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Exhibit 99.CODE ETH
ING FUNDS
SARBANES-OXLEY ACT
CODE OF ETHICS
A. ADOPTION
The Boards of Directors/Trustees (collectively, the "Board") of the ING
Funds (each a "Fund," and collectively, the "Funds") set forth on EXHIBIT A
hereto, as such exhibit may be amended from time to time, have 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 a Fund or a third party)
of the Funds (the "Covered Officers"). For the purposes of this Code, the chief
executive officer and the chief financial officer of the Funds are the Covered
Officers for the Funds.
B. POLICY AND PURPOSE; CONFLICTS WITH LAW AND POLICY
1. POLICY AND PURPOSE
It is the policy of the Funds 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 a 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
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 Funds or of any service provider to the Funds, 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 a Fund. Specifically, each Covered
Officer shall:
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1. Conduct himself or herself in an honest and ethical manner when
dealing with or on behalf of a 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 Funds.
3. Refrain from using or appearing to use material non-public
information acquired in the course of his or her work for the
Funds for unethical or illegal advantage, either directly or
indirectly through others.
4. Place the interests of the Funds and their 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 a Fund in an ethical manner.
5. Be familiar with the disclosure requirements generally applicable
to the Funds and take all reasonable actions, consistent with his
or her position(s) with a Fund and/or a Fund's service
provider(s) to ensure full, fair, accurate, timely and
understandable disclosure in reports and documents that a Fund
files with, or submits to, the SEC or other governmental
authorities, and in other public communications made by a Fund.
6. Comply with applicable laws and governmental rules and
regulations in his or her dealings with or on behalf of a Fund,
and take all reasonable actions, consistent with his or her
position(s) with a Fund and/or a 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 a Fund and/or a 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 a Fund to a Fund's shareholders,
directors, counsel or auditors, to governmental regulators or
self-regulatory organizations, or to the public.
9. Consult with other officers and employees of a 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 Funds.
10. Promote compliance by the Funds 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 a 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 Funds 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 a 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 a Fund is involved that is different from the interests of
the Fund with regard to that
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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 a 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 foregoing,
an actual conflict of interest shall not include situations that are covered by
law or by the Funds' 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 a Fund of a material departure
from a provision of this Code. The term "implicit waiver" means a failure by a
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 a 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%
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(1) Certain actual conflicts of interest are inherent in the relationship
between a 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 a 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 a
Fund.
These inherent conflicts of interest are known to and understood by the
Funds 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 a 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
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 a Fund because of his or
her status as an "affiliated person" of the Fund. The Funds' 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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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 Funds'
Chief Legal Officer (the "Chief Legal Officer") and the Funds' 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
(the "QLCC"). To obtain such approval, the Covered Officer shall submit a
written statement to 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 a 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 a Fund
or if any 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 a 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 a
Fund may exploit. This prohibition shall not apply to securities
trading undertaken in conformance with the Funds' 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 a Fund. For the purposes of
this restriction, gifts from different persons employed by 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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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 a 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 any Fund, or borrow money from or have any
other financial transactions with any company, other than a
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 a Fund,
except that this prohibition shall not apply to the purchase or
redemption of the shares of any 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 a 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
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 Funds' outside counsel.
3. INVESTIGATIONS
The Funds 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.
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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
QLCC.
d. If the QLCC 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 QLCC 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 QLCC 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 Funds. 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 Funds 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 Funds, the Funds' 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 superseded by this Code to the extent that they overlap or conflict
with the provisions of this Code. The Funds' and their investment advisers' 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 Funds' outside counsel.
J. INTERNAL USE
The Code is intended solely for the internal use by the Funds 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:
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EXHIBIT A
ING VP BALANCED PORTFOLIO, INC.
ING STRATEGIC ALLOCATION PORTFOLIOS, INC.
ING GET FUND
ING VP BOND PORTFOLIO
ING VP MONEY MARKET PORTFOLIO
ING VARIABLE FUNDS
ING VARIABLE PORTFOLIOS, INC.
ING SERIES FUND, INC.
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EXHIBIT B
INITIAL ACKNOWLEDGEMENT
Covered Officer Name and Title:
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(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:
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(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
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