in three newspaperswith sufficiently wide distribution, at least one of which will be aLuxembourg newspaper.

As soon as the general meeting of shareholders has decided to dissolvethe Company, the issue, redemption and conversion of shares will beprohibited, any such transactions being rendered void.

If the share capital falls to below two-thirds of the minimum capitalrequired by law, a general meeting convened by the Board of Directors,which will propose the dissolution of the Company, will be held withinforty days of this fact coming to light. The meeting for which no quorumshall be required shall decide by simple majority of the votes of theshares represented.

If the share capital of the Company falls to below one fourth of theminimum capital, the Directors must propose the Company’s dissolutionto a general meeting within the same timeframe; in such an event thegeneral meeting shall deliberate without any quorum requirement andthe dissolution may be decided upon by the shareholders holding one-fourth of the votes of the shares represented at the meeting.

In the event of the dissolution of the Company, the liquidation shall becarried out by one or more liquidators, who may be natural persons orlegal entities and who shall be appointed by the general meeting ofshareholders. The latter will determine their powers and compensation.

The liquidation will take place in accordance with the Law of 20December 2002 on undertakings for collective investment, specifyingthe distribution amongst the shareholders of the net liquidation proceedsafter deduction of liquidation costs; the liquidation proceeds shall bedistributed to shareholders in proportion to their rights, taking paritiesinto due consideration.

On completion of the liquidation of the Company, the sums that have notbeen claimed by the shareholders will be paid into the Caisse desConsignations, which will hold said sums at their disposal for the periodcontemplated by the law. After the expiry of this period, the balance willrevert to the State of Luxembourg.

XVI. Stopped securities

The system is that provided for under the Luxembourg Law of 3September 1996 concerning the involuntary dispossession of bearersecurities. This Law provides for the issue, under certain conditions, ofduplicates of stopped securities.

XVII. Prevention of money laundering and thefinancing of terrorism

Within the context of the fight against money laundering and thefinancing of terrorism, the Company and/or ING InvestmentManagement Luxembourg S.A. will ensure that the relevantLuxembourg legislation is complied with and that the identification ofsubscribers will be carried out in Luxembourg in accordance with theregulations currently in force in the following cases:

1. in the event of direct subscription to the Company;

2. in the event of subscription through a financial sector professionalresiding in a country that is not subject to identification requirementsequivalent to Luxembourg standards with regard to the fight againstmoney laundering and the financing of terrorism;

3. in the event of subscription through a subsidiary or branch whoseparent company is subject to identification requirements equivalentto those under Luxembourg law, if the law applicable to the parentcompany does not oblige it to ensure compliance with theseprovisions for its subsidiaries and branches.

Furthermore, the Company must identify the source of the funds in theevent that the sources are financial establishments that are not subjectto identification requirements equivalent to those required underLuxembourg law. Subscriptions may be temporarily blocked until thesource of the funds has been identified.

It is generally accepted that financial sector professionals residing incountries that have adhered to the conclusions of the GAFI report(Groupe d'Action Financière sur le blanchiment de capitaux – FinancialAction Task Force on Money Laundering) are deemed to haveidentification requirements equivalent to those required by Luxembourglaw.

XVIII. Conflicts of Interests

The management company, portfolio managers and any investmentadvisers, the custodian, the paying agent, the administrative agent, theregistrar and the transfer agent, together with their subsidiaries,directors, managers or shareholders (collectively the “Parties”) are, ormay be, involved in other professional and financial activities that areliable to create a conflict of interests with the management andadministration of the Company. This includes the management of otherfunds, the purchase and sale of securities, brokerage services, custodyof securities and the fact of acting as a director, manager, advisor orrepresentative of other funds or companies in which the Company mayinvest.

Each Party respectively undertakes to ensure that the execution of theirobligations vis-à-vis the Company is not compromised by suchinvolvement. In the event that a conflict of interests becomes apparent,the Directors and the Party concerned undertake to resolve this in anequitable manner within a reasonable period of time and in the interestsof the shareholders.

XIX. Nominees

ING Investment Management Luxembourg S.A. may decide to appointNominees within the framework of the distribution of Company shares incountries where they will be marketed. Certain Nominees may not offertheir clients all the sub-funds or share classes or the option to makesubscriptions or redemptions in all currencies. For more information onthis, the clients concerned are invited to consult their Nominee.

Where the issue of registered shares is available and where theintervention of a Nominee is an integral part of the marketingmechanism, relations between the Company, ING InvestmentManagement Luxembourg S.A., the Nominee, ING Luxembourg and theinvestors must be stipulated in a contract that specifies the respectiveobligations of the parties involved. The Company and ING InvestmentManagement Luxembourg S.A. will ensure that the Nominees they havechosen are sufficiently guaranteed to duly carry out their obligations withregard to investors using their services.

Furthermore, the intervention of a Nominee is subject to compliancewith the following conditions:

1. investors must have the possibility of investing directly in the sub-fund of their choice without using the Nominee as an intermediary;

2. contracts between the Nominee and investors must contain atermination clause that confers on the investor the right to claim, atany time, direct ownership of the securities subscribed through aNominee.

It is understood that the conditions laid down in 1 and 2 above will notbe applicable in the event that the use of the services of a Nominee isessential, and even mandatory, for legal, regulatory or restrictivepractice reasons.

In the event that a Nominee is appointed, it must apply the proceduresfor fighting money laundering and the financing of terrorism as laid outin Chapter XVII above.




Nominees are not authorised to delegate all or part of their duties andpowers.

For additional information please contact:

ING Investment ManagementP.O. Box 904702509 LL The HagueThe NetherlandsTel. +31 70 378 1800e-mail: [email protected] www.ingim.com

ING (L) Renta Fund

Economy & Finance

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