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Exhibit 99.CODE ETH
ING FUNDS
SARBANES-OXLEY ACT
CODE OF ETHICS
A. ADOPTION
The Board of Directors (the "Board") of ING Partners, Inc. (the "Fund")
has adopted this code of ethics (the "Code") in connection with the requirements
of Section 406 of the Sarbanes-Oxley Act of 2002 (the "Act") concerning
disclosure of a code of ethics for the principal executive officer, the
principal financial officer, the principal accounting officer or controller, and
persons performing similar functions (regardless of whether they are employed by
the Fund or a third party of the Fund) (the "Covered Officers"). For the
purposes of this Code, the chief executive officer and the chief financial
officer of the Fund are the Covered Officers for the Fund.
B. POLICY AND PURPOSE; CONFLICTS WITH LAW AND POLICY
1. POLICY AND PURPOSE
It is the policy of the Fund to conduct their affairs in an honest and
ethical manner, and to comply with all applicable laws, rules and regulations.
The purpose of this Code is to assist in the accomplishment of the foregoing
policy, to deter wrongdoing and to promote:
a. Honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships.
b. Full, fair, accurate, timely and understandable disclosure in
reports and documents that the Fund files with, or submits to,
the Securities and Exchange Commission (the "SEC") and in
other public communications made by a Fund.
c. Compliance with applicable laws and governmental rules and
regulations.
d. The prompt internal reporting of violations of this Code to an
appropriate person or persons identified in this Code.
e. Accountability for adherence to this Code.
2. CONFLICTS WITH LAW AND POLICY
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If any part of this Code, or if compliance with any part of this Code,
violates or is in conflict with any applicable law, the provisions of such
applicable law shall control. If any part of this Code, or if compliance with
any part of this Code, violates or is in conflict with any policy or practice of
the Fund or of any service provider to the Fund, the provisions of this Code
shall control.
C. COVERED OFFICER DUTIES
Each Covered Officer shall adhere to a high standard of business ethics in
his or her dealings with and on behalf of the Fund. Specifically, each Covered
Officer shall:
1. Conduct himself or herself in an honest and ethical manner when
dealing with or on behalf of the Fund.
2. Refrain from engaging in any activity that would compromise his or
her professional ethics or otherwise prejudice his or her ability
faithfully to carry out his or her duties to the Fund.
3. Refrain from using or appearing to use material non-public
information acquired in the course of his or her work for the Fund
for unethical or illegal advantage, either directly or indirectly
through others.
4. Place the interests of the Fund and its shareholders before his or
her personal interests, and handle actual or apparent conflicts of
interest between his or her personal interests and the interests of
the Fund in an ethical manner.
5. Be familiar with the disclosure requirements generally applicable to
the Fund and take all reasonable actions, consistent with his or her
position(s) with the Fund and/or the Fund's service provider(s) to
ensure full, fair, accurate, timely and understandable disclosure in
reports and documents that the Fund files with, or submits to, the
SEC or other governmental authorities, and in other public
communications made by the Fund.
6. Comply with applicable laws and governmental rules and regulations
in his or her dealings with or on behalf of the Fund, and take all
reasonable actions, consistent with his or her position(s) with the
Fund and/or the Fund's service provider(s), to ensure compliance by
the Fund with applicable laws and governmental rules and
regulations.
7. Take all reasonable actions, consistent with his or her position(s)
with the Fund and/or the Fund's service provider(s), to ensure
prompt internal reporting of violations of this Code to an
appropriate person or persons identified in this Code.
8. Not knowingly misrepresent, or knowingly cause or permit others to
misrepresent, facts about the Fund to the Fund's shareholders,
directors, counsel or auditors, to governmental regulators or
self-regulatory organizations, or to the public.
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9. Consult with other officers and employees of the Fund, and its
adviser(s), administrator and principal underwriter, with the goal
of promoting full, fair, accurate, timely and understandable
disclosure in the reports and documents the Fund files with, or
submits to, the SEC and in other public communications made by the
Fund.
10. Promote compliance by the Fund with the standards and restrictions
imposed by applicable laws, rules and regulations.
11. Not influence investment decisions or financial or other reporting
by the Fund whereby the Covered Officer would benefit personally.
12. Not cause the Fund to take an action, or fail to take an action,
whereby the Covered Officer would benefit personally.
13. Not retaliate or take any adverse action against, or cause or permit
any retaliation or adverse action to be taken against, any other
Covered Officer or any employee of the Fund or their affiliated
persons for reports of potential violations of this Code or of
applicable laws and governmental rules and regulations that are made
in good faith.
D. DEFINITIONS
1. CONFLICTS OF INTEREST
For the purposes of this Code (i) an "actual conflict of interest" is a
situation in which a Covered Officer, a member of a Covered Officer's immediate
family, or an entity other than the Fund on whose behalf a Covered Officer is
acting or from which a Covered Officer may receive compensation or other
personal benefit, has an interest in a transaction or the results of a
transaction in which the Fund is involved that is different from the interests
of the Fund with regard to that same transaction, and (ii) an "apparent conflict
of interest" is a situation in which a Covered Officer, a member of a Covered
Officer's immediate family, or an entity other than the Fund on whose behalf a
Covered Officer is acting or from which a Covered Officer may receive
compensation or other personal benefit, appears to have an actual conflict of
interest, without regard to whether an actual conflict of interest in fact
exists. (1) Notwithstanding the
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(1) Certain actual conflicts of interest are inherent in the relationship
between the Fund and a Covered Officer who is employed by the Fund's investment
adviser, administrator or principal underwriter. As a result, this Code
recognizes that Covered Officers will, in the normal course of their duties
(whether acting on behalf of the Fund or on behalf of the adviser, administrator
or principal underwriter, or for a combination thereof), be involved in
recommending actions that may have different effects on the respective parties
or may redound to the benefit of the adviser, the administrator or the principal
underwriter at the expense of the Fund. For example, the negotiation of the
underlying advisory, administrative and underwriting agreements necessarily
places such Covered Officers in an actual conflict of interest position as to
the Fund.
These inherent conflicts of interest are known to and understood by the
Fund and the Board, and the Board has determined that the existence of these
conflicts of interest is consistent with the performance by the Covered Officers
of their duties as officers of the Fund. Therefore, the fact that a Covered
Officer acts primarily or exclusively on behalf of a party other than the Fund
with regard to a transaction that is covered by such inherent conflicts of
interest shall not IPSO FACTO cause such conduct to be in violation of the
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foregoing, an actual conflict of interest shall not include situations that are
covered by law or by the Fund's and an investment adviser's code of ethics
required under Rule 17j-1 of the Investment Company Act of 1940.(2)
2. WAIVER AND IMPLICIT WAIVER
The term "waiver" means the approval by the Fund of a material departure
from a provision of this Code. The term "implicit waiver" means a failure by the
Fund to take action within a reasonable period of time regarding a material
departure from a provision of this Code that has been made known to an executive
officer(3) of the Fund.
3. BENEFIT PERSONALLY; IMMEDIATE FAMILY
With regard to a Covered Officer, the term "benefit personally" means the
direct or indirect receipt by the Covered Officer, by a member of the Covered
Officer's immediate family, or by any entity (other than the Fund's investment
adviser or any affiliate thereof) of which the Covered Officer or any member of
the Covered Officer's immediate family owns 5% or more of the beneficial
ownership interest or by which the Covered Officer or any member of the Covered
Officer's immediate family is employed, or from which the Covered Officer or any
member of the Covered Officer's immediate family receives any compensation or
other benefit, of any compensation or other personal benefit. For the purposes
of this Code, the term "member of the immediate family" means a Covered
Officer's parent, spouse of a parent, child, spouse of a child, spouse, brother,
or sister, and includes step and adoptive relationships.
E. ACTIVITIES REQUIRING PRIOR APPROVAL
A Covered Officer and his or her immediate family shall not engage in any
of the following activities without the prior written approval of the Fund's
Chief Legal Officer (the "Chief Legal Officer") and the Fund's Chief Executive
Officer, except that in the case of the Chief Executive Officer or a member of
the Chief Executive Officer's immediate family, such approval shall be from the
Chief Legal Officer and the Qualified Legal Compliance Committee of the Board.
To obtain such approval, the Covered Officer shall submit a written statement to
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requirements of this Code. Absent specific dishonest or unethical conduct in
such a transaction, the actions by a Covered Officer in such regard shall be
deemed to be honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and professional
relationships.
(2) These inherent conflicts of interest are already subject to prohibitions in
the Investment Company Act of 1940 (the "Investment Company Act") and the
Investment Advisers Act of 1940 (the "Investment Advisers Act"). For example, a
Covered Officer may not individually engage in certain transactions (such as the
purchase of sale or securities or other property) with the Fund because of his
or her status as an "affiliated person" of the Fund. The Fund's and the
investment adviser's compliance programs and procedures are designed to prevent,
or identify and correct, violations of these provisions. This Code does not, and
is not intended to, repeat and replace those programs and procedures, and such
actual and apparent conflicts of interest fall outside of the coverage of this
Code. All other actual and apparent conflicts of interest, even if such actual
and apparent conflicts of interest are not subject to provisions in the
Investment Company Act or the Investment Advisers Act, are covered by this Code.
(3) The term "executive officer," when used with reference to a registrant,
means its president, any vice president of the registrant in charge of a
principal business unit, division or function (such as sales, administration or
finance), any other officer who performs a policy making function or any other
person who performs similar policy making functions for the registrant.
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the Chief Legal Officer describing in detail the proposed activity and the
reasons for it.
1. Service as a director, partner, officer, manager or managing member
on the board of any public or private company(4) other than the
Fund's investment adviser, administrator, principal underwriter, or
an affiliate of any of the foregoing, if such company has current or
prospective business dealings with the Fund or if the Fund may
invest in securities issued by such company.
2. Receipt of any entertainment(5) or meals from any company with which
the Fund has current or prospective business dealings unless such
entertainment or meals are business-related, reasonable in cost,
appropriate as to time and place, and not so frequent as to raise
any question of impropriety. For the purposes of this Code,
entertainment and meals that are incidental to a business
conference, seminar or meeting shall be deemed business-related,
reasonable in cost, and appropriate as to time and place.
3. Having any ownership interest in, or any consulting, employment or
compensation relationship with, any of the Fund's service providers,
other than its investment adviser(s), administrator, principal
underwriter, or any affiliated person thereof.
4. Exploit for his or her own personal gain any opportunity which the
Fund may exploit. This prohibition shall not apply to securities
trading undertaken in conformance with the Fund's and an investment
adviser's code of ethics adopted pursuant to Rule 17j-1 of the
Investment Company Act.
F. PROHIBITED ACTIVITIES
A Covered Officer and his or her immediate family shall not engage in any
of the following activities:
1. Have a direct or indirect financial interest, such as compensation
or equity ownership, in commissions, transaction charges or spreads
paid by the Fund for effecting portfolio transactions or for selling
or redeeming shares other than an interest arising from the Covered
Officer's employment with the Fund's investment adviser,
administrator, principal underwriter, or any affiliated person
thereof.
2. Receive any gifts in excess of $500 in any calendar year from any
entity or person that directly or indirectly currently or
prospectively does or will do business with or receives compensation
or other benefits from the Fund. For the
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(4) For the purposes of this Code, "company" includes any legal or business
entity such as a corporation, limited liability company, partnership, limited
partnership, trust, association, sole proprietorship, ETC.
(5) For the purposes of this Code, "entertainment" means activities or events,
such as golfing, theater, sporting events, ETC., at which a representative of
the entertaining company is present along with the Covered Officer or his or her
immediate family member. If a representative of the entertaining company is not
present, such activities or events shall be treated as gifts hereunder.
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purposes of this restriction, gifts from different persons employed
by the same entity shall be aggregated, along with any gifts from
the entity itself, in order to determine whether the $500 limit has
been exceeded.
3. Accept employment from any company, other than the Fund's investment
adviser(s), administrator or principal underwriter (or any affiliate
thereof), with which the Fund has current or prospective business
dealings within one year after the latest to occur of such Covered
Officer's termination of employment at the Fund or at the Fund's
investment adviser(s), administrator or principal underwriter (or
any affiliate thereof).
4. Borrow money from the Fund, or borrow money from or have any other
financial transactions with any company, other than the Fund's
investment adviser(s), administrator or principal underwriter (or
any affiliate thereof), with which the Fund has current or
prospective business dealings, other than routine retail
transactions that are effected on the same terms and conditions as
are available to the general public.
5. Engage in a transaction directly as a principal with the Fund,
except that this prohibition shall not apply to the purchase or
redemption of the shares of the Fund on the same terms and
conditions as all other shareholders.
6. Any other activity that would cause them to benefit personally at
the expense of the Fund.
G. REPORTING AND ACCOUNTABILITY
1. REPORTING
Each Covered Officer must:
a. Upon adoption of this Code (or thereafter, as applicable, upon
becoming a Covered Officer), affirm in writing to the Chief
Legal Officer and the Board that he or she has received, read
and understands this Code. Such affirmation shall be
substantially in the form attached hereto as EXHIBIT B.
b. Annually thereafter affirm to the Chief Legal Officer and the
Board that he or she has complied with the requirements of
this Code. Such affirmation shall be substantially in the form
attached hereto as EXHIBIT C.
c. Report at least annually all employment, ownership,
affiliations or other relationships related to conflicts of
interest that the Fund's Directors and Officers Questionnaire
covers.
d. Notify the Chief Legal Officer promptly if he or she knows of
any violation of this Code or of any applicable laws and
governmental rules and regulations. Failure to do so is itself
a violation of this Code.
2. INTERPRETATIONS
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The Chief Legal Officer has the authority and shall be responsible for
applying this Code to specific situations and for making interpretations of this
Code in any particular situation. In making interpretations of this Code, the
Chief Legal Officer may consult with the Fund's outside counsel.
3. INVESTIGATIONS
The Fund will follow these procedures in investigating and enforcing this
Code:
a. The Chief Legal Officer will take all appropriate action to
investigate any potential violations reported to him or her.
b. If, after such investigation, the Chief Legal Officer believes
that no violation has occurred, the Chief Legal Officer is not
required to take any further action.
c. If, after such investigation, the Chief Legal Officer believes
that a violation has occurred, the Chief Legal Officer shall
report such potential violation to the Qualified Legal
Compliance Committee.
d. If the Qualified Legal Compliance Committee concurs that a
violation has occurred, it will inform and make a
recommendation to the Board, which will consider appropriate
action, which may include review of, and appropriate
modifications to, applicable policies and procedures;
notification to appropriate personnel of the investment
adviser or its board; and a recommendation to discipline or
dismiss the Covered Officer or to require reimbursement or
disgorgement by the Covered Officer of any personal benefits
received.
4. WAIVERS
The Qualified Legal Compliance Committee and the Chief Legal Officer, as
applicable, may grant a waiver to compliance with this Code by a Covered Officer
or his or her immediate family if the Qualified Legal Compliance Committee or
the Chief Legal Officer determines that the proposed activity will not have an
adverse impact on any Fund or on the ability of a Covered Officer faithfully to
perform his or her duties to the Fund. To obtain a waiver, a Covered Officer
shall submit a written statement to the Chief Legal Officer describing in detail
the proposed activity, and the reasons for it, and the provision(s) of this Code
as to which a waiver is requested. Any waivers of the provisions of this Code
shall be disclosed to the extent required by law and SEC rules.
H. RELATIONSHIP TO OTHER POLICIES AND PROCEDURES
This Code shall be the sole code of ethics adopted by the Fund for
purposes of Section 406 of the Sarbanes-Oxley Act and the rules and forms
applicable to registered investment companies thereunder. Insofar as other
policies or procedures of the Fund, the Fund's adviser(s), administrator,
principal underwriter, or other service providers govern or purport to govern
the behavior or activities of the Covered Officers who are subject to this Code,
they are
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superseded by this Code to the extent that they overlap or conflict with the
provisions of this Code. The Fund's and their investment adviser's and principal
underwriter's codes of ethics under Rule 17j-1 under the Investment Company Act
are separate requirements applying to the Covered Officers and others, and are
not part of this Code.
I. CONFIDENTIALITY
All reports and records prepared or maintained pursuant to this Code will
be considered confidential and shall be maintained and protected accordingly.
Except as otherwise required by law or this Code, such matters shall not be
disclosed to anyone other than the appropriate Board or committee thereof or the
Fund's outside counsel.
J. INTERNAL USE
The Code is intended solely for the internal use by the Fund and does not
constitute an admission, by or on behalf of any Fund or any Covered Officer or
his or her immediate family, as to any fact, circumstance, or legal conclusion.
K. AMENDMENTS
Any amendments to this Code must be approved or ratified by a majority
vote of the Board, including a majority of the independent directors. Any
amendments to this Code shall be disclosed to the extent required by law and SEC
rules.
Date: November 19, 2003
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EXHIBIT B
INITIAL ACKNOWLEDGEMENT
Covered Officer Name and Title: __________________________________________
(PLEASE PRINT)
I acknowledge that I have received and read a copy of the ING Funds
Sarbanes-Oxley Act Code of Ethics (the "Code") and that I understand it. I
further acknowledge that I am responsible for understanding and complying with
the policies set forth in the Code during my tenure as a Covered Officer, as
defined in the Code.
I also acknowledge my responsibility to report any violation of the Code
to the Chief Legal Officer of the Funds.
I further acknowledge that the policies contained in the Code are not
intended to create any contractual rights or obligations, express or implied. I
also understand that, consistent with applicable law, the Funds have the right
to amend, interpret, modify or withdraw any of the provisions of the Code at any
time in their sole discretion, with or without notice.
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Signature Date
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EXHIBIT C
ANNUAL ACKNOWLEDGEMENT
Covered Officer Name and Title: __________________________________________
(PLEASE PRINT)
I acknowledge that I have received and read a copy of the ING Funds
Sarbanes-Oxley Act Code of Ethics (the "Code") and that I understand it. I
further acknowledge that I am responsible for understanding and complying with
the policies set forth in the Code during my tenure as a Covered Officer, as
defined in the Code.
I also acknowledge that I have fully complied with the terms and
provisions of the Code during the period of time since the most recent Initial
or Annual Acknowledgement provided by me.
I further acknowledge that the policies contained in the Code are not
intended to create any contractual rights or obligations, express or implied. I
also understand that, consistent with applicable law, the Funds have the right
to amend, interpret, modify or withdraw any of the provisions of the Code at any
time in their sole discretion, with or without notice.
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Signature Date