ING Groep N.V.

In re ING Groep, N.V. ERISA Litigation

As lead counsel for plaintiffs and the class, Bottini & Bottini, Inc. has reached a settlement with defendants in this class action brought on behalf of the participants and beneficiaries of the ING Americas Savings Plan and ESOP and ING 401(k) Plan for ILIAC Agents. The settlement, once approved, will resolve all claims under the Employee Retirement Income Security Act of 1974 alleged in the Consolidated Class Action Complaint attached below. The Stipulation of Settlement sets forth class members’ rights under the settlement. Copies of the Stipulation and its exhibits are attached below. By Order dated February 4, 2013 (a copy of which is attached below), the Court granted preliminary approval of the settlement and set a date of May 21, 2013 for a hearing to consider final approval of the settlement.