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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF
REGISTERED MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number: 811-21786
ING Global Advantage and Premium Opportunity Fund
(Exact name of registrant as specified in charter)
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7337 E. Doubletree Ranch Rd., Scottsdale, AZ
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85258 |
(Address of principal executive offices)
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(Zip code) |
The Corporation Trust Company, 1209 Orange
Street, Wilmington, DE 19801
(Name and address of agent for service)
Registrants telephone number, including area code: 1-800-992-0180
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Date of fiscal year end:
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February 28 |
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Date of reporting period:
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February 28, 2011 |
Annual Report
February 28,
2011
ING Global Advantage and
Premium Opportunity Fund
E-Delivery
Sign-up details inside
This report is submitted for
general information to shareholders of the ING Funds. It is
not authorized for distribution to prospective shareholders
unless accompanied or preceded by a prospectus which includes
details regarding the funds investment objectives, risks,
charges, expenses and other information. This information should
be read carefully.
FUNDS
TABLE
OF CONTENTS
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31
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36
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37
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Go
Paperless with
E-Delivery!
Sign up now for
on-line
prospectuses, fund reports, and proxy statements. In less than
five minutes, you can help reduce paper mail and lower fund
costs.
Just go to www.ingfunds.com, click
on the
E-Delivery
icon from the home page, follow the directions and complete the
quick 5 Steps to Enroll.
You will be notified by
e-mail when
these communications become available on the internet. Documents
that are not available on the internet will continue to be sent
by mail.
PROXY VOTING
INFORMATION
A description of the policies and procedures that the Fund uses
to determine how to vote proxies related to portfolio securities
is available: (1) without charge, upon request, by calling
Shareholder Services toll-free at
(800) 992-0180;
(2) on the ING Funds website at www.ingfunds.com; and
(3) on the SECs website at www.sec.gov. Information
regarding how the Fund voted proxies related to portfolio
securities during the most recent
12-month
period ended June 30 is available without charge on the ING
Funds website at www.ingfunds.com and on the SECs
website at www.sec.gov.
QUARTERLY
PORTFOLIO HOLDINGS
The Fund files its complete schedule of portfolio holdings with
the SEC for the first and third quarters of each fiscal year on
Form N-Q.
This report contains a summary portfolio of investments for the
Fund. The Funds
Forms N-Q
are available on the SECs website at www.sec.gov. The
Funds
Forms N-Q
may be reviewed and copied at the SECs Public Reference
Room in Washington, DC, and information on the operation of
the Public Reference Room may be obtained by calling
(800) SEC-0330.
The Funds Forms
N-Q, as well
as a complete portfolio of investments, are available without
charge upon request from the Fund by calling Shareholder
Services toll-free at
(800) 992-0180.
(THIS PAGE INTENTIONALLY LEFT BLANK)
PRESIDENTS
LETTER
Dear Shareholder,
ING Global Advantage and Premium Opportunity Fund (the
Fund) is a diversified, closed end management
investment company whose shares are traded on the New York Stock
Exchange under the symbol IGA. The primary objective
of the Fund is to provide a high level of income, with a
secondary objective of capital appreciation.
The Fund seeks to achieve its investment objectives by investing
at least 80% of its managed assets in a diversified global
equity portfolio and employing an option strategy of writing
index call options equivalent to a significant portion of its
equity portfolio. The Fund also hedges most of its foreign
currency exposure to reduce volatility of total returns.
For the fiscal year ended February 28, 2011, the Fund made
quarterly distributions totaling $1.38 per share, all consisting
of net investment income.
Based on net asset value (NAV), the Fund provided a
total return of 14.05% for the fiscal year ended
February 28,
2011.(1)
This NAV return reflects an increase in the Funds NAV from
$13.37 on February 28, 2010 to $13.76 on February 28,
2011, including the reinvestment of $1.38 per share in
distributions. Based on its share price, the Fund provided a
total return of 6.32% for the fiscal year ended
February 28,
2011.(2)
This share price return reflects a decrease in the Funds
share price from $14.30 on February 28, 2010 to $13.72 on
February 28, 2011, including the reinvestment of $1.38 per
share in distributions.
The global equity markets have witnessed a challenging and
turbulent period. Please read the Market Perspective and
Portfolio Managers Report for more information on the
market and the Funds performance.
At ING Funds our mission is to help you grow, protect and enjoy
your wealth. We seek to assist you and your financial advisor by
offering a range of global investment solutions. We invite you
to visit our website at www.ingfunds.com. Here you will find
information on our products and services, including current
market data and fund statistics on our open- and closed-end
funds. You will see that we offer a broad variety of equity,
fixed income and multi-asset funds that aim to fulfill a variety
of investor needs.
We thank you for trusting ING Funds with your investment assets,
and we look forward to serving you in the months and years ahead.
Sincerely,
Shaun P. Mathews
President & Chief Executive Officer
ING Funds
April 8, 2011
The views expressed in the Presidents Letter reflect those
of the President as of the date of the letter. Any such views
are subject to change at any time based upon market or other
conditions and ING Funds disclaim any responsibility to update
such views. These views may not be relied on as investment
advice and because investment decisions for an ING Fund are
based on numerous factors, may not be relied on as an indication
of investment intent on behalf of any ING Fund. Reference to
specific company securities should not be construed as
recommendations or investment advice. International investing
does pose special risks including currency fluctuation, economic
and political risks not found in investments that are solely
domestic.
For more complete information, or to obtain a prospectus for
any ING Fund, please call your Investment Professional or the
Funds Shareholder Service Department at
(800) 992-0180
or log on to www.ingfunds.com. The prospectus should be read
carefully before investing. Consider the funds investment
objectives, risks, charges and expenses carefully before
investing. The prospectus contains this information and other
information about the fund. Check with your Investment
Professional to determine which funds are available for sale
within their firm. Not all funds are available for sale at all
firms.
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(1)
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Total investment return at net asset value has been calculated
assuming a purchase at net asset value at the beginning of each
period and a sale at net asset value at the end of each period
and assumes reinvestment of dividends, capital gain
distributions and return of capital distributions/allocations,
if any, in accordance with the provisions of the Funds
dividend reinvestment plan.
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(2)
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Total investment return at market value measures the change in
the market value of your investment assuming reinvestment of
dividends, capital gain distributions and return of capital
distributions/allocations, if any, in accordance with the
provisions of the Funds dividend reinvestment plan.
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1
Market
Perspective: Year
Ended February 28, 2011
In our semi-annual report we described how, after a
13-month
advance through mid-April, a confluence of local and world
issues sent global equities, in the form of the MSCI World
Indexsm
measured in local currencies, including net reinvested dividends
(MSCI for regions discussed below), reeling to a
loss of over 3%. But in the second half of our fiscal year the
MSCI World
Indexsm
roared back, and for the whole year returned 17.46%. (The MSCI
World
Indexsm
returned 21.67% for the year ended February 28, 2011,
measured in U.S. dollars.) Investor sentiment turned
distinctly positive, despite the grave concerns that remained
and a new crisis to worry about.
It was a bumpy ride. Markets from stocks to bonds to currencies
were continually buffeted by news and events relating to three
main themes: the fitful U.S. economic recovery, the
sovereign debt crisis in the euro zone and growth dynamics in
China.
In the U.S., quarterly gross domestic product (GDP)
growth decelerated from 2.7% (annualized) in the first quarter
of 2010 to 1.7% in the second, before recovering to 2.8% in the
fourth. But attention seemed focused on employment and housing.
Since the latest recession ended in June 2009, the unemployment
rate had been stuck between 9.4% and 10.1%. At last, the
February employment report showed improvement to 9.0% in
January. But economists were baffled by the paltry 36,000 new
jobs created that month, while the labor force participation
rate, at 64.2%, was the lowest since March 1984.
In the housing market, sales of new and existing homes collapsed
after the expiry in April of a program of tax credits for home
buyers and languished thereafter. House prices (based on the
S&P/Case-Shiller 20-City Composite Home Price Index),
having shown annual increases from February 2010 started falling
again in October and our fiscal year ended with the index less
than 1% above the trough recorded in May 2009.
To be sure, there were grounds for optimism as the fiscal year
drew to a close. Consumer spending had risen for seven straight
months. The modest GDP growth above concealed a 6.7% surge in
real final sales, the best since 1998. The Institute for Supply
Management purchasing managers index signaled the busiest
manufacturing sector since 2004. The Federal Reserve in November
announced a second round of quantitative easing and would buy
$600 billion in Treasury notes and bonds. The mixed
mid-term election results forced a compromise
stimulus package worth an estimated $858 billion for 2011.
Those two measures increased the attractiveness of riskier asset
classes like equities at the expense of high grade bonds.
In the euro zone, a sovereign debt crisis started with fiscally
profligate Greece, bringing falling stock markets, downgrades,
soaring yields on peripheral euro zone bonds and doubts about
the viability of the euro itself. Greeces bail-out was
followed by Ireland near the end of 2010 and as our fiscal year
ended, Portugal, with its
10-year
bonds yielding about 7.5%, looked to be next.
Investors watched nervously as China, the source of much of the
worlds growth, wrestled with inflation near 5% and a
housing bubble. The authorities increased banks reserve
ratio requirements six times in 2010 and twice more in 2011.
Interest rates were raised three times after mid October.
Then in January, popular revolt erupted in North Africa. In
short order, dictatorships in Tunisia and Egypt fell, to be
replaced by... no one knew exactly what. As the fiscal year
ended, the fate of Libya, a significant oil producer, hung in
the balance and the price of oil, which had been rising anyway
on improving demand, was nudging $100 per barrel.
In U.S. fixed income markets the Barclays Capital
U.S. Aggregate Bond Index of investment grade bonds
returned 6.54% in the fiscal year, with a small loss in the
second half as risk appetite returned. Within this the Barclays
Capital U.S. Treasury index returned 3.71%, underperforming
the 7.93% on the Barclays Capital Corporate Investment Grade
Bond index. But both paled against the Barclays Capital High
Yield Bond 2% Issuer Constrained Composite Index,
which gained 17.34%.
U.S. equities, represented by the S&P
500®
Index including dividends, rose 22.57% in the 12 months
through February 2011, including its best September since 1939
and best December since 1991. Prices were supported by strong
earnings reports, with operating earnings per share for S&P
500®
companies set to record their fifth straight quarter of annual
growth. Equities also benefited from improved risk appetite
through the quantitative easing initiative and stimulus package
referred to above.
In currencies, the worst of the gloom about the euro zone in
early June was replaced by renewed pessimism about the dollar in
a stalling economy. Then, markets were seized by another bout of
euro zone angst, before the threat of another energy crisis
proved dollar-negative. For the fiscal year the dollar fell
1.07% against the euro, 5.78% against the pound and 8.10% to the
yen, which breached
15-year high
levels.
In international markets, the MSCI
Japan®
Index confounded the pessimists by returning 8.14% for the year
after being down nearly 10% half way through. This was based on
generally favorable corporate earnings and came despite
declining GDP and 23 months of falling prices. The MSCI
Europe ex
UK®
Index returned 14.50%, with Germany up 29.52% and Ireland and
Greece both falling. This broadly reflected the two-tier economy
that has developed, with economic statistics favoring more
soundly based countries at the expense of the peripherals.
Powered by its sizeable materials sector, the MSCI
UK®
Index advanced 15.43%, despite the prospect of severe public
spending cuts intended to eliminate an 11% budget deficit, a
shock 0.6% quarterly fall in fourth quarter GDP growth and
inflation rising to 4.0%.
Parentheses denote a negative number.
Past performance does not guarantee future results. The
performance quoted represents past performance. Investment
return and principal value of an investment will fluctuate, and
shares, when redeemed, may be worth more or less than their
original cost. The Funds performance is subject to change
since the periods end and may be lower or higher than the
performance data shown. Please call
(800) 992-0180
or log on to www.ingfunds.com to obtain performance data current
to the most recent month end.
Market Perspective reflects the views of INGs Chief
Investment Risk Officer only through the end of the period, and
is subject to change based on market and other conditions.
2
Benchmark
Descriptions
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Index
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Description
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MSCI World
Indexsm
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An unmanaged index that measures the performance of over 1,400
securities listed on exchanges in the U.S., Europe, Canada,
Australia, New Zealand and the Far East.
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S&P/Case-Shiller 20-City Composite Home Price Index
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A composite index of the home price index for the top 20
Metropolitan Statistical Areas in the United States. The index
is published monthly by Standard & Poors.
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Barclays Capital U.S. Aggregate Bond Index
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An unmanaged index of publicly issued investment grade U.S.
Government, mortgage-backed, asset-backed and corporate debt
securities.
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Barclays Capital U.S. Treasury Index
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An unmanaged index that includes public obligations of the U.S.
Treasury. Treasury bills, certain special issues, such as state
and local government series bonds (SLGs), as well as U.S.
Treasury TIPS and STRIPS, are excluded.
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Barclays Capital Corporate Investment Grade Bond Index
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The corporate component of the Barclays Capital U.S. Credit
Index. The U.S. Credit Index includes publicly-issued U.S.
corporate and specified foreign debentures and secured notes
that meet the specified maturity, liquidity, and quality
requirements. The index includes both corporate and
non-corporate sectors. The corporate sectors are industrial,
utility and finance, which includes both U.S. and non-U.S.
corporations.
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Barclays Capital High Yield Bond 2% Issuer
Constrained Composite Index
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An unmanaged index that includes all fixed income securities
having a maximum quality rating of Ba1, a minimum amount
outstanding of $150 million, and at least one year to maturity.
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S&P
500®
Index
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An unmanaged index that measures the performance of securities
of approximately 500 large-capitalization companies whose
securities are traded on major U.S. stock markets.
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MSCI
Japan®
Index
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A free float-adjusted market capitalization index that is
designed to measure developed market equity performance in Japan.
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MSCI Europe ex
UK®
Index
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A free float-adjusted market capitalization index that is
designed to measure developed market equity performance in
Europe, excluding the UK.
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MSCI
UK®
Index
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A free float-adjusted market capitalization index that is
designed to measure developed market equity performance in the
UK.
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Chicago Board Options Exchange BuyWrite Monthly Index
(CBOE BuyWrite Monthly Index)
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A passive total return index based on selling the near-term,
at-the-money S&P
500®
Index call option against the S&P
500®
stock index portfolio each month, on the day the current
contract expires.
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Morgan Stanley Capital International Europe,
Australasia and Far
East®
Index (MSCI
EAFE®
Index)
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An unmanaged index that measures the performance of securities
listed on exchanges in Europe, Australasia and the Far East. It
includes the reinvestment of dividends net of withholding taxes,
but does not reflect fees, brokerage commissions or other
expenses of investing.
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3
ING
Global Advantage and Premium Opportunity Fund
Portfolio
Managers Report
Country Allocation
as of February 28,
2011
(as a percent of net
assets)
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United States
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57
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.4%
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Japan
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9
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.5%
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United Kingdom
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7
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.8%
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Germany
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4
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.1%
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Australia
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3
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.4%
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France
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2
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.9%
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Switzerland
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2
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.7%
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Netherlands
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2
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.0%
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Sweden
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1
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.9%
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Spain
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1
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.6%
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Finland
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1
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.3%
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Hong Kong
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1
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.2%
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Italy
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1
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.2%
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Countries between 0.5%
0.7%(1)
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1
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.2%
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Countries less than
0.5%(2)
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2
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.3%
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Other Assets and Liabilities Net*
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(0
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.5)%
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Net Assets
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100
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.0%
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* Includes short-term investments related to Blackrock
Liquidity Funds TempFund Portfolio Class I.
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(1) Includes
two countries, which each represents 0.5% 0.7% of
net assets.
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(2) Includes
seventeen countries, which each represents less than 0.5% of net
assets.
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Portfolio holdings are subject to change daily.
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ING Global Advantage and Premium Opportunity Funds (the
Fund) primary investment objective is to provide a
high level of income. Capital appreciation is a secondary
investment objective. The Fund seeks to achieve its investment
objectives by:
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investing at least 80% of its managed assets in a diversified
global equity portfolio; and
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utilizing an integrated option writing strategy.
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The Fund is managed by Paul Zemsky, Vincent Costa, Jody I.
Hrazanek, Pranay Gupta and Frank van Etten, Portfolio Managers,
ING Investment Management Co. the
Sub-Adviser*.
Equity Portfolio Construction: Under normal market
conditions, the Fund invests in a diversified portfolio of
common stocks of companies located in a number of different
countries throughout the world, normally in approximately
750-1500
common stocks, seeking to reduce the Funds exposure to
individual stock risk. The Fund normally invests across a broad
range of countries (usually
25-30
countries), industries and market sectors, including investments
in issuers located in countries with emerging markets.
The Funds weighting between U.S. and international
equities depends on the
Sub-Advisers
ongoing assessment of market opportunities for the Fund. Under
normal market conditions, the Fund seeks to maintain a target
weighting of 60% in U.S. domestic common stocks and not less
than 40% in international (ex-U.S.) common stocks.
The Funds Integrated Option Strategy: The
option strategy of the Fund is designed to seek gains and lower
volatility of total returns over a market cycle by writing
(selling) index call options on selected indices and/or exchange
traded funds (ETFs) in an amount equal to
approximately 60% to 100% of the value of the Funds
holdings in common stocks.
Writing index call options involves granting the buyer the right
to appreciation of the value of an index above at a particular
price (the strike price) at a particular time. If
the purchaser exercises an index call option sold by the Fund,
the Fund will pay the purchaser the difference between the cash
value of the index and the strike price of the option.
The Fund seeks to generate gains from its portfolio index call
option strategy and, to a lesser extent, income from dividends
on the common stocks held in the Funds portfolio. The
extent of call option writing activity depends upon market
conditions and the
Sub-Advisers
ongoing assessment of the attractiveness of writing call options
on selected indices and/or ETFs. Call options are primarily
written in over-the-counter markets with major international
banks, broker-dealers and financial institutions. The Fund may
also write call options in exchange-listed option markets.
The Fund writes call options that are generally short-term
(between 10 days and three months until expiration) and at-
or
near-the-money.
The Fund typically maintains its call positions until
expiration, but it retains the option to buy back the call
options and sell new call options. Lastly, in order to reduce
volatility of NAV returns, the Fund employs a policy to hedge
major foreign currencies.
Performance: Based on net asset value
(NAV) as of February 28, 2011, the Fund
provided a total return of 14.05% for the fiscal year. This NAV
return reflects an increase in the Funds NAV from $13.37
on February 28, 2010 to $13.76 on February 28, 2011.
Based on its share price as of February 28, 2011, the Fund
provided a total return of 6.32% for the fiscal year. This share
price return reflects a decrease in the Funds share price
from $14.30 on February 28, 2010 to $13.72 on
February 28, 2011. The S&P
500®
Top Ten Holdings*
as of February 28, 2011
(as a percent of net
assets)
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ExxonMobil Corp.
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2.2
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%
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Apple, Inc.
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1.3
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%
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Chevron Corp.
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1.0
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%
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General Electric Co.
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1.0
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%
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AT&T, Inc.
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1.0
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%
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Coca-Cola Co.
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0.9
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%
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International Business Machines Corp.
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0.8
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%
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Microsoft Corp.
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0.8
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%
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Berkshire Hathaway, Inc.
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0.8
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%
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JPMorgan Chase & Co.
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0.8
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%
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*
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Excludes short-term investments
related to Blackrock Liquidity Funds
TempFund Portfolio Class I.
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Portfolio holdings are
subject to change daily.
4
ING
Global Advantage and Premium Opportunity Fund
Portfolio
Managers Report
Index, the MSCI
EAFE®
Index and the CBOE BuyWrite Monthly Index returned 22.58%,
20.00% and 8.70%, respectively, for the reporting period. During
the fiscal year, the Fund made quarterly distributions totaling
$1.38 per share, all consisting of net investment income. As of
February 28, 2011, the Fund had 18,274,358 shares
outstanding.
Market Review: The equity portfolio of the Fund
uses a customized reference index a blend of 60%
S&P
500®
Index and 40% MSCI
EAFE®
Index to reflect its strategic emphasis. During the
Funds fiscal year, the markets became highly volatile in
reaction to upsets as diverse as the Greek sovereign debt
crisis, the Gulf of Mexico oil well blowout, an
eleventh-hour
U.S. compromise on extending the Bush-era tax cuts and finally,
the eruption of rebellion and violence in the Middle East. The
rise of global uncertainty favored developed markets over
developing ones. The S&P
500®
Index gained 22.58% for the period; the MSCI
EAFE®
Index gained 20.00%. The Funds blended reference index
gained 21.66% for the period.
Equity Portfolio: INGs International Index
Plus strategy is utilized for the international equity portion
of the Fund. For the review period, the strategy performed
inline with the MSCI
EAFE®
Index. Stock selection in industrials, consumer discretionary
and energy were the main contributors to the Funds
results. These contributions were partially offset by selection
in the information technology and telecommunications services
sectors. Top contributors to performance include positive
contributions from overweights in Boliden AB and Atlas Copco AB,
while an underweight in Daimler AG and an overweight in Elpida
Memory Inc contributed negatively. By design, there was minimal
impact from region and sector allocations.
The Funds U.S. domestic equity component underperformed
the S&P
500®
Index due mainly to negative selection effect in certain
sectors. In particular, financials, energy and industrials acted
as a drag on performance. In financials, overweights in Vornado
Realty Trust and M&T Bank Corp. hurt performance. In
energy, underweights in Exxon Mobil Corp. and Schlumberger Ltd.
had a negative impact, as these stocks outperformed the overall
market. Selection added value in the information technology and
telecommunication services sectors. Within technology, an
underweight in Cisco Systems Inc. and an overweight in Altera
Corp. were a positive for the Fund. In telecommunication
services, the Funds overweight position in Qwest
Communications International Inc. helped performance. Sector
allocation had a positive impact, as overweights in industrials
and information technology added to performance.
Option Portfolio: The Fund generates premiums and
seeks gains by writing (selling) call options on a basket of
market indexes on a portion of the value of the equity
portfolio. During the period, the Fund sold short-maturity
options on the S&P 500 index, the DJ Eurostoxx 50 Index,
the Nikkei 225 Index and the FTSE 100 Index. The construction of
the option portfolio is such that there is a low tracking error
with the reference index of the international sleeve of the
equity portfolio, which is MSCI
EAFE®
Index . The strike prices of the traded options were typically
at or near the money, and the average expiration dates were
between three and six weeks. The coverage ratio was maintained
at approximately
65-70%
throughout the period. Option positions resulted in an overall
drag on performance for the period, as global equity markets
experienced significant rallies, particularly at the end of 2010
and the beginning of 2011. As a result, many of the options
expired in the money. Volatility, as measured by the VIX Index,
spiked near the middle of last year but decreased significantly
throughout the remainder of the period as uncertainty in the
global markets faded and equities rallied.
The Fund continued its policy of hedging foreign currencies to
seek to reduce volatility of NAV returns. Its hedges detracted
from performance for the period amid the reduction of global
turmoil beginning in the second half of the period.
Current Strategy & Outlook: The
underlying U.S. and EAFE strategies seek to reward investors
with sector- and country-diversification close to the S&P
500 and MSCI EAFE indices, while seeking outperformance through
portfolio construction techniques. If the market falls or moves
sideways, the premiums generated from our call-writing,
dividends and our disciplined equity strategies may make up an
important part of the Funds total return. If the market
rallies, the strategy may generate an absolute positive return,
but the upside may be limited as call options will likely be
exercised.
Prompted by political turmoil in the Middle East and North
Africa, oil prices have surged to over $100 per barrel. If oil
prices stay high the impact on global economic growth could be
significant. Following demand destruction during the recent
financial crisis, oil markets have been operating with a hefty
cushion of spare production capacity, most of which resides in
Saudi Arabia. While the recent Saudi pledge to supply the lost
Libyan output has calmed markets, it has at the same time
reduced the spare capacity cushion. This reduction might be
temporary, and it has yet to reach a dangerous level; however,
the overall risk of a possible oil supply shock has increased.
In our opinion, we expect the U.S. economy to outperform EAFE,
as non-U.S.
developed economies are more vulnerable to oil-shock inflation
and have relatively weaker growth momentum. As a result, we
believe volatility should persist at a high-enough level that
the Fund will be able to generate attractive premiums through
its call writing activities.
* Effective January 1,
2011, Bas Peeters is no longer a portfolio manager to the
Portfolio.
Portfolio holdings and
characteristics are subject to change and may not be
representative of current holdings and
characteristics.
Performance data represents past
performance and is no guarantee of future results.
Past performance is not
indicative of future results. The indices do not reflect fees,
brokerage commissions, taxes or other expenses of investing.
Investors cannot invest directly in an index.
5
The Shareholders and Board of Trustees
ING Global Advantage and Premium Opportunity Fund
We have audited the accompanying statement of assets and
liabilities, including the summary portfolio of investments, of
ING Global Advantage and Premium Opportunity Fund as of
February 28, 2011, and the related statement of operations
for the year then ended, the statement of changes in net assets
for each of the years in the two-year period then ended, and the
financial highlights for each of the years in the five-year
period then ended. These financial statements and financial
highlights are the responsibility of management. Our
responsibility is to express an opinion on these financial
statements and financial highlights based on our audits.
We conducted our audits in accordance with the standards of the
Public Company Accounting Oversight Board (United States). Those
standards require that we plan and perform the audit to obtain
reasonable assurance about whether the financial statements and
financial highlights are free of material misstatement. An audit
includes examining, on a test basis, evidence supporting the
amounts and disclosures in the financial statements. Our
procedures included confirmation of securities owned as of
February 28, 2011, by correspondence with the custodian and
brokers or by other appropriate auditing procedures where
replies from brokers were not received. An audit also includes
assessing the accounting principles used and significant
estimates made by management, as well as evaluating the overall
financial statement presentation. We believe that our audits
provide a reasonable basis for our opinion.
In our opinion, the financial statements and financial
highlights referred to above present fairly, in all material
respects, the financial position of ING Global Advantage and
Premium Opportunity Fund as of February 28, 2011, and the
results of its operations, the changes in its net assets, and
the financial highlights for the periods specified in the first
paragraph above, in conformity with U.S. generally accepted
accounting principles.
Boston, Massachusetts
April 25, 2011
6
STATEMENT
OF ASSETS AND LIABILITIES
as of February 28,
2011
|
|
|
|
|
ASSETS:
|
|
|
|
|
Investments in securities at value*
|
|
$
|
252,817,837
|
|
Short-term investments at value**
|
|
|
2,383,000
|
|
Cash
|
|
|
55,062
|
|
Cash collateral for futures
|
|
|
276,012
|
|
Foreign currencies at value***
|
|
|
149,972
|
|
Receivables:
|
|
|
|
|
Investment securities sold
|
|
|
1,875
|
|
Dividends
|
|
|
600,373
|
|
Unrealized appreciation on forward foreign currency contracts
|
|
|
1,533
|
|
Prepaid expenses
|
|
|
1,910
|
|
|
|
|
|
|
Total assets
|
|
|
256,287,574
|
|
|
|
|
|
|
|
|
|
|
|
LIABILITIES:
|
|
|
|
|
Payable for investment securities purchased
|
|
|
2,153
|
|
Unrealized depreciation on forward foreign currency contracts
|
|
|
2,699,749
|
|
Payable to affiliates
|
|
|
42,933
|
|
Payable for trustee fees
|
|
|
2,008
|
|
Other accrued expenses and liabilities
|
|
|
176,707
|
|
Written options at fair value^
|
|
|
1,818,547
|
|
|
|
|
|
|
Total liabilities
|
|
|
4,742,097
|
|
|
|
|
|
|
NET ASSETS (equivalent to $13.76 per share on
18,274,358 shares outstanding)
|
|
$
|
251,545,477
|
|
|
|
|
|
|
|
|
|
|
|
NET ASSETS WERE COMPRISED OF:
|
|
|
|
|
Paid-in capital shares beneficial interest at $0.01
par value (unlimited shares authorized)
|
|
$
|
254,259,561
|
|
Undistributed net investment income
|
|
|
1,080,724
|
|
Accumulated net realized loss
|
|
|
(26,967,654
|
)
|
Net unrealized appreciation
|
|
|
23,172,846
|
|
|
|
|
|
|
NET ASSETS
|
|
$
|
251,545,477
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
* Cost of investments in securities
|
|
$
|
227,864,488
|
|
** Cost of short-term investments
|
|
$
|
2,383,000
|
|
*** Cost of foreign currencies
|
|
$
|
149,324
|
|
^ Premiums received on written options
|
|
$
|
2,608,803
|
|
See
Accompanying Notes to Financial Statements
7
|
|
|
|
|
INVESTMENT INCOME:
|
|
|
|
|
Dividends, net of foreign taxes
withheld*(1)
|
|
$
|
5,938,816
|
|
|
|
|
|
|
Total investment income
|
|
|
5,938,816
|
|
|
|
|
|
|
|
|
|
|
|
EXPENSES:
|
|
|
|
|
Investment management fees
|
|
|
1,797,988
|
|
Transfer agent fees
|
|
|
20,466
|
|
Administrative service fees
|
|
|
239,730
|
|
Shareholder reporting expense
|
|
|
71,463
|
|
Professional fees
|
|
|
46,012
|
|
Custody and accounting expense
|
|
|
135,771
|
|
Trustee fees
|
|
|
4,585
|
|
Miscellaneous expense
|
|
|
43,760
|
|
|
|
|
|
|
Total expenses
|
|
|
2,359,775
|
|
Net recouped fees
|
|
|
22,923
|
|
|
|
|
|
|
Net expenses
|
|
|
2,382,698
|
|
|
|
|
|
|
Net investment income
|
|
|
3,556,118
|
|
|
|
|
|
|
|
|
|
|
|
REALIZED AND UNREALIZED GAIN (LOSS):
|
|
|
|
|
Net realized gain (loss) on:
|
|
|
|
|
Investments
|
|
|
38,630,518
|
|
Foreign currency related transactions
|
|
|
(2,946,641
|
)
|
Futures
|
|
|
640,816
|
|
Written options
|
|
|
(6,915,700
|
)
|
|
|
|
|
|
Net realized gain
|
|
|
29,408,993
|
|
|
|
|
|
|
Net change in unrealized appreciation or depreciation on:
|
|
|
|
|
Investments
|
|
|
2,389,065
|
|
Foreign currency related transactions
|
|
|
(3,021,287
|
)
|
Futures
|
|
|
98,956
|
|
Written options
|
|
|
(189,043
|
)
|
|
|
|
|
|
Net change in unrealized appreciation or depreciation
|
|
|
(722,309
|
)
|
|
|
|
|
|
Net realized and unrealized gain
|
|
|
28,686,684
|
|
|
|
|
|
|
Increase in net assets resulting from operations
|
|
$
|
32,242,802
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
* Foreign taxes withheld
|
|
$
|
268,030
|
|
(1) Dividends
from affiliates
|
|
$
|
5,273
|
|
See
Accompanying Notes to Financial Statements
8
|
|
|
|
|
|
|
|
|
|
|
Year Ended
|
|
Year Ended
|
|
|
February 28,
|
|
February 28,
|
|
|
2011
|
|
2010
|
|
FROM OPERATIONS:
|
|
|
|
|
|
|
|
|
Net investment income
|
|
$
|
3,556,118
|
|
|
$
|
3,728,829
|
|
Net realized gain (loss)
|
|
|
29,408,993
|
|
|
|
(24,315,335
|
)
|
Net change in unrealized appreciation or depreciation
|
|
|
(722,309
|
)
|
|
|
89,653,429
|
|
|
|
|
|
|
|
|
|
|
Increase in net assets resulting from operations
|
|
|
32,242,802
|
|
|
|
69,066,923
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
FROM DISTRIBUTIONS TO SHAREHOLDERS:
|
|
|
|
|
|
|
|
|
Net investment income
|
|
|
(25,041,070
|
)
|
|
|
|
|
Return of capital
|
|
|
|
|
|
|
(31,827,194
|
)
|
|
|
|
|
|
|
|
|
|
Total distributions
|
|
|
(25,041,070
|
)
|
|
|
(31,827,194
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
FROM CAPITAL SHARE TRANSACTIONS:
|
|
|
|
|
|
|
|
|
Reinvestment of distributions
|
|
|
1,917,476
|
|
|
|
2,069,138
|
|
Cost of shares repurchased, net of commissions
|
|
|
|
|
|
|
(1,428,482
|
)
|
|
|
|
|
|
|
|
|
|
Net increase in net assets resulting from capital share
transactions
|
|
|
1,917,476
|
|
|
|
640,656
|
|
|
|
|
|
|
|
|
|
|
Net increase in net assets
|
|
|
9,119,208
|
|
|
|
37,880,385
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
NET ASSETS:
|
|
|
|
|
|
|
|
|
Beginning of year
|
|
|
242,426,269
|
|
|
|
204,545,884
|
|
|
|
|
|
|
|
|
|
|
End of year
|
|
$
|
251,545,477
|
|
|
$
|
242,426,269
|
|
|
|
|
|
|
|
|
|
|
Distributions in excess of net investment income at end of year
|
|
$
|
1,080,724
|
|
|
$
|
(2,896,957
|
)
|
|
|
|
|
|
|
|
|
|
See
Accompanying Notes to Financial Statements
9
FINANCIAL
HIGHLIGHTS
Selected data for a share of beneficial interest outstanding
throughout each year or period.
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Year
|
|
Year
|
|
Year
|
|
Year
|
|
Year
|
|
|
|
|
Ended
|
|
Ended
|
|
Ended
|
|
Ended
|
|
Ended
|
|
|
|
|
February 28,
|
|
February 28,
|
|
February 28,
|
|
February 29,
|
|
February 28,
|
|
|
|
|
2011
|
|
2010
|
|
2009
|
|
2008
|
|
2007
|
|
|
Per Share Operating Performance:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Net asset value, beginning of period
|
|
|
$
|
|
|
|
13.37
|
|
|
|
11.29
|
|
|
|
17.79
|
|
|
|
21.19
|
|
|
|
20.24
|
|
Income (loss) from investment operations:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Net investment income
|
|
|
$
|
|
|
|
0.20
|
|
|
|
0.21
|
*
|
|
|
0.31
|
*
|
|
|
0.30
|
*
|
|
|
0.26
|
|
Net realized and unrealized gain (loss) on investments
|
|
|
$
|
|
|
|
1.57
|
|
|
|
3.64
|
|
|
|
(4.95
|
)
|
|
|
(0.73
|
)
|
|
|
2.55
|
|
Total from investment operations
|
|
|
$
|
|
|
|
1.77
|
|
|
|
3.85
|
|
|
|
(4.64
|
)
|
|
|
(0.43
|
)
|
|
|
2.81
|
|
Less distributions from:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Net investment income
|
|
|
$
|
|
|
|
1.38
|
|
|
|
|
|
|
|
0.74
|
|
|
|
|
|
|
|
0.04
|
|
Net realized gains on investments
|
|
|
$
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
2.40
|
|
|
|
1.54
|
|
Return of capital
|
|
|
$
|
|
|
|
|
|
|
|
1.77
|
|
|
|
1.12
|
|
|
|
0.57
|
|
|
|
0.28
|
|
Total distributions
|
|
|
$
|
|
|
|
1.38
|
|
|
|
1.77
|
|
|
|
1.86
|
|
|
|
2.97
|
|
|
|
1.86
|
|
Net asset value, end of period
|
|
|
$
|
|
|
|
13.76
|
|
|
|
13.37
|
|
|
|
11.29
|
|
|
|
17.79
|
|
|
|
21.19
|
|
Market value, end of period
|
|
|
$
|
|
|
|
13.72
|
|
|
|
14.30
|
|
|
|
10.42
|
|
|
|
16.73
|
|
|
|
21.11
|
|
Total investment return at net asset
value(1)
|
|
|
%
|
|
|
|
14.05
|
|
|
|
35.81
|
|
|
|
(26.96
|
)
|
|
|
(2.40
|
)
|
|
|
14.81
|
|
Total investment return at market
value(2)
|
|
|
%
|
|
|
|
6.32
|
|
|
|
57.38
|
|
|
|
(28.32
|
)
|
|
|
(7.87
|
)
|
|
|
24.40
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ratios and Supplemental
Data:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Net assets, end of period (000s)
|
|
|
$
|
|
|
|
251,545
|
|
|
|
242,426
|
|
|
|
204,546
|
|
|
|
324,275
|
|
|
|
385,433
|
|
Ratios to average net assets:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Gross expenses prior to expense
waiver/recoupment(3)
|
|
|
%
|
|
|
|
0.98
|
|
|
|
1.01
|
|
|
|
0.99
|
|
|
|
0.97
|
|
|
|
0.95
|
|
Net expenses after expense
waiver/recoupment(3)(4)
|
|
|
%
|
|
|
|
0.99
|
**
|
|
|
1.00
|
**
|
|
|
0.99
|
**
|
|
|
0.97
|
**
|
|
|
0.95
|
|
Net investment income after expense
waiver/recoupment(3)(4)
|
|
|
%
|
|
|
|
1.48
|
**
|
|
|
1.61
|
**
|
|
|
2.01
|
**
|
|
|
1.45
|
**
|
|
|
1.29
|
|
Portfolio turnover rate
|
|
|
%
|
|
|
|
164
|
|
|
|
141
|
|
|
|
178
|
|
|
|
194
|
|
|
|
132
|
|
|
|
|
|
(1) |
|
Total investment return at net
asset value has been calculated assuming a purchase at net asset
value at the beginning of each period and a sale at net asset
value at the end of each period and assumes reinvestment of
dividends, capital gain distributions and return of capital
distributions/allocations, if any, in accordance with the
provisions of the dividend reinvestment plan. Total investment
return at net asset value is not annualized for periods less
than one year.
|
|
(2) |
|
Total investment return at market
value measures the change in the market value of your investment
assuming reinvestment of dividends, capital gain distributions
and return of capital distributions/allocations, if any, in
accordance with the provisions of the Funds dividend
reinvestment plan. Total investment return at market value is
not annualized for periods less than one year.
|
|
(3) |
|
Annualized for periods less than
one year.
|
|
(4) |
|
The Investment Adviser has agreed
to limit expenses, (excluding interest, taxes, brokerage,
extraordinary expenses and acquired fund fees and expenses)
subject to possible recoupment by ING Investments, LLC
within three years of being incurred.
|
|
*
|
|
Calculated using average number of
shares outstanding throughout the period.
|
|
**
|
|
Impact of waiving the advisory fee
for the ING Institutional Prime Money Market Fund holding has
less than 0.005% impact on the expense ratio and net investment
income ratio.
|
See
Accompanying Notes to Financial Statements
10
NOTE 1
ORGANIZATION
ING Global Advantage and Premium Opportunity Fund (the
Fund) is a diversified, closed-end management
investment company registered under the Investment Company Act
of 1940, as amended (the 1940 Act). The Fund is
organized as a Delaware statutory trust.
NOTE 2 SIGNIFICANT
ACCOUNTING POLICIES
The following significant accounting policies are consistently
followed by the Fund in the preparation of its financial
statements, and such policies are in conformity with
U.S. generally accepted accounting principles for
investment companies.
A. Security Valuation. All investments in
securities are recorded at their estimated fair value, as
described below. Investments in equity securities traded on a
national securities exchange are valued at the last reported
sale price. Securities reported by NASDAQ are valued at the
NASDAQ official closing prices. Securities traded on an exchange
or NASDAQ for which there has been no sale and equity securities
traded in the
over-the-counter-market
are valued at the mean between the last reported bid and ask
prices. All investments quoted in foreign currencies will be
valued daily in U.S. dollars on the basis of the foreign
currency exchange rates prevailing at that time. Debt securities
with more than 60 days to maturity are fair valued using
matrix pricing methods determined by an independent pricing
service which takes into consideration such factors as yields,
maturities, liquidity, ratings and traded prices in similar or
identical securities. Investments in open-end mutual funds are
valued at the net asset value. Investments in securities of
sufficient credit quality maturing in 60 days or less from
date of acquisition are valued at amortized cost which
approximates fair value.
Securities for which valuations are not readily available from
an independent pricing service may be valued by brokers which
use prices provided by market makers or estimates of fair market
value obtained from yield data relating to investments or
securities with similar characteristics.
Securities and assets for which market quotations are not
readily available (which may include certain restricted
securities that are subject to limitations as to their sale) are
valued at their fair values as defined by the 1940 Act, and as
determined in good faith by or under the supervision of the
Funds Board of Trustees (Board), in accordance
with methods that are specifically authorized by the Board.
Securities traded on exchanges, including foreign exchanges,
which close earlier than the time that the Fund calculates its
net asset value (NAV) may also be valued at their
fair values, as defined by the 1940 Act, and as determined
in good faith by or under the supervision of the Board, in
accordance with methods that are specifically authorized by the
Board. The value of a foreign security traded on an exchange
outside the United States is generally based on its price on the
principal foreign exchange where it trades as of the time the
Fund determines its NAV or if the foreign exchange closes prior
to the time the Fund determines its NAV, the most recent closing
price of the foreign security on its principal exchange. Trading
in certain
non-U.S. securities
may not take place on all days on which the NYSE Euronext
(NYSE) is open. Further, trading takes place in
various foreign markets on days on which the NYSE is not open.
Consequently, the calculation of the Funds NAV may not
take place contemporaneously with the determination of the
prices of securities held by the Fund in foreign securities
markets. Further, the value of the Funds assets may be
significantly affected by foreign trading on days when a
shareholder cannot purchase or redeem shares of the Fund. In
calculating the Funds NAV, foreign securities denominated
in foreign currency are converted to U.S. dollar
equivalents. If an event occurs after the time at which the
market for foreign securities held by the Fund closes but before
the time that the Funds NAV is calculated, such event may
cause the closing price on the foreign exchange to not represent
a readily available reliable market value quotation for such
securities at the time the Fund determines its NAV. In such a
case, the Fund will use the fair value of such securities as
determined under the Funds valuation procedures. Events
after the close of trading on a foreign market that could
require the Fund to fair value some or all of its foreign
securities include, among others, securities trading in the U.S.
and other markets, corporate announcements, natural and other
disasters, and political and other events. Among other elements
of analysis in the determination of a securitys fair
value, the Board has authorized the use of one or more
independent research services to assist with such
determinations. An independent research service may use
statistical analyses and quantitative models to help determine
fair value as of the time the Fund calculates its NAV. There can
be no assurance that such models accurately reflect the behavior
of the applicable markets or the effect of the behavior of such
markets on the fair value of securities, or that such markets
will continue to
11
NOTES
TO FINANCIAL STATEMENTS
as of February 28,
2011 (continued)
NOTE 2 SIGNIFICANT
ACCOUNTING POLICIES (continued)
behave in a fashion that is consistent with such models. Unlike
the closing price of a security on an exchange, fair value
determinations employ elements of judgment. Consequently, the
fair value assigned to a security may not represent the actual
value that the Fund could obtain if it were to sell the security
at the time of the close of the NYSE. Pursuant to procedures
adopted by the Board, the Fund is not obligated to use the fair
valuations suggested by any research service, and valuation
recommendations provided by such research services may be
overridden if other events have occurred or if other fair
valuations are determined in good faith to be more accurate.
Unless an event is such that it causes the Fund to determine
that the closing prices for one or more securities do not
represent readily available reliable and market value quotations
at the time the Fund determines its NAV, events that occur
between the time of the close of the foreign market on which
they are traded and the close of regular trading on the NYSE
will not be reflected in the Funds NAV.
Options that are traded
over-the-counter
will be valued using one of three methods: (1) dealer
quotes; (2) industry models with objective inputs; or (3)
by using a benchmark arrived at by comparing prior-day dealer
quotes with the corresponding change in the underlying security.
Exchange traded options will be valued using the last reported
sale. If no last sale is reported, exchange traded options will
be valued using an industry accepted model such as Black
Scholes. Options on currencies purchased by the Fund are
valued using industry models with objective inputs.
Fair value is defined as the price that the Fund would receive
to sell an asset or pay to transfer a liability in an orderly
transaction between market participants at the measurement date.
Each investment asset or liability of the Fund is assigned a
level at measurement date based on the significance and source
of the inputs to its valuation. Quoted prices in active markets
for identical securities are classified as
Level 1, inputs other than quoted prices for an
asset or liability that are observable are classified as
Level 2 and unobservable inputs, including the
sub-advisers judgment about the assumptions that a market
participant would use in pricing an asset or liability are
classified as Level 3. The inputs used for
valuing securities are not necessarily an indication of the
risks associated with investing in those securities. Short-term
securities of sufficient credit quality which are valued at
amortized cost, which approximates fair value, are generally
considered to be Level 2 securities under applicable
accounting rules. A table summarizing the Funds
investments under these levels of classification is included
following the Summary Portfolio of Investments.
For the year ended February 28, 2011, there have been no
significant changes to the fair valuation methodologies.
B. Security Transactions and Revenue
Recognition. Security transactions are recorded on the
trade date. Realized gains or losses on sales of investments are
calculated on the identified cost basis. Interest income is
recorded on the accrual basis. Premium amortization and discount
accretion are determined using the effective yield method.
Dividend income is recorded on the ex-dividend date, or in the
case of some foreign dividends, when the information becomes
available to the Fund.
C. Foreign Currency Translation. The books and
records of the Fund are maintained in U.S. dollars. Any
foreign currency amounts are translated into U.S. dollars
on the following basis:
|
|
|
|
(1)
|
Market value of investment securities, other assets and
liabilities at the exchange rates prevailing at the
end of the day.
|
|
|
(2)
|
Purchases and sales of investment securities, income and
expenses at the rates of exchange prevailing on the
respective dates of such transactions.
|
Although the net assets and the market values are presented at
the foreign exchange rates at the end of the day, the Fund does
not isolate the portion of the results of operations resulting
from changes in foreign exchange rates on investments from the
fluctuations arising from changes in market prices of securities
held. Such fluctuations are included with the net realized and
unrealized gains or losses from investments. For securities,
which are subject to foreign withholding tax upon disposition,
liabilities are recorded on the Statement of Assets and
Liabilities for the estimated tax withholding based on the
securities current market value. Upon disposition, realized
gains or losses on such securities are recorded net of foreign
withholding tax. Reported net realized foreign exchange gains or
losses arise from sales of foreign currencies, currency gains or
losses realized between the trade and settlement dates on
securities transactions, the difference between the amounts of
dividends, interest, and foreign withholding taxes
12
NOTES
TO FINANCIAL STATEMENTS
as of February 28,
2011 (continued)
NOTE 2 SIGNIFICANT
ACCOUNTING POLICIES (continued)
recorded on the Funds books and the U.S. dollar
equivalent of the amounts actually received or paid. Net
unrealized foreign exchange gains and losses arise from changes
in the value of assets and liabilities other than investments in
securities at period end, resulting from changes in the exchange
rate. Foreign security and currency transactions may involve
certain considerations and risks not typically associated with
investing in U.S. companies and U.S. government
securities. These risks include, but are not limited to,
revaluation of currencies and future adverse political and
economic developments which could cause securities and their
markets to be less liquid and prices more volatile than those of
comparable U.S. companies and U.S. government
securities.
D. Distributions to Shareholders. The Fund
intends to make quarterly distributions from its cash available
for distribution, which consists of the Funds dividends
and interest income after payment of Fund expenses, net option
premiums and net realized and unrealized gains on investments.
At least annually, the Fund intends to distribute all or
substantially all of its net realized capital gains.
Distributions are recorded on the ex-dividend date.
Distributions are determined annually in accordance with federal
tax principles, which may differ from U.S. generally
accepted accounting principles for investment companies.
The tax treatment and characterization of the Funds
distributions may vary significantly from time to time depending
on whether the Fund has gains or losses on the call options
written on its portfolio versus gains or losses on the equity
securities in the portfolio. Each quarter, the Fund will provide
disclosures with distribution payments made that estimate the
percentages of that distribution that represent net investment
income, other income or capital gains, and return of capital, if
any. The final composition of the tax characteristics of the
distributions cannot be determined with certainty until after
the end of the Funds tax year, and will be reported to
shareholders at that time. A significant portion of the
Funds distributions may constitute a return of capital.
The amount of quarterly distributions will vary, depending on a
number of factors. As portfolio and market conditions change,
the rate of dividends on the common shares will change. There
can be no assurance that the Fund will be able to declare a
dividend in each period.
E. Federal Income Taxes. It is the policy of
the Fund to comply with the requirements of subchapter M of the
Internal Revenue Code that are applicable to regulated
investment companies and to distribute substantially all of its
net investment income and any net realized capital gains to its
shareholders. Therefore, a federal income tax or excise tax
provision is not required. Management has considered the
sustainability of the Funds tax positions taken on federal
income tax returns for all open tax years in making this
determination. No capital gain distributions shall be made until
the capital loss carryforwards have been fully utilized or
expire.
F. Use of Estimates. The preparation of
financial statements in conformity with U.S. generally accepted
accounting principles requires management to make estimates and
assumptions that affect the reported amounts of assets and
liabilities and disclosure of contingent assets and liabilities
at the date of the financial statements and the reported amounts
of increases and decreases in net assets from operations during
the reporting period. Actual results could differ from those
estimates.
G. Risk Exposures and the use of Derivative
Instruments. The Funds investment objectives
permit the Fund to enter into various types of derivatives
contracts, including, but not limited to, forward foreign
currency exchange contracts, futures and purchased and written
options. In doing so, the Fund will employ strategies in
differing combinations to permit it to increase or decrease the
level of risk, or change the level or types of exposure to
market risk factors. This may allow the Fund to pursue its
objectives more quickly and efficiently, than if it were to make
direct purchases or sales of securities capable of affecting a
similar response to market factors.
Market Risk Factors. In pursuit of its investment
objectives, the Fund may seek to use derivatives to increase or
decrease its exposure to the following market risk factors:
Credit Risk. Credit risk relates to the ability of
the issuer to meet interest and principal payments, or both, as
they come due. In general, lower-grade, higher-yield bonds are
subject to credit risk to a greater extent than lower-yield,
higher-quality bonds.
Equity Risk. Equity risk relates to the change in
value of equity securities as they relate to increases or
decreases in the general market.
13
NOTES
TO FINANCIAL STATEMENTS
as of February 28,
2011 (continued)
NOTE 2 SIGNIFICANT
ACCOUNTING POLICIES (continued)
Foreign Exchange Rate Risk. Foreign exchange rate
risk relates to the change in U.S. dollar value of a
security held that is denominated in a foreign currency. The
U.S. dollar value of a foreign currency denominated
security will decrease as the dollar appreciates against the
currency, while the U.S. dollar value will increase as the
dollar depreciates against the currency.
Interest Rate Risk. Interest rate risk refers to the
fluctuations in value of fixed-income securities resulting from
the inverse relationship between price and yield. For example,
an increase in general interest rates will tend to reduce the
market value of already issued fixed-income investments, and a
decline in general interest rates will tend to increase their
value. In addition, debt securities with longer duration, which
tend to have higher yields, are subject to potentially greater
fluctuations in value from changes in interest rates than
obligations with shorter duration.
Risks of Investing in Derivatives. The Funds
use of derivatives can result in losses due to unanticipated
changes in the market risk factors and the overall market. In
instances where the Fund is using derivatives to decrease, or
hedge, exposures to market risk factors for securities held by
the Fund, there are also risks that those derivatives may not
perform as expected resulting in losses for the combined or
hedged positions.
The use of these strategies involves certain special risks,
including a possible imperfect correlation, or even no
correlation, between price movements of derivative instruments
and price movements of related investments. While some
strategies involving derivative instruments can reduce the risk
of loss, they can also reduce the opportunity for gain or even
result in losses by offsetting favorable price movements in
related investments or otherwise, due to the possible inability
of the Fund to purchase or sell a portfolio security at a time
that otherwise would be favorable or the possible need to sell a
portfolio security at a disadvantageous time because the Fund is
required to maintain asset coverage or offsetting positions in
connection with transactions in derivative instruments.
Additional associated risks from investing in derivatives also
exist and potentially could have significant effects on the
valuation of the derivative and the Fund. Associated risks are
not the risks that the Fund is attempting to increase or
decrease exposure to, per its investment objectives, but are the
additional risks from investing in derivatives. Examples of
these associated risks are liquidity risk, which is the risk
that the Fund will not be able to sell the derivative in the
open market in a timely manner, and counterparty credit risk,
which is the risk that the counterparty will not fulfill its
obligation to the Fund. Associated risks can be different for
each type of derivative and are discussed by each derivative
type in the following notes.
Counterparty Credit Risk and Credit Related Contingent
Features. Certain derivative positions are subject to
counterparty credit risk, which is the risk that the
counterparty will not fulfill its obligation to the Fund. The
Funds derivative counterparties are financial institutions
who are subject to market conditions that may weaken their
financial position. The Fund intends to enter into financial
transactions with counterparties that it believes to be
creditworthy at the time of the transaction. To reduce this
risk, the Fund generally enters into master netting
arrangements, established within the Funds International
Swap and Derivatives Association, Inc. (ISDA) Master
Agreements (Master Agreements). These agreements are
with select counterparties and they govern transactions,
including certain over-the-counter (OTC) derivative
and forward foreign currency contracts, entered into by the Fund
and the counterparty. The Master Agreements maintain provisions
for general obligations, representations, agreements,
collateral, and events of default or termination. The occurrence
of a specified event of termination may give a counterparty the
right to terminate all of its contracts and affect settlement of
all outstanding transactions under the applicable Master
Agreement.
The Fund may also enter into collateral agreements with certain
counterparties to further mitigate credit risk associated with
OTC derivative and forward foreign currency contracts. Subject
to established minimum levels, collateral is generally
determined based on the net aggregate unrealized gain or loss on
contracts with a certain counterparty. Collateral pledged to the
Fund is held in a segregated account by a third-party agent and
can be in the form of cash or debt securities issued by the
U.S. government or related agencies.
The Funds maximum risk of loss from counterparty credit
risk on OTC derivatives is generally the aggregate unrealized
gain in excess of any collateral
14
NOTES
TO FINANCIAL STATEMENTS
as of February 28,
2011 (continued)
NOTE 2 SIGNIFICANT
ACCOUNTING POLICIES (continued)
pledged by the counterparty to the Fund. For purchased OTC
options, the Fund bears the risk of loss in the amount of the
premiums paid and the change in market value of the options
should the counterparty not perform under the contracts. The
Fund did not enter into any purchased OTC options during the
year ended February 28, 2011.
The Funds master agreements with derivative counterparties
have credit related contingent features that if triggered would
allow its derivatives counterparties to close out and demand
payment or additional collateral to cover their exposure from
the Fund. Credit related contingent features are established
between the Fund and its derivatives counterparties to reduce
the risk that the Fund will not fulfill its payment obligations
to its counterparties. These triggering features include, but
are not limited to, a percentage decrease in the Funds net
assets and or a percentage decrease in the Funds NAV,
which could cause the Fund to accelerate payment of any net
liability owed to the counterparty. The contingent features are
established within the Funds Master Agreements.
Written options by the Fund do not give rise to counterparty
credit risk, as written options obligate the Fund to perform and
not the counterparty. As of February 28, 2011, the total
value of written OTC call options subject to Master Agreements
in a liability position was $1,818,547. If a contingent feature
had been triggered, the Fund could have been required to pay
this amount in cash to its counterparties. The Fund did not hold
or post collateral for its open written OTC call options at year
end.
H. Forward Foreign Currency Contracts and Futures
Contracts. The Fund may enter into forward foreign
currency contracts primarily to hedge against foreign currency
exchange rate risks on its
non-U.S. dollar
denominated investment securities. When entering into a forward
foreign currency contract, the Fund agrees to receive or deliver
a fixed quantity of foreign currency for an agreed-upon price on
an agreed future date. These contracts are valued daily and the
Funds net equity therein, representing unrealized gain or
loss on the contracts as measured by the difference between the
forward foreign exchange rates at the dates of entry into the
contracts and the forward rates at the reporting date, is
included in the statement of assets and liabilities. Realized
and unrealized gains and losses on forward foreign currency
contracts are included on the Statement of Operations. These
instruments involve market and/or credit risk in excess of the
amount recognized in the statement of assets and liabilities.
Risks arise from the possible inability of counterparties to
meet the terms of their contracts and from movement in currency
and securities values and interest rates.
During the year ended February 28, 2011, the Fund used
forward foreign currency contracts to hedge its investments in
non-U.S. dollar denominated equity securities in an attempt
to decrease the volatility of the Funds NAV.
During the year ended February 28, 2011, the Fund had
average contract amounts on forward foreign currency contracts
to buy and sell of $1,067,480 and $94,990,300, respectively.
The Fund may enter into futures contracts involving foreign
currency, interest rates, securities and securities indices. The
Fund intends to limit its use of futures contracts and futures
options to bona fide hedging transactions, as such
term is defined in applicable regulations, interpretations and
practice. A futures contract obligates the seller of the
contract to deliver and the purchaser of the contract to take
delivery of the type of foreign currency, financial instrument
or security called for in the contract at a specified future
time for a specified price. Upon entering into such a contract,
the Fund is required to deposit and maintain as collateral such
initial margin as required by the exchange on which the contract
is traded. Pursuant to the contract, the Fund agrees to receive
from or pay to the broker an amount equal to the daily
fluctuations in the value of the contract. Such receipts or
payments are known as variation margin and are recorded as
unrealized gains or losses by the Fund. When the contract is
closed, the Fund records a realized gain or loss equal to the
difference between the value of the contract at the time it was
opened and the value at the time it was closed.
Futures contracts are exposed to the market risk factor of the
underlying financial instrument. During the year ended
February 28, 2011, the Fund had purchased futures contracts
on various equity indices to potentially enhance the Funds
return and decrease the volatility of the Funds NAV.
Additional associated risks of entering into futures contracts
include the possibility that there may be an illiquid market
where the Fund is unable to liquidate the contract or enter into
an offsetting position and, if
15
NOTES
TO FINANCIAL STATEMENTS
as of February 28,
2011 (continued)
NOTE 2 SIGNIFICANT
ACCOUNTING POLICIES (continued)
used for hedging purposes, the risk that the price of the
contract will correlate imperfectly with the prices of the
Funds securities. With futures, there is minimal
counterparty credit risk to the Fund since futures are exchange
traded and the exchanges clearinghouse, as counterparty to
all exchange traded futures, guarantees the futures against
default.
During the year ended February 28, 2011, the Fund had an
average notional value of $3,706,025 on purchased futures
contracts.
I. Options Contracts. The Fund may purchase put
and call options and may write (sell) put options and covered
call options. The premium received by the Fund upon the writing
of a put or call option is included in the Statement of Assets
and Liabilities as a liability which is subsequently
marked-to-market until it is exercised or closed, or it expires.
The Fund will realize a gain or loss upon the expiration or
closing of the option contract. When an option is exercised, the
proceeds on sales of the underlying security for a written call
option or purchased put option or the purchase cost of the
security for a written put option or a purchased call option is
adjusted by the amount of premium received or paid. The risk in
writing a call option is that the Fund gives up the opportunity
for profit if the market price of the security increases and the
option is exercised. The risk in buying an option is that the
Fund pays a premium whether or not the option is exercised.
Risks may also arise from an illiquid secondary market or from
the inability of counterparties to meet the terms of the
contract.
The Fund generates premiums and seeks gains by writing OTC call
options on indices on a portion of the value of the equity
portfolio. Please refer to Note 6 for the volume of written
option activity during the year ended February 28, 2011.
J. Indemnifications. In the normal course of
business, the Fund may enter into contracts that provide certain
indemnifications. The Funds maximum exposure under these
arrangements is dependent on future claims that may be made
against the Fund and, therefore, cannot be estimated; however,
based on experience, management considers the risk of loss from
such claims remote.
NOTE 3 INVESTMENT
MANAGEMENT AND ADMINISTRATIVE FEES
ING Investments, LLC (ING Investments or the
Investment Adviser), an Arizona limited liability
company, is the Investment Adviser of the Fund. The Fund pays
the Investment Adviser for its services under the
investment management agreement (Management
Agreement), a fee, payable monthly, based on an annual
rate of 0.75% of the Funds average daily managed assets.
For purposes of the Management Agreement, managed assets are
defined as the Funds average daily gross asset value,
minus the sum of the Funds accrued and unpaid dividends on
any outstanding preferred shares and accrued liabilities (other
than liabilities for the principal amount of any borrowings
incurred, commercial paper or notes issued by the Fund and the
liquidation preference of any outstanding preferred shares). As
of February 28, 2011, there were no preferred shares
outstanding.
The Investment Adviser entered into a
sub-advisory
agreement (Sub-Advisory Agreement) with ING IM.
Subject to policies as the Board or the Investment Adviser might
determine, ING IM manages the Funds assets in accordance
with the Funds investment objectives, policies and
limitations.
During the period, ING Funds were permitted to invest end-of-day
cash balances into ING Institutional Prime Money Market Fund.
Investment management fees paid by the Fund were reduced by an
amount equal to the management fees paid indirectly to the ING
Institutional Prime Money Market Fund with respect to assets
invested by the Fund. For the year ended February 28, 2011,
the Fund waived $2,264 of such management fees. These fees are
not subject to recoupment.
Effective December 20, 2010, ING Institutional Prime Money
Market Fund was liquidated. As a result of this liquidation, the
Fund will no longer invest end-of-day cash balances into ING
Institutional Prime Money Market Fund.
ING Funds Services, LLC, a Delaware limited liability company,
(the Administrator) serves as Administrator to the
Fund. The Fund pays the Administrator for its services a fee
based on an annual rate of 0.10% of the Funds average
daily managed assets. The Investment Adviser, ING IM, and the
Administrator are indirect, wholly-owned subsidiaries of ING
Groep N.V. (ING Groep). ING Groep is a global
financial institution of Dutch origin
16
NOTES
TO FINANCIAL STATEMENTS
as of February 28,
2011 (continued)
NOTE 3 INVESTMENT
MANAGEMENT AND ADMINISTRATIVE FEES (continued)
offering banking, investments, life insurance and retirement
services.
ING Groep has adopted a formal restructuring plan that was
approved by the European Commission in November 2009 under which
the ING life insurance businesses, including the retirement
services and investment management businesses, which include the
Investment Adviser and its affiliates, would be divested by ING
Groep by the end of 2013. To achieve this goal, ING Groep
announced in November 2010 that it plans to pursue two
separate Initial Public Offerings: one a U.S. focused offering
that would include U.S. based insurance, retirement services,
and investment management operations: and the other a European
based offering for European and Asian based insurance and
investment management operations. There can be no assurance that
the restructuring plan will be carried out through two offerings
or at all.
The restructuring plan and the uncertainty about its
implementation, whether implemented through the planned Initial
Public Offerings or through other means, in whole or in part,
may be disruptive to the businesses of ING entities, including
the ING entities that service the Fund, and may cause, among
other things, interruption or reduction of business and
services, diversion of managements attention from day-to
day operations, and loss of key employees or customers. A
failure to complete the offerings or other means of
implementation on favorable terms could have a material adverse
impact on the operations of the businesses subject to the
restructuring plan. The restructuring plan may result in the
Investment Advisers and/or Sub-Advisers loss of
access to services and resources of ING Groep, which could
adversely affect their businesses and profitability. In
addition, the divestment of ING businesses, including the
Investment Adviser and Sub-Adviser, may potentially be deemed a
change of control of each entity. A change of
control would result in the termination of the Funds
advisory and
sub-advisory
agreements, which would trigger the necessity for new agreements
that would require approval of the Board, and may trigger the
need for shareholder approval. Currently, the Investment Adviser
does not anticipate that the restructuring will have a material
adverse impact on the Fund or its operations and administration.
The Investment Adviser has entered into a written expense
limitation agreement (Expense Limitation Agreement)
with the Fund under which it will limit the expenses of the
Fund, excluding interest, taxes, leverage expenses, and
extraordinary expenses (and acquired fund fees and expenses) to
1.00% of average daily managed assets. The Investment Adviser
may at a later date recoup from the Fund fees waived and other
expenses assumed by the Investment Adviser during the previous
36 months, but only if, after such recoupment, the
Funds expense ratio does not exceed the percentage
described above. The Expense Limitation Agreement is contractual
and shall renew automatically for one-year terms unless ING
Investments or the Fund provides written notice of the
termination within 90 days of the end of the then current
term or upon written termination of the Management Agreement.
Waived and reimbursed fees and any recoupment by the Investment
Adviser of such waived and reimbursed fees are reflected on the
accompanying Statement of Operations for the Fund.
As of February 28, 2011, there are no amounts of waived and
reimbursed fees that are subject to possible recoupment by the
Investment Adviser.
NOTE 4 OTHER
TRANSACTIONS WITH AFFILIATED AND RELATED PARTIES
As of February 28, 2011, the Fund had the following amounts
recorded as payable to affiliates on the accompanying Statement
of Assets and Liabilities:
|
|
|
|
|
Accrued
|
|
|
|
|
Investment
|
|
Accrued
|
|
|
Management
|
|
Administrative
|
|
|
Fees
|
|
Fees
|
|
Total
|
|
$23,718
|
|
$19,215
|
|
$42,933
|
The Fund has adopted a Deferred Compensation Plan (the
Plan), which allows eligible non-affiliated trustees
as described in the Plan to defer the receipt of all or a
portion of the trustees fees payable. Amounts deferred are
treated as though invested in various notional funds
advised by ING Investments until distribution in accordance with
the Plan.
NOTE 5 PURCHASES
AND SALES OF INVESTMENT SECURITIES
The cost of purchases and proceeds from sales of investments for
the year ended February 28, 2011, excluding short-term
securities, were $390,120,254 and $414,418,543, respectively.
17
NOTES
TO FINANCIAL STATEMENTS
as of February 28,
2011 (continued)
NOTE 6 TRANSACTIONS
IN WRITTEN OPTIONS
Transactions in written OTC call options on equity indices were
as follows:
|
|
|
|
|
|
|
|
|
|
|
Number of
|
|
Premiums
|
|
|
Contracts
|
|
Received
|
|
Balance at 02/28/10
|
|
|
303,167
|
|
|
$
|
3,337,062
|
|
Options Written
|
|
|
3,778,041
|
|
|
|
43,728,455
|
|
Options Expired
|
|
|
(1,401,141
|
)
|
|
|
(15,822,495
|
)
|
Options Exercised
|
|
|
|
|
|
|
|
|
Options Terminated in Closing Purchase Transactions
|
|
|
(2,409,044
|
)
|
|
|
(28,634,219
|
)
|
|
|
|
|
|
|
|
|
|
Balance at 02/28/11
|
|
|
271,023
|
|
|
$
|
2,608,803
|
|
|
|
|
|
|
|
|
|
|
NOTE 7 CONCENTRATION
OF INVESTMENT RISKS
All mutual funds involve risk some more than
others and there is always the chance that you could
lose money or not earn as much as you hope. The Funds risk
profile is largely a factor of the principal securities in which
it invests and investment techniques that it uses. For more
information regarding the types of securities and investment
techniques that may be used by the Fund and its corresponding
risks, see the Funds most recent Prospectus
and/or the
Statement of Additional Information.
Foreign Securities and Emerging Markets. The Fund
makes significant investments in foreign securities and may
invest up to 20% of its managed assets in securities issued by
companies located in countries with emerging markets.
Investments in foreign securities may entail risks not present
in domestic investments. Since investments in securities are
denominated in foreign currencies, changes in the relationship
of these foreign currencies to the U.S. dollar can
significantly affect the value of the investments and earnings
of the Fund. Foreign investments may also subject the Fund to
foreign government exchange restrictions, expropriation,
taxation or other political, social or economic developments, as
well as from movements in currency, security value and interest
rate, all of which could affect the market and/or credit risk of
the investments. The risks of investing in foreign securities
can be intensified in the case of investments in issuers located
in countries with emerging markets.
Leverage. Although the Fund has no current intention
to do so, the Fund is authorized to utilize leverage through the
issuance of preferred shares and/or borrowings, including the
issuance of debt securities. In the event that the Fund
determines in the future to utilize investment leverage, there
can be no assurance that such a leveraging strategy will be
successful during any period in which it is employed.
NOTE 8 CAPITAL
SHARES
Transactions in capital shares and dollars were as follows:
|
|
|
|
|
|
|
|
|
|
|
Year
|
|
Year
|
|
|
Ended
|
|
Ended
|
|
|
February 28,
|
|
February 28,
|
|
|
2011
|
|
2010
|
|
Number of Shares
|
|
|
|
|
|
|
|
|
Reinvestment of distributions
|
|
|
144,848
|
|
|
|
158,337
|
|
Shares repurchased
|
|
|
|
|
|
|
(153,044
|
)
|
|
|
|
|
|
|
|
|
|
Net increase in shares outstanding
|
|
|
144,848
|
|
|
|
5,293
|
|
|
|
|
|
|
|
|
|
|
$
|
|
|
|
|
|
|
|
|
Reinvestment of distributions
|
|
$
|
1,917,476
|
|
|
$
|
2,069,138
|
|
Shares repurchased, net of commissions
|
|
|
|
|
|
|
(1,428,482
|
)
|
|
|
|
|
|
|
|
|
|
Net increase
|
|
$
|
1,917,476
|
|
|
$
|
640,656
|
|
|
|
|
|
|
|
|
|
|
Share Repurchase
Program
Effective December 2008, the Board authorized an open-market
share repurchase program pursuant to which the Fund could
purchase, over the period ended December 31, 2009, up to
10% of its stock, in open-market transactions. There was no
assurance that the Fund would purchase shares at any particular
discount level or in any particular amounts. The share
repurchase program sought to enhance shareholder value by
purchasing shares trading at a discount from their NAV per
share, in an attempt to reduce or eliminate the discount or to
increase the NAV per share of the applicable remaining shares of
the Fund.
For the year ended February 28, 2010, the Fund repurchased
153,044 shares, representing approximately 0.8% of the
Funds outstanding shares for a net purchase price of
$1,428,482 (including commissions of $4,591). Shares were
repurchased at a weighted-average discount from NAV per share of
14.25% and a weighted-average price per share of $9.30.
NOTE 9
FEDERAL INCOME TAXES
The amount of distributions from net investment income and net
realized capital gains are determined in accordance with federal
income tax regulations, which may differ from U.S. generally
accepted accounting principles for investment companies. These
book/tax differences may be either temporary or permanent.
Permanent differences are reclassified within the capital
accounts based on their federal tax-basis treatment; temporary
differences are not
18
NOTES
TO FINANCIAL STATEMENTS
as of February 28,
2011 (continued)
NOTE 9
FEDERAL INCOME TAXES (continued)
reclassified. Key differences include the treatment of
short-term capital gains, foreign currency transactions, income
from passive foreign investment corporations and wash sale
deferrals. Distributions in excess of net investment income
and/or net
realized capital gains for tax purposes are reported as return
of capital.
The following permanent tax differences have been reclassified
as of the Funds tax year ended December 31,
2010 (1):
|
|
|
|
|
|
|
|
|
Accumulated
|
Paid-in
|
|
Undistributed
|
|
Net Realized
|
Capital
|
|
Net Investment Income
|
|
Gains / (Losses)
|
|
$(22,692,768)
|
|
$25,462,633
|
|
$(2,769,865)
|
|
|
|
(1) |
|
$22,691,848 relates to
distributions in excess of net investment income taxed as
ordinary income due to current year earnings & profits.
|
Dividends paid by the Fund from net investment income and
distributions of net realized short-term capital gains are, for
federal income tax purposes, taxable as ordinary income to
shareholders.
The tax composition of dividends and distributions in the
current period will not be determined until after the
Funds tax year-end of December 31, 2011. The tax
composition of dividends and distributions as of the Funds
most recent tax year-ends were as follows:
|
|
|
Tax Year Ended
|
|
Tax Year Ended
|
December 31, 2010
|
|
December 31, 2009
|
Ordinary
|
|
Return
|
Income
|
|
of Capital
|
|
$25,041,070
|
|
$31,827,194
|
The tax-basis components of distributable earnings and the
expiration dates of the capital loss carryforwards which may be
used to offset future realized capital gains for federal income
tax purposes as of the tax year ended December 31, 2010
were:
|
|
|
|
|
|
|
Unrealized
|
|
Capital Loss
|
|
Expiration
|
Depreciation
|
|
Carryforwards
|
|
Date
|
|
$20,257,648
|
|
|
(30,935,937)
|
|
|
2017
|
|
|
|
|
|
|
|
|
|
$
|
(30,935,937)
|
|
|
|
|
|
|
|
|
|
|
The Funds major tax jurisdictions are federal and Arizona.
The earliest tax year that remains subject to examination by
these jurisdictions is 2006.
As of February 28, 2011, no provision for income tax is
required in the Funds financial statements as a result of
tax positions taken on federal and state income tax returns for
open tax years. The Funds federal and state income and
federal excise tax returns for tax years for which the
applicable statutes of limitations have not expired are subject
to examination by the Internal Revenue Service and state
department of revenue.
The Regulated Investment Company Modernization Act of 2010 (the
Act) was enacted on December 22, 2010. The Act
makes changes to several tax rules impacting the Fund. In
general, the provisions of the Act will be effective for the
Funds tax year ending December 31, 2011. Although the
Act provides several benefits, including the unlimited
carryforward of future capital losses, there may be a greater
likelihood that all or a portion of the Funds
pre-enactment capital loss carryforwards may expire without
being utilized due to the fact that post-enactment capital
losses are required to be utilized before pre-enactment capital
loss carryforwards. Relevant information regarding the impact of
the Act on the Fund, if any, will be contained within the
Federal Income Taxes section of the notes to financial
statements for the fiscal year ending February 29, 2012.
NOTE 10 SUBSEQUENT
EVENTS
Dividends: Subsequent to February 28, 2011, the
Fund made distributions of:
|
|
|
|
|
|
|
Per Share Amount
|
|
Declaration Date
|
|
Payable Date
|
|
Record Date
|
|
$0.335
|
|
3/15/2011
|
|
4/15/2011
|
|
4/5/2011
|
Each quarter, the Fund will provide disclosures with
distribution payments made that estimate the percentages of that
distribution that represent net investment income, capital
gains, and return of capital, if any. A significant portion of
the quarterly distribution payments made by the Fund may
constitute a return of capital.
The Fund has evaluated events occurring after the balance sheet
date (subsequent events) to determine whether any subsequent
events necessitated adjustment to or disclosure in the financial
statements. Other than the above, no such subsequent events were
identified.
19
ING
Global Advantage and Premium
Opportunity Fund
as
of February 28, 2011
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent
|
|
|
|
|
|
|
|
|
of Net
|
Shares
|
|
|
|
Value
|
|
Assets
|
|
|
|
COMMON STOCK: 98.7%
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Australia: 3.2%
|
|
29,647
|
|
|
|
|
BHP Billiton Ltd.
|
|
$
|
1,400,950
|
|
|
|
0.6
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
6,657,678
|
|
|
|
2.6
|
|
|
|
|
|
|
|
|
|
|
|
|
8,058,628
|
|
|
|
3.2
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Austria: 0.2%
|
|
|
|
|
|
|
Other Securities
|
|
|
582,523
|
|
|
|
0.2
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Barbados: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
239,148
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Belgium: 0.5%
|
|
|
|
|
|
|
Other Securities
|
|
|
1,131,188
|
|
|
|
0.5
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Bermuda: 0.3%
|
|
|
|
|
|
|
Other Securities
|
|
|
752,986
|
|
|
|
0.3
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Denmark: 0.3%
|
|
|
|
|
|
|
Other Securities
|
|
|
780,183
|
|
|
|
0.3
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Finland: 1.3%
|
|
|
|
|
|
|
Other Securities
|
|
|
3,172,093
|
|
|
|
1.3
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
France: 2.9%
|
|
15,642
|
|
|
|
|
Total S.A.
|
|
|
958,860
|
|
|
|
0.4
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
6,404,634
|
|
|
|
2.5
|
|
|
|
|
|
|
|
|
|
|
|
|
7,363,494
|
|
|
|
2.9
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Germany: 3.7%
|
|
13,197
|
|
|
|
|
BASF AG
|
|
|
1,100,372
|
|
|
|
0.4
|
|
|
|
|
10,267
|
|
|
|
|
Siemens AG
|
|
|
1,388,156
|
|
|
|
0.6
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
6,802,672
|
|
|
|
2.7
|
|
|
|
|
|
|
|
|
|
|
|
|
9,291,200
|
|
|
|
3.7
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Greece: 0.2%
|
|
|
|
|
|
|
Other Securities
|
|
|
378,923
|
|
|
|
0.2
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Guernsey: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
156,996
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Hong Kong: 1.2%
|
|
|
|
|
|
|
Other Securities
|
|
|
2,927,699
|
|
|
|
1.2
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Ireland: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
247,979
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Israel: 0.3%
|
|
|
|
|
|
|
Other Securities
|
|
|
815,053
|
|
|
|
0.3
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Italy: 1.2%
|
|
|
|
|
|
|
Other Securities
|
|
|
3,124,621
|
|
|
|
1.2
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Japan: 9.4%
|
|
25,400
|
|
|
|
|
Toyota Motor Corp.
|
|
|
1,186,876
|
|
|
|
0.5
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
22,373,103
|
|
|
|
8.9
|
|
|
|
|
|
|
|
|
|
|
|
|
23,559,979
|
|
|
|
9.4
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Kazakhstan: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
185,783
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Luxembourg: 0.0%
|
|
|
|
|
|
|
Other Securities
|
|
|
91,429
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Macau: 0.0%
|
|
|
|
|
|
|
Other Securities
|
|
|
30,484
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Malaysia: 0.0%
|
|
|
|
|
|
|
Other Securities
|
|
|
25,599
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Mauritius: 0.0%
|
|
|
|
|
|
|
Other Securities
|
|
|
2,052
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Mexico: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
163,147
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Netherlands: 2.0%
|
|
38,149
|
|
|
|
|
Royal Dutch Shell PLC Class A
|
|
|
1,372,325
|
|
|
|
0.9
|
|
|
|
|
27,050
|
|
|
|
|
Royal Dutch Shell PLC Class B
|
|
|
966,990
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
2,684,691
|
|
|
|
1.1
|
|
|
|
|
|
|
|
|
|
|
|
|
5,024,006
|
|
|
|
2.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
New Zealand: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
208,245
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Norway: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
361,668
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Portugal: 0.3%
|
|
|
|
|
|
|
Other Securities
|
|
|
812,294
|
|
|
|
0.3
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Singapore: 0.6%
|
|
|
|
|
|
|
Other Securities
|
|
|
1,400,525
|
|
|
|
0.6
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Spain: 1.6%
|
|
84,015
|
|
|
|
|
Banco Santander Central Hispano S.A.
|
|
|
1,034,377
|
|
|
|
0.4
|
|
|
|
|
40,173
|
|
|
|
|
Telefonica S.A.
|
|
|
1,021,372
|
|
|
|
0.4
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
2,036,631
|
|
|
|
0.8
|
|
|
|
|
|
|
|
|
|
|
|
|
4,092,380
|
|
|
|
1.6
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Sweden: 1.9%
|
|
|
|
|
|
|
Other Securities
|
|
|
4,867,246
|
|
|
|
1.9
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
See Accompanying Notes to Financial
Statements
20
SUMMARY
PORTFOLIO OF INVESTMENTS
ING
Global Advantage and Premium
Opportunity Fund
as
of February 28, 2011 (continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent
|
|
|
|
|
|
|
|
|
of Net
|
Shares
|
|
|
|
Value
|
|
Assets
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Switzerland: 2.7%
|
|
21,734
|
|
|
|
|
Nestle S.A.
|
|
$
|
1,230,557
|
|
|
|
0.5
|
|
|
|
|
22,387
|
|
|
|
|
Novartis AG
|
|
|
1,258,074
|
|
|
|
0.5
|
|
|
|
|
7,453
|
|
|
|
|
Roche Holding AG Genusschein
|
|
|
1,124,229
|
|
|
|
0.5
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
3,118,054
|
|
|
|
1.2
|
|
|
|
|
|
|
|
|
|
|
|
|
6,730,914
|
|
|
|
2.7
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
United Kingdom: 7.7%
|
|
28,837
|
|
|
|
|
BHP Billiton PLC
|
|
|
1,143,080
|
|
|
|
0.4
|
|
|
|
|
184,364
|
|
|
|
|
BP PLC
|
|
|
1,486,278
|
|
|
|
0.6
|
|
|
|
|
27,813
|
|
|
|
|
British American Tobacco PLC
|
|
|
1,114,298
|
|
|
|
0.4
|
|
|
|
|
48,939
|
|
|
|
|
GlaxoSmithKline PLC
|
|
|
939,451
|
|
|
|
0.4
|
|
|
|
|
150,004
|
|
|
|
|
HSBC Holdings PLC
|
|
|
1,652,014
|
|
|
|
0.6
|
|
|
|
|
406,879
|
|
|
|
|
Vodafone Group PLC
|
|
|
1,155,166
|
|
|
|
0.5
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
11,974,896
|
|
|
|
4.8
|
|
|
|
|
|
|
|
|
|
|
|
|
19,465,183
|
|
|
|
7.7
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
United States: 56.5%
|
|
9,303
|
|
|
@,S
|
|
Apple, Inc.
|
|
|
3,285,913
|
|
|
|
1.3
|
|
|
|
|
86,800
|
|
|
S
|
|
AT&T, Inc.
|
|
|
2,463,384
|
|
|
|
1.0
|
|
|
|
|
112,340
|
|
|
|
|
Bank of America Corp.
|
|
|
1,605,339
|
|
|
|
0.6
|
|
|
|
|
23,700
|
|
|
@
|
|
Berkshire Hathaway, Inc.
|
|
|
2,068,536
|
|
|
|
0.8
|
|
|
|
|
25,242
|
|
|
|
|
Chevron Corp.
|
|
|
2,618,858
|
|
|
|
1.0
|
|
|
|
|
64,292
|
|
|
@
|
|
Cisco Systems, Inc.
|
|
|
1,193,260
|
|
|
|
0.5
|
|
|
|
|
358,600
|
|
|
@,S
|
|
Citigroup, Inc.
|
|
|
1,678,248
|
|
|
|
0.7
|
|
|
|
|
33,772
|
|
|
|
|
Coca-Cola Co.
|
|
|
2,158,706
|
|
|
|
0.9
|
|
|
|
|
17,700
|
|
|
|
|
ConocoPhillips
|
|
|
1,378,299
|
|
|
|
0.5
|
|
|
|
|
64,169
|
|
|
S
|
|
ExxonMobil Corp.
|
|
|
5,488,356
|
|
|
|
2.2
|
|
|
|
|
124,416
|
|
|
|
|
General Electric Co.
|
|
|
2,602,783
|
|
|
|
1.0
|
|
|
|
|
5,405
|
|
|
|
|
Goldman Sachs Group, Inc.
|
|
|
885,231
|
|
|
|
0.4
|
|
|
|
|
2,669
|
|
|
@
|
|
Google, Inc. Class A
|
|
|
1,637,165
|
|
|
|
0.7
|
|
|
|
|
21,609
|
|
|
|
|
Hewlett-Packard Co.
|
|
|
942,801
|
|
|
|
0.4
|
|
|
|
|
43,402
|
|
|
|
|
Intel Corp.
|
|
|
931,841
|
|
|
|
0.4
|
|
|
|
|
13,189
|
|
|
|
|
International Business Machines Corp.
|
|
|
2,135,035
|
|
|
|
0.8
|
|
|
|
|
31,575
|
|
|
|
|
Johnson & Johnson
|
|
|
1,939,968
|
|
|
|
0.8
|
|
|
|
|
43,657
|
|
|
|
|
JPMorgan Chase & Co.
|
|
|
2,038,345
|
|
|
|
0.8
|
|
|
|
|
12,600
|
|
|
|
|
McDonalds Corp.
|
|
|
953,568
|
|
|
|
0.4
|
|
|
|
|
34,427
|
|
|
|
|
Merck & Co., Inc.
|
|
|
1,121,287
|
|
|
|
0.4
|
|
|
|
|
80,162
|
|
|
|
|
Microsoft Corp.
|
|
|
2,130,706
|
|
|
|
0.8
|
|
|
|
|
9,600
|
|
|
|
|
Occidental Petroleum Corp.
|
|
|
978,912
|
|
|
|
0.4
|
|
|
|
|
39,775
|
|
|
|
|
Oracle Corp.
|
|
|
1,308,598
|
|
|
|
0.5
|
|
|
|
|
22,500
|
|
|
|
|
PepsiCo, Inc.
|
|
|
1,426,950
|
|
|
|
0.6
|
|
|
|
|
91,255
|
|
|
|
|
Pfizer, Inc.
|
|
|
1,755,746
|
|
|
|
0.7
|
|
|
|
|
21,550
|
|
|
|
|
Procter & Gamble Co.
|
|
|
1,358,728
|
|
|
|
0.5
|
|
|
|
|
17,805
|
|
|
|
|
Qualcomm, Inc.
|
|
|
1,060,822
|
|
|
|
0.4
|
|
|
|
|
20,705
|
|
|
|
|
Schlumberger Ltd.
|
|
|
1,934,261
|
|
|
|
0.8
|
|
|
|
|
13,233
|
|
|
|
|
United Technologies Corp.
|
|
|
1,105,485
|
|
|
|
0.4
|
|
|
|
|
40,855
|
|
|
S
|
|
Verizon Communications, Inc.
|
|
|
1,508,367
|
|
|
|
0.6
|
|
|
|
|
23,067
|
|
|
|
|
Wal-Mart Stores, Inc.
|
|
|
1,199,023
|
|
|
|
0.5
|
|
|
|
|
57,971
|
|
|
|
|
Wells Fargo & Co.
|
|
|
1,870,144
|
|
|
|
0.7
|
|
|
|
|
|
|
|
|
|
Other Securities
|
|
|
85,421,728
|
|
|
|
34.0
|
|
|
|
|
|
|
|
|
|
|
|
|
142,186,393
|
|
|
|
56.5
|
|
|
|
|
|
|
|
Total Common Stock
(Cost $223,781,253)
|
|
|
248,230,041
|
|
|
|
98.7
|
|
|
REAL ESTATE INVESTMENT TRUSTS: 1.4%
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Australia: 0.2%
|
|
|
|
|
|
|
Other Securities
|
|
|
469,270
|
|
|
|
0.2
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
France: 0.0%
|
|
|
|
|
|
|
Other Securities
|
|
|
56,810
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Hong Kong: 0.0%
|
|
|
|
|
|
|
Other Securities
|
|
|
137,457
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Japan: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
242,796
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Singapore: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
204,691
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
United Kingdom: 0.1%
|
|
|
|
|
|
|
Other Securities
|
|
|
249,321
|
|
|
|
0.1
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
United States: 0.9%
|
|
|
|
|
|
|
Other Securities
|
|
|
2,294,698
|
|
|
|
0.9
|
|
|
|
|
|
|
|
|
|
Total Real Estate Investment Trusts
(Cost $3,166,770)
|
|
|
3,655,043
|
|
|
|
1.4
|
|
|
PREFERRED STOCK: 0.4%
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Germany: 0.4%
|
|
|
|
|
|
|
Other Securities
|
|
|
927,695
|
|
|
|
0.4
|
|
|
|
|
|
|
|
|
|
Total Preferred Stock
(Cost $916,465)
|
|
|
927,695
|
|
|
|
0.4
|
|
|
RIGHTS: 0.0%
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Hong Kong: 0.0%
|
|
|
|
|
|
|
Other Securities
|
|
|
5,044
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Sweden: 0.0%
|
|
|
|
|
|
|
Other Securities
|
|
|
14
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
Total Rights
(Cost $-)
|
|
|
5,058
|
|
|
|
0.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Long-Term Investments
(Cost $227,864,488)
|
|
|
252,817,837
|
|
|
|
100.5
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
See Accompanying Notes to Financial
Statements
21
SUMMARY
PORTFOLIO OF INVESTMENTS
ING
Global Advantage and Premium
Opportunity Fund
as
of February 28, 2011 (continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percent
|
|
|
|
|
|
|
|
|
of Net
|
Shares
|
|
|
|
Value
|
|
Assets
|
|
|
|
SHORT-TERM INVESTMENTS: 1.0%
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Mutual Funds: 1.0%
|
|
2,383,000
|
|
|
|
|
Blackrock Liquidity Funds TempFund Portfolio
Class I
|
|
$
|
2,383,000
|
|
|
|
1.0
|
|
|
|
|
|
|
|
|
|
Total Short-Term Investments
(Cost $2,383,000)
|
|
|
2,383,000
|
|
|
|
1.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Investments in Securities
(Cost $230,247,488)*
|
|
$
|
255,200,837
|
|
|
|
101.5
|
|
|
|
|
|
|
|
Other Assets and Liabilities - Net
|
|
|
(3,655,360
|
)
|
|
|
(1.5
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Net Assets
|
|
$
|
251,545,477
|
|
|
|
100.0
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Other Securities represents issues not identified as
the top 50 holdings in terms of market value and issues or
issuers not exceeding 1% of net assets individually or in
aggregate respectively as of February 28, 2011.
|
|
|
|
|
|
The following footnotes apply to either the individual
securities noted or one or more of the securities aggregated and
listed as a single line item.
|
|
|
|
@
|
|
Non-income producing security
|
|
|
|
S
|
|
All or a portion of this security has been identified by the
Fund to cover future collateral requirements for applicable
futures, options, swaps, foreign currency contracts
and/or
when-issued or delayed-delivery securities.
|
|
|
|
*
|
|
Cost for federal income tax purposes is $233,155,845.
|
|
|
|
|
|
Net unrealized appreciation consists of:
|
|
|
|
|
|
Gross Unrealized Appreciation
|
|
$
|
28,234,761
|
|
Gross Unrealized Depreciation
|
|
|
(6,189,769
|
)
|
|
|
|
|
|
Net Unrealized Appreciation
|
|
$
|
22,044,992
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percentage of
|
Industry
|
|
Net Assets
|
|
|
Consumer Discretionary
|
|
|
9.9
|
%
|
Consumer Staples
|
|
|
9.5
|
|
Energy
|
|
|
12.2
|
|
Financials
|
|
|
19.6
|
|
Health Care
|
|
|
9.8
|
|
Industrials
|
|
|
12.4
|
|
Information Technology
|
|
|
11.8
|
|
Materials
|
|
|
6.0
|
|
Telecommunication Services
|
|
|
4.6
|
|
Utilities
|
|
|
4.7
|
|
Short-Term Investments
|
|
|
1.0
|
|
Other Assets and Liabilities Net
|
|
|
(1.5
|
)
|
|
|
|
|
|
Net Assets
|
|
|
100.0
|
%
|
|
|
|
|
|
Fair Value Measurements
The following is a summary of the fair valuations according to
the inputs used as of February 28, 2011 in valuing the
Funds assets and liabilities:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Quoted Prices
|
|
|
|
|
|
|
|
|
in Active Markets
|
|
Other
|
|
Significant
|
|
|
|
|
for Identical
|
|
Observable
|
|
Unobservable
|
|
Fair Value
|
|
|
Investments
|
|
Inputs#
|
|
Inputs
|
|
at
|
|
|
(Level 1)
|
|
(Level 2)
|
|
(Level 3)
|
|
2/28/2011
|
|
|
Asset Table
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Investments, at value
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Common Stock
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Australia
|
|
$
|
|
|
|
$
|
7,945,680
|
|
|
$
|
112,948
|
|
|
$
|
8,058,628
|
|
Austria
|
|
|
|
|
|
|
582,523
|
|
|
|
|
|
|
|
582,523
|
|
Barbados
|
|
|
239,148
|
|
|
|
|
|
|
|
|
|
|
|
239,148
|
|
Belgium
|
|
|
123
|
|
|
|
1,131,065
|
|
|
|
|
|
|
|
1,131,188
|
|
Bermuda
|
|
|
249,211
|
|
|
|
503,775
|
|
|
|
|
|
|
|
752,986
|
|
Denmark
|
|
|
|
|
|
|
780,183
|
|
|
|
|
|
|
|
780,183
|
|
Finland
|
|
|
|
|
|
|
3,172,093
|
|
|
|
|
|
|
|
3,172,093
|
|
France
|
|
|
|
|
|
|
7,363,494
|
|
|
|
|
|
|
|
7,363,494
|
|
Germany
|
|
|
3,053
|
|
|
|
9,288,147
|
|
|
|
|
|
|
|
9,291,200
|
|
Greece
|
|
|
|
|
|
|
378,923
|
|
|
|
|
|
|
|
378,923
|
|
Guernsey
|
|
|
|
|
|
|
156,996
|
|
|
|
|
|
|
|
156,996
|
|
Hong Kong
|
|
|
336,516
|
|
|
|
2,591,183
|
|
|
|
|
|
|
|
2,927,699
|
|
Ireland
|
|
|
158,550
|
|
|
|
89,429
|
|
|
|
|
|
|
|
247,979
|
|
Israel
|
|
|
|
|
|
|
815,053
|
|
|
|
|
|
|
|
815,053
|
|
Italy
|
|
|
|
|
|
|
3,124,621
|
|
|
|
|
|
|
|
3,124,621
|
|
Japan
|
|
|
|
|
|
|
23,559,979
|
|
|
|
|
|
|
|
23,559,979
|
|
Kazakhstan
|
|
|
|
|
|
|
185,783
|
|
|
|
|
|
|
|
185,783
|
|
Luxembourg
|
|
|
|
|
|
|
91,429
|
|
|
|
|
|
|
|
91,429
|
|
Macau
|
|
|
|
|
|
|
30,484
|
|
|
|
|
|
|
|
30,484
|
|
Malaysia
|
|
|
|
|
|
|
25,599
|
|
|
|
|
|
|
|
25,599
|
|
Mauritius
|
|
|
|
|
|
|
2,052
|
|
|
|
|
|
|
|
2,052
|
|
Mexico
|
|
|
|
|
|
|
163,147
|
|
|
|
|
|
|
|
163,147
|
|
Netherlands
|
|
|
|
|
|
|
5,024,006
|
|
|
|
|
|
|
|
5,024,006
|
|
New Zealand
|
|
|
|
|
|
|
208,245
|
|
|
|
|
|
|
|
208,245
|
|
See Accompanying Notes to Financial
Statements
22
SUMMARY
PORTFOLIO OF INVESTMENTS
ING
Global Advantage and Premium
Opportunity Fund
as
of February 28, 2011 (continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Quoted Prices
|
|
|
|
|
|
|
|
|
in Active Markets
|
|
Other
|
|
Significant
|
|
|
|
|
for Identical
|
|
Observable
|
|
Unobservable
|
|
Fair Value
|
|
|
Investments
|
|
Inputs#
|
|
Inputs
|
|
at
|
|
|
(Level 1)
|
|
(Level 2)
|
|
(Level 3)
|
|
2/28/2011
|
|
|
Norway
|
|
|
|
|
|
|
361,668
|
|
|
|
|
|
|
|
361,668
|
|
Portugal
|
|
|
|
|
|
|
812,294
|
|
|
|
|
|
|
|
812,294
|
|
Singapore
|
|
|
|
|
|
|
1,400,525
|
|
|
|
|
|
|
|
1,400,525
|
|
Spain
|
|
|
26,792
|
|
|
|
4,065,588
|
|
|
|
|
|
|
|
4,092,380
|
|
Sweden
|
|
|
|
|
|
|
4,867,246
|
|
|
|
|
|
|
|
4,867,246
|
|
Switzerland
|
|
|
227,700
|
|
|
|
6,503,214
|
|
|
|
|
|
|
|
6,730,914
|
|
United Kingdom
|
|
|
72,752
|
|
|
|
19,392,431
|
|
|
|
|
|
|
|
19,465,183
|
|
United States
|
|
|
142,186,393
|
|
|
|
|
|
|
|
|
|
|
|
142,186,393
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Common Stock
|
|
|
143,500,238
|
|
|
|
104,616,855
|
|
|
|
112,948
|
|
|
|
248,230,041
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Real Estate Investment Trusts
|
|
|
2,327,070
|
|
|
|
1,327,973
|
|
|
|
|
|
|
|
3,655,043
|
|
Preferred Stock
|
|
|
|
|
|
|
927,695
|
|
|
|
|
|
|
|
927,695
|
|
Rights
|
|
|
|
|
|
|
5,044
|
|
|
|
14
|
|
|
|
5,058
|
|
Short-Term Investments
|
|
|
2,383,000
|
|
|
|
|
|
|
|
|
|
|
|
2,383,000
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Investments, at value
|
|
$
|
148,210,308
|
|
|
$
|
106,877,567
|
|
|
$
|
112,962
|
|
|
$
|
255,200,837
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Other Financial Instruments+:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Forward foreign currency contracts
|
|
|
|
|
|
|
1,533
|
|
|
|
|
|
|
|
1,533
|
|
Futures
|
|
|
118,139
|
|
|
|
|
|
|
|
|
|
|
|
118,139
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Assets
|
|
$
|
148,328,447
|
|
|
$
|
106,879,100
|
|
|
$
|
112,962
|
|
|
$
|
255,320,509
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Liabilities Table
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Other Financial Instruments+:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Forward foreign currency contracts
|
|
$
|
|
|
|
$
|
(2,699,749
|
)
|
|
$
|
|
|
|
$
|
(2,699,749
|
)
|
Written options
|
|
|
|
|
|
|
(1,818,547
|
)
|
|
|
|
|
|
|
(1,818,547
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Liabilities
|
|
$
|
|
|
|
$
|
(4,518,296
|
)
|
|
$
|
|
|
|
$
|
(4,518,296
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
The following is a reconciliation of the fair valuations using
significant unobservable inputs (Level 3) for the
Funds assets and liabilities during the period ended
February 28, 2011:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Beginning
|
|
|
|
|
|
Accrued
|
|
Total
|
|
Total Unrealized
|
|
Transfers
|
|
Transfers
|
|
Ending
|
|
|
Balance
|
|
|
|
|
|
Discounts/
|
|
Realized
|
|
Appreciation/
|
|
Into
|
|
Out of
|
|
Balance
|
|
|
2/28/2010
|
|
Purchases
|
|
Sales
|
|
(Premiums)
|
|
Gain/(Loss)
|
|
(Depreciation)
|
|
Level 3
|
|
Level 3
|
|
2/28/2011
|
|
|
Asset Table
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Investments, at value
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Common Stock
|
|
$
|
|
|
|
$
|
74,895
|
|
|
$
|
(75,219
|
)
|
|
$
|
|
|
|
$
|
324
|
|
|
$
|
|
|
|
$
|
112,948
|
|
|
$
|
|
|
|
$
|
112,948
|
|
Rights
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
14
|
|
|
|
|
|
|
|
|
|
|
|
14
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Investments, at value
|
|
$
|
|
|
|
$
|
74,895
|
|
|
$
|
(75,219
|
)
|
|
$
|
|
|
|
$
|
324
|
|
|
$
|
14
|
|
|
$
|
112,948
|
|
|
$
|
|
|
|
$
|
112,962
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
As of February 28, 2011, the net change in unrealized
appreciation or depreciation on Level 3 investments still
held at year end and included in the change in net assets was
$14.
|
|
^
|
See Note 2, Significant Accounting Policies in
the Notes to Financial Statements for additional information.
|
+
|
Other Financial Instruments are derivatives not reflected in the
Summary Portfolio of Investments and may include open forward
foreign currency contracts, futures, swaps, and written options.
|
Forward foreign currency contracts and futures are reported at
their unrealized gain/loss at measurement date which represents
the amount due to/from the Fund. Swaps and written options are
reported at their market value at measurement date.
Transfers in or out of Level 3 represent either the
beginning value (for transfers in), or the ending value (for
transfers out) of any security or derivative instrument where a
change in the pricing level occurred from the beginning to the
end of the period. It is the policy of the Portfolio to
recognize transfers at the end of the reporting period.
There were no significant transfers into or out of Level 1
and 2 during the year ended February 28, 2011.
|
|
# |
The earlier close of the foreign markets gives rise to the
possibility that significant events, including broad market
moves, may have occurred in the interim and may materially
affect the value of those securities. To account for this, the
Portfolio may frequently value many of its foreign equity
securities using fair value prices based on third party vendor
modeling tools to the extent available. Accordingly, a
significant portion of the Portfolios investments are
categorized as Level 2 investments.
|
See Accompanying Notes to Financial
Statements
23
SUMMARY
PORTFOLIO OF INVESTMENTS
ING
Global Advantage and Premium
Opportunity Fund
as
of February 28, 2011 (continued)
At February 28, 2011 the following forward foreign currency
contracts were outstanding for the ING Global Advantage and
Premium Opportunity Fund:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Currency/
|
|
|
|
|
|
In
|
|
|
|
Unrealized
|
|
|
Contract
|
|
|
|
Settlement
|
|
Exchange
|
|
|
|
Appreciation
|
Counterparty
|
|
Amount
|
|
Buy/Sell
|
|
Date
|
|
For
|
|
Fair Value
|
|
(Depreciation)
|
|
|
JPMorgan Chase & Co.
|
|
EU Euro
EUR 80,000
|
|
|
BUY
|
|
|
|
4/28/11
|
|
|
$
|
108,783
|
|
|
$
|
110,316
|
|
|
$
|
1,533
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$
|
1,533
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
JPMorgan Chase & Co.
|
|
Australian Dollar
AUD 8,850,000
|
|
|
SELL
|
|
|
|
3/16/11
|
|
|
$
|
8,702,931
|
|
|
$
|
8,991,216
|
|
|
$
|
(288,285
|
)
|
The Bank of New York Mellon Corporation
|
|
EU Euro
EUR 1,300,000
|
|
|
SELL
|
|
|
|
3/16/11
|
|
|
|
1,767,111
|
|
|
|
1,793,549
|
|
|
|
(26,438
|
)
|
Brown Brothers Harriman & Co.
|
|
Swiss Franc
CHF 6,000,000
|
|
|
SELL
|
|
|
|
3/16/11
|
|
|
|
6,212,055
|
|
|
|
6,458,715
|
|
|
|
(246,660
|
)
|
Brown Brothers Harriman & Co.
|
|
British Pound
GBP 13,600,000
|
|
|
SELL
|
|
|
|
3/16/11
|
|
|
|
21,585,240
|
|
|
|
22,105,722
|
|
|
|
(520,482
|
)
|
Brown Brothers Harriman & Co.
|
|
Japanese Yen
JPY 60,000,000
|
|
|
SELL
|
|
|
|
3/16/11
|
|
|
|
721,585
|
|
|
|
733,529
|
|
|
|
(11,944
|
)
|
Citigroup, Inc.
|
|
EU Euro
EUR 27,400,000
|
|
|
SELL
|
|
|
|
3/16/11
|
|
|
|
36,649,774
|
|
|
|
37,802,491
|
|
|
|
(1,152,717
|
)
|
Citigroup, Inc.
|
|
Japanese Yen
JPY 1,810,000,000
|
|
|
SELL
|
|
|
|
3/16/11
|
|
|
|
21,674,908
|
|
|
|
22,128,131
|
|
|
|
(453,223
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$
|
(2,699,749
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
ING Global Advantage and Premium Opportunity Fund Open
Futures Contracts on February 28, 2011:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Number
|
|
Expiration
|
|
Notional
|
|
Unrealized
|
Contract Description
|
|
of Contracts
|
|
Date
|
|
Value
|
|
Appreciation
|
|
|
Long Contracts
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
E-Mini MSCI
EAFE Index
|
|
|
19
|
|
|
|
03/18/11
|
|
|
$
|
1,670,195
|
|
|
$
|
93,130
|
|
S&P 500
E-Mini
|
|
|
15
|
|
|
|
03/18/11
|
|
|
|
994,575
|
|
|
|
17,832
|
|
S&P 500
E-Mini
|
|
|
7
|
|
|
|
06/17/11
|
|
|
|
462,385
|
|
|
|
7,177
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$
|
3,127,155
|
|
|
$
|
118,139
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Written OTC Call Options
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
# of
|
|
|
|
|
|
Expiration
|
|
Strike
|
|
|
|
Premiums
|
|
Fair
|
Contracts
|
|
Counterparty
|
|
Description
|
|
Date
|
|
Price
|
|
|
|
Received
|
|
Value
|
|
|
|
2,550
|
|
|
Barclays Bank PLC
|
|
Dow Jones Euro Stoxx 50
|
|
03/02/11
|
|
2,999.980
|
|
EUR
|
|
$
|
216,632
|
|
|
$
|
(84,594
|
)
|
|
2,700
|
|
|
Goldman Sachs & Co.
|
|
Dow Jones Euro Stoxx 50
|
|
03/17/11
|
|
3,069.140
|
|
EUR
|
|
|
211,637
|
|
|
|
(85,069
|
)
|
|
1,200
|
|
|
Goldman Sachs & Co.
|
|
FTSE 100 Index
|
|
03/02/11
|
|
5,965.390
|
|
GBP
|
|
|
206,319
|
|
|
|
(85,369
|
)
|
|
1,200
|
|
|
Goldman Sachs & Co.
|
|
FTSE 100 Index
|
|
03/17/11
|
|
6,069.120
|
|
GBP
|
|
|
188,970
|
|
|
|
(77,610
|
)
|
|
94,000
|
|
|
UBS Warburg LLC
|
|
Nikkei 225 Index
|
|
03/02/11
|
|
10,436.576
|
|
JPY
|
|
|
203,141
|
|
|
|
(224,357
|
)
|
|
92,500
|
|
|
JPMorgan Chase & Co.
|
|
Nikkei 225 Index
|
|
03/17/11
|
|
10,842.060
|
|
JPY
|
|
|
198,517
|
|
|
|
(66,192
|
)
|
|
40,318
|
|
|
UBS Warburg LLC
|
|
S&P
500®
Index
|
|
03/02/11
|
|
1,307.100
|
|
USD
|
|
|
722,095
|
|
|
|
(843,398
|
)
|
|
36,555
|
|
|
UBS Warburg LLC
|
|
S&P
500®
Index
|
|
03/17/11
|
|
1,340.430
|
|
USD
|
|
|
661,492
|
|
|
|
(351,958
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$
|
2,608,803
|
|
|
$
|
(1,818,547
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
See Accompanying Notes to Financial
Statements
24
SUMMARY
PORTFOLIO OF INVESTMENTS
ING
Global Advantage and Premium
Opportunity Fund
as
of February 28, 2011 (continued)
A summary of derivative instruments by primary risk exposure
is outlined in the following tables.
The fair value of derivative instruments as of February 28,
2011 was as follows:
|
|
|
|
|
|
|
Derivatives not accounted for
|
|
|
|
|
as hedging instruments
|
|
Location on Statement of Assets and Liabilities
|
|
Fair Value
|
|
Asset Derivatives
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Foreign exchange contracts
|
|
Unrealized appreciation on forward foreign currency contracts
|
|
$
|
1,533
|
|
Equity contracts
|
|
Net Assets- Unrealized appreciation*
|
|
|
118,139
|
|
|
|
|
|
|
|
|
Total Asset Derivatives
|
|
|
|
$
|
119,672
|
|
|
|
|
|
|
|
|
Liability Derivatives
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Foreign exchange contracts
|
|
Unrealized depreciation on forward foreign currency contracts
|
|
$
|
2,699,749
|
|
Equity contracts
|
|
Written options, at fair value
|
|
|
1,818,547
|
|
|
|
|
|
|
|
|
Total Liability Derivatives
|
|
|
|
$
|
4,518,296
|
|
|
|
|
|
|
|
|
|
|
* |
Includes cumulative appreciation/depreciation of futures
contracts as reported in the table following the Summary
Portfolio of Investments.
|
The effect of derivative instruments on the Funds
Statement of Operations for the year ended February 28,
2011 was as follows:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Amount of Realized Gain or (Loss)
|
|
|
on Derivatives Recognized in Income
|
Derivatives not accounted for
|
|
Foreign currency related
|
|
|
|
Written
|
|
|
as hedging instruments
|
|
transactions*
|
|
Futures
|
|
options
|
|
Total
|
|
Equity contracts
|
|
$
|
|
|
|
$
|
640,816
|
|
|
$
|
(6,915,700
|
)
|
|
$
|
(6,274,884
|
)
|
Foreign exchange contracts
|
|
|
(3,357,539
|
)
|
|
|
|
|
|
|
|
|
|
|
(3,357,539
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total
|
|
$
|
(3,357,539
|
)
|
|
$
|
640,816
|
|
|
$
|
(6,915,700
|
)
|
|
$
|
(9,632,423
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Change in Unrealized
|
|
|
Appreciation or Depreciation
|
|
|
on Derivatives Recognized in Income
|
Derivatives not accounted for
|
|
Foreign currency related
|
|
|
|
Written
|
|
|
as hedging instruments
|
|
transactions*
|
|
Futures
|
|
options
|
|
Total
|
|
Equity contracts
|
|
$
|
|
|
|
$
|
98,956
|
|
|
$
|
(189,043
|
)
|
|
$
|
(90,087
|
)
|
Foreign exchange contracts
|
|
|
(3,028,966
|
)
|
|
|
|
|
|
|
|
|
|
|
(3,028,966
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total
|
|
$
|
(3,028,966
|
)
|
|
$
|
98,956
|
|
|
$
|
(189,043
|
)
|
|
$
|
(3,119,053
|
)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
* |
Amounts recognized for forward foreign currency contracts are
included in net realized gain (loss) on foreign currency related
transactions and net change in unrealized appreciation or
depreciation on foreign currency related transactions.
|
Supplemental Option Information (Unaudited)
|
|
|
Supplemental Call Option Statistics as of February 28,
2011
|
|
|
% of Total Net Assets against which calls written
|
|
68.10%
|
Average Days to Expiration at time written
|
|
28 days
|
Average Call Moneyness* at time written
|
|
ATM
|
Premium received for calls
|
|
$2,608,803
|
Value of calls
|
|
$(1,818,547)
|
|
|
* |
Moneyness is the term used to describe the
relationship between the price of the underlying asset and the
options exercise or strike price. For example, a call
(buy) option is considered
in-the-money
when the value of the underlying asset exceeds the strike price.
Conversely, a put (sell) option is considered
in-the-money
when its strike price exceeds the value of the underlying asset.
Options are characterized for the purpose of Moneyness as,
in-the-money
(ITM),
out-of-the-money
(OTM) or
at-the-money
(ATM), where the underlying asset value equals the
strike price.
|
See Accompanying Notes to Financial
Statements
25
Dividends paid during the year ended February 28, 2011 were
as follows:
|
|
|
|
|
|
|
|
|
Fund Name
|
|
Type
|
|
Per Share Amount
|
|
ING Global Advantage and Premium Opportunity Fund
|
|
|
NII
|
|
|
$
|
1.3770
|
|
NII Net investment income
Above figures may differ from those cited elsewhere in this
report due to differences in the calculation of income and gains
under U.S. generally accepted accounting principles (book)
purposes and Internal Revenue Service (tax) purposes.
Shareholders are strongly advised to consult their own tax
advisers with respect to the tax consequences of their
investments in the Fund. In January, shareholders, excluding
corporate shareholders, receive an IRS
1099-DIV
regarding the federal tax status of the dividends and
distributions they received in the calendar year.
26
The business and affairs of the Trust are managed under the
direction of the Trusts Board. A Trustee who is not an
interested person of the Trust, as defined in the 1940 Act, is
an independent trustee (Independent Trustee). The
Trustees and Officers of the Trust are listed below. The
Statement of Additional Information includes additional
information about trustees of the Trust and is available,
without charge, upon request at
(800) 992-0180.
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Number of
|
|
|
|
|
|
|
|
|
|
|
Funds
|
|
|
|
|
|
|
|
|
|
|
in Fund
|
|
|
|
|
Position(s)
|
|
Term of Office
|
|
|
|
Complex
|
|
|
|
|
Held with
|
|
and Length of
|
|
Principal Occupation(s)
|
|
Overseen
|
|
Other Board Positions
|
Name, Address and Age
|
|
the Trust
|
|
Time Served
(1)
|
|
During the Past 5 Years
|
|
by
Trustee(2)
|
|
Held by Trustee
|
|
Independent Trustees:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Colleen D. Baldwin
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 50
|
|
Trustee
|
|
October 2007 Present
|
|
President, Glantuam Partners, LLC, a business consulting firm
(January 2009 Present) and Consultant
(January 2005 Present).
|
|
133
|
|
None.
|
|
|
|
|
|
|
|
|
|
|
|
John V. Boyer
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 57
|
|
Trustee
|
|
July 2005 Present
|
|
President and Chief Executive Officer, Bechtler Arts Foundation,
an arts and education foundation (January 2008
Present). Formerly, Consultant (July 2007
February 2008); President and Chief Executive Officer,
Franklin and Eleanor Roosevelt Institute, a public policy
foundation (March 2006 July 2007); and
Executive Director, The Mark Twain House &
Museum(3)
(September 1989 March 2006).
|
|
133
|
|
None.
|
|
|
|
|
|
|
|
|
|
|
|
Patricia W. Chadwick
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 62
|
|
Trustee
|
|
January 2006 Present
|
|
Consultant and President, Ravengate Partners LLC, a consulting
firm that provides advice regarding financial markets and the
global economy (January 2000 Present).
|
|
133
|
|
Wisconsin Energy Corp. (June 2006 Present) and
The Royce Fund (December 2009 Present).
|
|
|
|
|
|
|
|
|
|
|
|
Peter S. Drotch
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 69
|
|
Trustee
|
|
October 2007 Present
|
|
Retired. Formerly, Partner, PricewaterhouseCoopers LLP, an
accounting firm, until July 2000.
|
|
133
|
|
First Marblehead Corporation (September 2003- Present).
|
|
|
|
|
|
|
|
|
|
|
|
J. Michael Earley
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 65
|
|
Trustee
|
|
July 2005 Present
|
|
Retired. Formerly, Banking President and Chief Executive
Officer, Bankers Trust Company, N.A., Des Moines
(June 1992 December 2008).
|
|
133
|
|
None.
|
|
|
|
|
|
|
|
|
|
|
|
Patrick W. Kenny
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 68
|
|
Trustee
|
|
July 2005 Present
|
|
Retired. Formerly, President and Chief Executive Officer,
International Insurance Society (June 2001
June 2009).
|
|
133
|
|
Assured Guaranty Ltd. (April 2004 Present).
|
|
|
|
|
|
|
|
|
|
|
|
Sheryl K. Pressler
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 60
|
|
Trustee
|
|
January 2006 Present
|
|
Consultant (May 2001 Present).
|
|
133
|
|
Stillwater Mining Company (May 2002 Present).
|
27
TRUSTEE
AND OFFICER INFORMATION
(Unaudited)
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Number of
|
|
|
|
|
|
|
|
|
|
|
Funds
|
|
|
|
|
|
|
|
|
|
|
in Fund
|
|
|
|
|
Position(s)
|
|
Term of Office
|
|
|
|
Complex
|
|
|
|
|
Held with
|
|
and Length of
|
|
Principal Occupation(s)
|
|
Overseen
|
|
Other Board Positions
|
Name, Address and Age
|
|
the Trust
|
|
Time Served
(1)
|
|
During the Past 5 Years
|
|
by
Trustee(2)
|
|
Held by Trustee
|
|
|
|
|
|
|
|
|
|
|
|
|
Roger B. Vincent
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 65
|
|
Trustee
|
|
July 2005 Present
|
|
President, Springwell Corporation, a corporate finance firm
(March 1989 Present).
|
|
133
|
|
UGI Corporation (February 2006 Present) and UGI
Utilities, Inc. (February 2006 Present).
|
|
|
|
|
|
|
|
|
|
|
|
Trustees who are Interested Persons:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Robert W.
Crispin(4)
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 64
|
|
Trustee
|
|
October 2007 Present
|
|
Retired. Formerly, Chairman and Chief Executive Officer, ING
Investment Management Co. (July 2001
December 2007).
|
|
133
|
|
Intact Financial Corporation (December 2004
Present) and PFM Group (November 2010 Present).
|
|
|
|
|
|
|
|
|
|
|
|
Shaun P.
Mathews(4)(5)
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 55
|
|
Trustee
|
|
June 2006 Present
|
|
President and Chief Executive Officer, ING Investments,
LLC(6)
(November 2006 Present). Formerly, Head of ING
Mutual Funds and Investment Products
(November 2004 November 2006).
|
|
171
|
|
ING Capital Corporation, LLC (December 2005
Present).
|
|
|
|
(1) |
|
The Board is divided into three
classes, with the term of one class expiring at each annual
meeting of the Fund. At each annual meeting, one class of
Trustees is elected to a three-year term and serves until their
successors are duly elected and qualified. The tenure of each
Trustee is subject to the Boards retirement policy, which
states that each duly elected or appointed Trustee who is not an
interested person of the Fund, as defined in the
1940 Act, as amended (Independent Trustees), shall
retire from service as a Trustee at the conclusion of the first
regularly scheduled meeting of the Board that is held after the
Trustee reaches the age of 72. A unanimous vote of the Board may
extend the retirement date of a Trustee for up to one year. An
extension may be permitted if the retirement would trigger a
requirement to hold a meeting of shareholders of the Fund under
applicable law, whether for purposes of appointing a successor
to the Trustee or if otherwise necessary under applicable law,
in which case the extension would apply until such time as the
shareholder meeting can be held or is no longer needed.
|
|
(2) |
|
For the purposes of this table,
Fund Complex means the following investment
companies: ING Asia Pacific High Dividend Equity Income Fund,
ING Emerging Markets High Dividend Equity Fund; ING Emerging
Markets Local Bond Fund; ING Equity Trust; ING Funds Trust; ING
Global Advantage and Premium Opportunity Fund; ING Global Equity
Dividend and Premium Opportunity Fund; ING Infrastructure,
Industrials, and Materials Fund; ING International High Dividend
Equity Income Fund; ING Investors Trust; ING Mayflower Trust;
ING Mutual Funds; ING Partners, Inc.; ING Prime Rate Trust; ING
Risk Managed Natural Resources Fund; ING Senior Income Fund; ING
Separate Portfolios Trust; ING Variable Insurance Trust; and ING
Variable Products Trust.
|
|
(3) |
|
Mr. Boyer held a seat on the
Board of Directors of The Mark Twain House & Museum
from September 1989 to November 2005. ING Groep N.V.
makes non-material, charitable contributions to The Mark Twain
House & Museum.
|
|
(4) |
|
Messrs. Mathews and Crispin
are deemed to be interested persons of the Fund as
defined in the 1940 Act because of their affiliation with ING
Groep, N.V., the parent corporation of the Investment Adviser,
ING Investments, LLC and the Distributor, ING Investments
Distributor, LLC.
|
|
(5) |
|
For Mr. Mathews, the
Fund Complex also includes the following investment
companies: ING Balanced Portfolio, Inc.; ING Intermediate Bond
Portfolio; ING Money Market Portfolio; ING Series Fund,
Inc.; ING Strategic Allocation Portfolios, Inc.; ING Variable
Funds; and ING Variable Portfolios, Inc.
|
|
(6) |
|
ING Investments, LLC was previously
named ING Pilgrim Investments, LLC. ING Pilgrim Investments, LLC
is the successor in interest to ING Pilgrim Investments, Inc.,
which was previously known as Pilgrim Investments, Inc. and
before it was known as Pilgrim America Investments, Inc.
|
28
TRUSTEE
AND OFFICER INFORMATION
(Unaudited)
(continued)
|
|
|
|
|
|
|
|
|
|
|
Term of Office
|
|
|
|
|
Position(s) Held
|
|
and Length of
|
|
Principal Occupation(s)
|
Name, Address and Age
|
|
with the Trust
|
|
Time
Served(1)
|
|
during the Past 5 Years
|
|
Shaun P. Mathews
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 55
|
|
President and Chief Executive Officer
|
|
November 2006 Present
|
|
President and Chief Executive Officer, ING Investments,
LLC(2)
(November 2006 Present). Formerly, Head of ING
Mutual Funds and Investment Products (November 2004
November 2006).
|
|
|
|
|
|
|
|
Michael J. Roland
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 52
|
|
Executive Vice President
Chief Compliance Officer
|
|
July 2005 Present
March 2011 Present
|
|
Chief Compliance Officer of the ING Funds, Directed Services
LLC(4)
and ING Investments,
LLC(2)
(March 2011 Present) and Executive Vice President
and Chief Operating Officer, ING Investments,
LLC(2)
and ING Funds Services,
LLC(3)
(January 2007 Present). Formerly, Executive Vice
President, Head of Product Management, ING Investments,
LLC(2)
and ING Funds Services,
LLC(3)
(January 2005 January 2007).
|
|
|
|
|
|
|
|
Stanley D. Vyner
230 Park Avenue
New York, New York 10169
Age: 60
|
|
Executive Vice President
Chief Investment Risk Officer
|
|
July 2005 Present
September 2009 Present
|
|
Executive Vice President, ING Investments,
LLC(2)
(July 2000 Present) and Chief Investment Risk
Officer, ING Investments,
LLC(2)
(January 2003 Present).
|
|
|
|
|
|
|
|
Todd Modic
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 43
|
|
Senior Vice President, Chief/Principal Financial Officer and
Assistant Secretary
|
|
July 2005 Present
|
|
Senior Vice President, ING Funds Services,
LLC(3)
(March 2005 Present).
|
|
|
|
|
|
|
|
Kimberly A. Anderson
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 46
|
|
Senior Vice President
|
|
July 2005 Present
|
|
Senior Vice President, ING Investments,
LLC(2)
(October 2003 Present).
|
|
|
|
|
|
|
|
Robert Terris
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 40
|
|
Senior Vice President
|
|
May 2006 Present
|
|
Senior Vice President, Head of Division Operations, ING Funds
Services,
LLC(3)
(May 2006 Present). Formerly, Vice President of
Administration, ING Funds Services,
LLC(3)
(October 2001 May 2006).
|
|
|
|
|
|
|
|
Robyn L. Ichilov
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 43
|
|
Vice President and Treasurer
|
|
July 2005 Present
|
|
Vice President and Treasurer, ING Funds Services,
LLC(3)
(November 1995 Present) and ING Investments,
LLC(2)
(August 1997 Present).
|
|
|
|
|
|
|
|
Lauren D. Bensinger
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 57
|
|
Vice President
|
|
July 2005 Present
|
|
Vice President, ING Investments,
LLC(2)
and ING Funds Services,
LLC(3)
(February 1996 Present); Director of Compliance, ING
Investments,
LLC(2)
(October 2004 Present); and Vice President and Money
Laundering Reporting Officer, ING Investments Distributor,
LLC(5)
(April 2010 Present); Formerly, Chief Compliance
Officer, ING Investments Distributor,
LLC(5)
(August 1995 April 2010).
|
|
|
|
|
|
|
|
William Evans
10 State House Square
Hartford, Connecticut 06103
Age: 38
|
|
Vice President
|
|
September 2007 Present
|
|
Senior Vice President (March 2010 Present) and Head
of Manager Research and Selection Group (April 2007
Present). Formerly, Vice President, U.S. Mutual Funds and
Investment Products (May 2005 April 2007).
|
|
|
|
|
|
|
|
Maria M. Anderson
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 52
|
|
Vice President
|
|
July 2005 Present
|
|
Vice President, ING Funds Services,
LLC(3)
(September 2004 Present).
|
|
|
|
|
|
|
|
Denise Lewis
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 47
|
|
Vice President
|
|
January 2007 Present
|
|
Vice President, ING Funds Services,
LLC(3)
(December 2006 Present). Formerly, Senior Vice
President, UMB Investment Services Group, LLC (November
2003 December 2006).
|
29
TRUSTEE
AND OFFICER INFORMATION
(Unaudited)
(continued)
|
|
|
|
|
|
|
|
|
|
|
Term of Office
|
|
|
|
|
Position(s) Held
|
|
and Length of
|
|
Principal Occupation(s)
|
Name, Address and Age
|
|
with the Trust
|
|
Time
Served(1)
|
|
during the Past 5 Years
|
|
|
|
|
|
|
|
|
Kimberly K. Springer
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 53
|
|
Vice President
|
|
March 2006 Present
|
|
Vice President, ING Investment Management ING Funds
(March 2010 Present); Vice President, ING Funds
Services,
LLC(3)
(March 2006 Present) and Managing Paralegal,
Registration Statements (June 2003 Present).
Formerly, Assistant Vice President, ING Funds Services,
LLC(3)
(August 2004 March 2006).
|
|
|
|
|
|
|
|
Craig Wheeler
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 41
|
|
Assistant Vice President
|
|
May 2008 Present
|
|
Assistant Vice President Director of Tax, ING Funds
Services,
LLC(3)
(March 2008 Present). Formerly, Tax Manager, ING
Funds Services,
LLC(3)
(March 2005 March 2008).
|
|
|
|
|
|
|
|
Huey P. Falgout, Jr.
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 47
|
|
Secretary
|
|
July 2005 Present
|
|
Senior Vice President and Chief Counsel, ING Investment
Management ING Funds (March 2010
Present). Formerly, Chief Counsel, ING Americas, U.S. Legal
Services (October 2003 March 2010).
|
|
|
|
|
|
|
|
Theresa K. Kelety
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 48
|
|
Assistant Secretary
|
|
July 2005 Present
|
|
Vice President and Senior Counsel, ING Investment
Management ING Funds (March 2010
Present). Formerly, Senior Counsel, ING Americas, U.S. Legal
Services (April 2008 March 2010) and Counsel, ING
Americas, U.S. Legal Services (April 2003 April
2008).
|
|
|
|
|
|
|
|
Paul Caldarelli
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 59
|
|
Assistant Secretary
|
|
June 2010 Present
|
|
Vice President and Senior Counsel, ING Investment
Management ING Funds (March 2010
Present). Formerly, Senior Counsel, ING Americas, U.S. Legal
Services (April 2008 March 2010) and Counsel, ING
Americas, U.S. Legal Services (May 2005 April 2008).
|
|
|
|
|
|
|
|
Kathleen Nichols
7337 East Doubletree Ranch Rd.
Suite 100
Scottsdale, Arizona 85258
Age: 35
|
|
Assistant Secretary
|
|
May 2008 Present
|
|
Vice President and Counsel, ING Investment
Management ING Funds (March 2010
Present). Formerly, Counsel, ING Americas, U.S. Legal Services
(February 2008 March 2010) and Associate, Ropes
& Gray LLP (September 2005 February 2008).
|
|
|
|
(1) |
|
The officers hold office until the
next annual meeting of the Trustees and until their successors
shall have been elected and qualified.
|
|
(2) |
|
ING Investments, LLC was previously
named ING Pilgrim Investments, LLC. ING Pilgrim Investments, LLC
is the successor in interest to ING Pilgrim Investments, Inc.,
which was previously known as Pilgrim Investments, Inc. and
before that was known as Pilgrim America Investments, Inc.
|
|
(3) |
|
ING Funds Services, LLC was
previously named ING Pilgrim Group, LLC. ING Pilgrim Group, LLC
is the successor in interest to ING Pilgrim Group, Inc., which
was previously known as Pilgrim Group, Inc. and before that was
known as Pilgrim America Group, Inc.
|
|
(4) |
|
Directed Services LLC is the
successor in interest to Directed Services, Inc.
|
|
(5) |
|
ING Investments Distributor, LLC
was previously named ING Funds Distributor, LLC. ING Funds
Distributor, LLC is the successor in interest to ING Funds
Distributor, Inc., which was previously known as ING Pilgrim
Securities, Inc., and before that, was known as Pilgrim
Securities, Inc., and before that was known as Pilgrim America
Securities, Inc.
|
30
Board
Consideration and Re-Approval of Investment Advisory and
Sub-Advisory
Contracts
Section 15(c) of the Investment Company Act of 1940, as
amended (the 1940 Act) provides that, after an
initial period, ING Global Advantage and Premium Opportunity
Funds (the Fund) existing investment advisory
and
sub-advisory
contracts will remain in effect only if the Board of Trustees
(the Board) of the Fund, including a majority of
Board members who have no direct or indirect interest in the
advisory and
sub-advisory
contracts, and who are not interested persons of the
Fund, as such term is defined under the 1940 Act (the
Independent Trustees), annually review and approve
them. Thus, at a meeting held on November 18, 2010, the
Board, including a majority of the Independent Trustees,
considered whether to renew the investment advisory contract
(the Advisory Contract) between ING Investments, LLC
(the Adviser) and the
sub-advisory
contract
(Sub-Advisory
Contract) with ING Investment Management Co., the
sub-adviser
to the Fund (the
Sub-Adviser).
The Independent Trustees also held separate meetings on October
21 and November 16, 2010 to consider the renewal of the
Advisory and
Sub-Advisory
Contracts. As a result, subsequent references herein to factors
considered and determinations made by the Independent Trustees
include, as applicable, factors considered and determinations
made on those earlier dates by the Independent Trustees.
At its November 18, 2010 meeting, the Board voted to renew
the Advisory and
Sub-Advisory
Contracts for the Fund. In reaching these decisions, the Board
took into account information furnished to it throughout the
year at regular meetings of the Board and the Boards
committees, as well as information prepared specifically in
connection with the annual renewal process. Determinations by
the Independent Trustees also took into account various factors
that they believed, in light of the legal advice furnished to
them by K&L Gates LLP (K&L Gates), their
independent legal counsel, and their own business judgment, to
be relevant. Further, while the advisory and
sub-advisory
contracts for all the Fund were considered at the same Board
meeting, the Trustees considered the Funds advisory and
sub-advisory
relationships separately.
Provided below is an overview of the Boards contract
approval process in general, as well as a discussion of certain
specific factors that the Board considered at its renewal
meeting. While the Board gave its attention to the information
furnished, at its request, that was most relevant to its
considerations, discussed below are a number of the primary
factors relevant to the Boards consideration as to whether
to renew the Advisory and
Sub-Advisory
Contracts for the one-year period ending November 30, 2011.
Each Board member may have accorded different weight to the
various factors in reaching his or her conclusions with respect
to the Funds advisory and
sub-advisory
arrangements.
Overview of the
Contract Renewal and Approval Process
Several years ago, the Independent Trustees instituted a revised
process by which they seek and consider relevant information
when they decide whether to approve new or existing advisory and
sub-advisory
arrangements for the investment companies in the ING Funds
complex under their jurisdiction, including the Funds
existing Advisory and
Sub-Advisory
Contracts. Among other actions, the Independent Trustees:
retained the services of independent consultants with experience
in the mutual fund industry to assist the Independent Trustees
in working with the personnel employed by the Adviser or its
affiliates who administer the Fund (Management) to
identify the types of information presented to the Board to
inform its deliberations with respect to advisory and
sub-advisory
relationships and to help evaluate that information; established
a specific format in which certain requested information is
provided to the Board; and determined the process for reviewing
such information in connection with advisory and
sub-advisory
contract renewals and approvals. The end result was an enhanced
process which is currently employed by the Independent Trustees
to review and analyze information in connection with their
annual renewal of the ING Funds advisory and
sub-advisory
contracts, as well as their review and approval of new advisory
relationships.
Since the current renewal and approval process was first
implemented, the Boards membership has changed
substantially through periodic retirements of some Trustees and
the appointment and election of new Trustees. In addition,
throughout this period the Independent Trustees have reviewed
and refined the renewal and approval process at least annually.
The Board also established a Contracts Committee and two
Investment Review Committees. Among other matters, the Contracts
Committee provides oversight with
31
ADVISORY
CONTRACT APPROVAL DISCUSSION
(Unaudited)
(continued)
respect to the contracts renewal and approval process, and the
Investment Review Committees jointly provide oversight
regarding, among other matters, investment performance. The
Investment Review Committees may apply a heightened level of
scrutiny in cases where performance has lagged an ING
Funds relevant benchmark
and/or
selected peer group of investment companies (Selected Peer
Groups).
The type and format of the information provided to the Board or
to legal counsel for the Independent Trustees in connection with
the contract approval and renewal process has been codified in
the ING Funds 15(c) Methodology Guide. This
Guide was developed under the direction of the
Independent Trustees and sets out a blueprint pursuant to which
the Independent Trustees request certain information that they
deem important to facilitate an informed review in connection
with initial and annual approvals of advisory and
sub-advisory
contracts.
Management provides certain of the information requested by the
15(c) Methodology Guide in Fund Analysis and
Comparison Tables (FACT sheets) prior to the
Independent Trustees review of advisory and
sub-advisory
arrangements (including the Funds Advisory and
Sub-Advisory
Contracts). The Independent Trustees previously retained an
independent firm to verify and test the accuracy of certain FACT
sheet data for a representative sample of funds in the ING Funds
complex. In addition, in recent years the Contracts Committee
employed the services of an independent consultant to assist in
its review and analysis of, among other matters, the 15(c)
Methodology Guide, the content and format of the FACT
sheets, and Selected Peer Groups to be used by the Fund for
certain comparison purposes during the renewal process. As part
of an ongoing process, the Contracts Committee recommends or
considers recommendations from Management for refinements to the
15(c) Methodology Guide and other aspects of the review
process, and the Boards Investment Review Committees
review benchmarks used to assess the performance of funds in the
ING Funds complex.
The Board employed its process for reviewing contracts when
considering the renewals of the Funds Advisory and
Sub-Advisory
Contracts that would be effective through November 30,
2011. Set forth below is a discussion of many of the
Boards primary considerations and conclusions resulting
from this process.
Nature, Extent
and Quality of Service
In determining whether to approve the Advisory and
Sub-Advisory
Contracts for the Fund for the year ending November 30,
2011, the Independent Trustees received and evaluated such
information as they deemed necessary regarding the nature,
extent and quality of services provided to the Fund by the
Adviser and
Sub-Adviser.
This included information regarding the Adviser and
Sub-Adviser
provided throughout the year at regular meetings of the Board
and its committees, as well as information furnished in
connection with the contract renewal meetings.
The materials requested by and provided to the Board
and/or to
K&L Gates prior to the November 18, 2010 Board meeting
included, among other information, the following items for the
Fund: (1) FACT sheets that provided information regarding
the performance and expenses of the Fund and other similarly
managed funds in its Selected Peer Group, as well as information
regarding the Funds investment portfolio, objective and
strategies; (2) reports providing risk and attribution
analyses of the Fund; (3) the 15(c) Methodology
Guide, which describes how the FACT sheets were prepared,
including the manner in which the Funds benchmark and
Selected Peer Group were selected and how profitability was
determined; (4) responses from the Adviser and
Sub-Adviser
to a series of questions posed by K&L Gates on behalf of
the Independent Trustees; (5) copies of the forms of
Advisory and
Sub-Advisory
Contracts; (6) copies of the Forms ADV for the Adviser
and
Sub-Adviser;
(7) financial statements for the Adviser and
Sub-Adviser;
(8) a draft of a narrative summary addressing key factors
the Board customarily considers in evaluating the renewals of
the ING Funds (including the Funds) advisory
contracts and
sub-advisory
contracts, including a written analysis for the Fund of how
performance, fees and expenses compare to its Selected Peer
Group and/or
designated benchmark; (9) independent analyses of Fund
performance by the Funds Chief Investment Risk Officer;
(10) information regarding net asset flows into and out of
the Fund; and (11) other information relevant to the
Boards evaluations.
The Funds common shares were used for purposes of certain
comparisons to the funds in its Selected Peer Group. Common
shares were selected because they are the only Fund class issued
and outstanding. The
32
ADVISORY
CONTRACT APPROVAL DISCUSSION
(Unaudited)
(continued)
common shares were compared to the analogous class of shares for
each fund in the Selected Peer Group. The mutual funds included
in the Funds Selected Peer Group were selected based upon
criteria designed to mirror the Fund share class being compared
to the Selected Peer Group.
In arriving at its conclusions with respect to the Advisory
Contract, the Board was mindful of the
manager-of-managers
platform of the ING Funds that has been developed by Management.
The Board also considered the techniques that the Adviser has
developed to screen and perform due diligence on the
sub-advisers
that are recommended to the Board to manage the investment
portfolios of the funds in the ING Funds complex. The Board
noted the resources that the Adviser has committed to the Board
and the Investment Review Committees to assist the Board and the
Investment Review Committees with their assessment of the
investment performance of the funds in the ING Funds complex
(including the Fund) on an on-going basis throughout the year.
This includes the appointment of a Chief Investment Risk Officer
and his staff, who report directly to the Board and who have
developed attribution analyses and other metrics used by the
Boards Investment Review Committees to analyze the key
factors underlying investment performance for the funds in the
ING Funds complex.
The Board also noted the techniques used by the Adviser to
monitor the performance of the
Sub-Adviser
and the proactive approach that the Adviser, working in
cooperation with the Investment Review Committees, has taken to
advocate or recommend, when it believed appropriate, changes
designed to assist in improving the Funds performance.
In considering the Funds Advisory Contract, the Board also
considered the extent of benefits provided to the Funds
shareholders, beyond advisory services, from being part of the
ING family of funds. The Board also took into account the
Advisers efforts in recent years to reduce the expenses of
the ING Funds through renegotiated arrangements with the ING
Funds service providers. In addition, the Board considered
the efforts of the Adviser and the expenses that it incurred in
recent years to help make the ING Funds complex more efficient
by combinations of similar funds.
Further, the Board received periodic reports showing that the
investment policies and restrictions for the Fund were
consistently complied with and other periodic reports covering
matters such as compliance by Adviser and
Sub-Adviser
personnel with codes of ethics. The Board considered reports
from the Funds Chief Compliance Officer (CCO)
evaluating whether the regulatory compliance systems and
procedures of the Adviser and
Sub-Adviser
are reasonably designed to assure compliance with the federal
securities laws, including those related to, among others, late
trading and market timing, best execution, fair value pricing,
proxy voting and trade allocation practices. The Board also took
into account the CCOs annual and periodic reports and
recommendations with respect to service provider compliance
programs. In this regard, the Board also considered the policies
and procedures developed by the CCO in consultation with the
Boards Compliance Committee that guide the CCOs
compliance oversight function.
The Board reviewed the level of staffing, quality and experience
of the Funds portfolio management team. The Board took
into account the respective resources and reputations of the
Adviser and
Sub-Adviser,
and evaluated the ability of the Adviser and the
Sub-Adviser
to attract and retain qualified investment advisory personnel.
The Board also considered the adequacy of the resources
committed to the Fund (and other relevant funds in the ING Funds
complex) by the Adviser and
Sub-Adviser,
and whether those resources are commensurate with the needs of
the Fund and are sufficient to sustain appropriate levels of
performance and compliance needs. In this regard, the Board
considered the financial stability of the Adviser and the
Sub-Adviser.
Based on their deliberations and the materials presented to
them, the Board concluded that the advisory and related services
provided by the Adviser and
Sub-Adviser
are appropriate in light of the Funds operations, the
competitive landscape of the investment company business, and
investor needs, and that the nature and quality of the overall
services provided by the Adviser and the
Sub-Adviser
were appropriate.
Fund Performance
In assessing advisory and
sub-advisory
relationships, the Board placed emphasis on the net investment
returns of the Fund. While the Board considered the performance
reports and discussions with portfolio managers at Board and
committee meetings during the year, particular attention in
assessing performance was given to the FACT sheets furnished in
connection
33
ADVISORY
CONTRACT APPROVAL DISCUSSION
(Unaudited)
(continued)
with the renewal process. The FACT sheet prepared for the Fund
included its investment performance compared to the Funds
Morningstar category median
and/or
Lipper category median, Selected Peer Group and primary
reference index. The FACT sheet performance data was as of
June 30, 2010. In addition, the Board also considered at
its November 18, 2010 meeting certain additional data
regarding performance and Fund asset level as of
September 30, 2010.
The Funds performance was compared to its Morningstar
category median and its primary reference index, a broad-based
securities market index that appears in the Funds
prospectus. With respect to Morningstar quintile rankings, the
first quintile represents the highest (best) performance and the
fifth quintile represents the lowest performance.
In considering whether to approve the renewal of the Advisory
and
Sub-Advisory
Contracts for the Fund, the Board considered that, based on
performance data for the periods ended June 30, 2010:
(1) the Fund outperformed its Morningstar category median
for all periods presented; (2) the Fund outperformed its
primary reference index for all periods presented, with the
exception of the one-year period, during which it
underperformed; and (3) the Fund is ranked in the first
(highest) quintile of its Morningstar category for the most
recent calendar quarter and
year-to-date
periods, the second quintile for the three-year period, and the
third quintile for the one-year period.
Economies of
Scale
When evaluating the reasonableness of advisory fee rates, the
Board also considered whether economies of scale will be
realized by the Adviser if the Fund grows larger and the extent
to which any such economies are reflected in contractual fee
rates. In this regard, the Board considered the compensation
under an Advisory Contract with a level advisory fee rate that
does not include breakpoints, taking into account that the Fund
is a closed-end fund. The Board also considered the extent to
which economies of scale could be realized through waivers,
reimbursements or expense reductions. In evaluating fee
breakpoint arrangements and economies of scale, the Independent
Trustees also considered prior periodic management reports and
industry information on this topic.
Information
Regarding Services to Other Clients
The Board requested and considered information regarding the
nature of services and fee rates offered by the Adviser and
Sub-Adviser
to other clients, including other registered investment
companies and institutional accounts. When fee rates offered to
other clients differed materially from those charged to the
Fund, the Board considered any underlying rationale provided by
the Adviser or a
Sub-Adviser
for these differences. The Board also noted that the fee rates
charged to the Fund and other institutional clients of the
Adviser or
Sub-Adviser
(including other investment companies) may differ materially due
to, among other reasons: differences in services; different
regulatory requirements associated with registered investment
companies, such as the Fund, as compared to non-registered
investment company clients; market differences in fee rates that
existed when the Fund first was organized; differences in the
original sponsors of Fund that now are managed by the Adviser;
investment capacity constraints that existed when certain
contracts were first agreed upon or that might exist at present;
and different pricing structures that are necessary to be
competitive in different marketing channels.
Fee Rates and
Profitability
The Board reviewed and considered the contractual investment
advisory fee rate payable by the Fund to the Adviser. The Board
also considered the contractual
sub-advisory
fee rate payable by the Adviser to the
Sub-Adviser
for
sub-advisory
services for the Fund. In addition, the Board considered fee
waivers and expense limitations applicable to the fees payable
by the Fund.
The Board considered: (1) the fee structure of the Fund as
it relates to the services provided under the contracts; and
(2) the potential fall-out benefits to the Adviser and the
Sub-Adviser
and their respective affiliates from their association with the
Fund.
In considering the fees payable under the Advisory and
Sub-Advisory
Contracts for the Fund, the Board took into account the factors
described above and also considered: (1) the fairness of
the compensation under an Advisory Contract with a level fee
rate that does not include breakpoints; and (2) the pricing
structure (including the expense ratio to be borne by
shareholders) of the Fund, as compared to its Selected Peer
Group, including that: (a) the management fee
34
ADVISORY
CONTRACT APPROVAL DISCUSSION
(Unaudited)
(continued)
(inclusive of a 0.10% administration fee) for the Fund is below
the median and the average management fees of the funds in its
Selected Peer Group; and (b) the expense ratio for the Fund
is below the median and the average expense ratios of the funds
in its Selected Peer Group.
In analyzing this fee data, the Board took into account
Managements representations that closed-end funds have
unique distribution characteristics and their pricing structures
are highly driven by the market and competitive environment at
the time of their initial offering when their fee structures
were established.
The Board considered information on revenues, costs and profits
realized by the Adviser, which was prepared by Management in
accordance with the allocation methodology (including related
assumptions) specified in the 15(c) Methodology Guide. In
analyzing the profitability of the Adviser in connection with
its services to the Fund, the Board took into account the
sub-advisory
fee rate payable by the Adviser to the
Sub-Adviser.
In addition, the Board considered information that it requested
and was provided by Management with respect to the profitability
of service providers affiliated with the Adviser and
Sub-Adviser.
The Board recognized that profitability analysis is not an exact
science and there is no uniform methodology for determining
profitability for this purpose. In this context, the Board
realized that Managements calculations regarding its costs
incurred in establishing the infrastructure necessary for the
Funds operations may not be fully reflected in the
expenses allocated to the Fund in determining profitability, and
that the information presented may not portray all of the costs
borne by Management or capture Managements entrepreneurial
risk associated with offering and managing a mutual fund complex
in the current regulatory and market environment. In addition,
the Board recognized that the use of different methodologies for
purposes of calculating profit data can give rise to
dramatically different profit and loss results.
In making its determinations, the Board based its conclusions on
the reasonableness of the advisory fee of the Adviser. The Board
determined that the fees payable to the Adviser and the
Sub-Adviser
are reasonable for the services that each performs, which were
considered in light of the nature and quality of the services
that each has performed and is expected to perform.
Conclusion
After its deliberation, the Board reached the following
conclusions: (1) the Funds management fee rate is
reasonable in the context of all factors considered by the
Board; (2) the Funds expense ratio is reasonable in
the context of all factors considered by the Board; (3) the
Funds performance is reasonable in the context of all
factors considered by the Board; and (4) the
sub-advisory
fee rate payable by the Adviser to the
Sub-Adviser
is reasonable in the context of all factors considered by the
Board. Based on these conclusions and other factors, the Board
voted to renew the Advisory and
Sub-Advisory
Contracts for the Fund for the year ending November 30,
2011. During this renewal process, different Board members may
have given different weight to different individual factors and
related conclusions.
35
A special meeting of shareholders of the ING Global Advantage
and Premium Opportunity Fund was held June 24, 2010, at the
offices of ING Funds, 7337 East Doubletree Ranch Road,
Scottsdale, AZ 85258.
Proposal:
To elect three members of the Board of Trustees to represent the
interests of the holders of Common Shares of the Fund, with all
three individuals to serve as Class II Trustees, for a term
of three-years, and until the election and qualification of
their successors.
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares
|
|
|
|
|
|
|
|
|
|
|
voted
|
|
|
|
|
|
|
|
|
Shares
|
|
against
|
|
|
|
Total
|
|
|
|
|
voted
|
|
or
|
|
Shares
|
|
Shares
|
|
|
Proposal*
|
|
for
|
|
withheld
|
|
abstained
|
|
Voted
|
|
Class II Trustees
|
|
John V. Boyer
|
|
|
13,373,419.738
|
|
|
|
222,592.445
|
|
|
|
|
|
|
|
13,596,012.183
|
|
|
|
Patricia W. Chadwick
|
|
|
13,360,056.914
|
|
|
|
235,955.269
|
|
|
|
|
|
|
|
13,596,012.183
|
|
|
|
Sheryl K. Pressler
|
|
|
13,364,026.135
|
|
|
|
231,986.048
|
|
|
|
|
|
|
|
13,596,012.183
|
|
36
During the period, there were no material changes in the
Funds investment objective or policies that were not
approved by the shareholders or the Funds charter or
by-laws or
in the principal risk factors associated with investment in the
Fund. Effective January 1, 2011, Bas Peeters is no longer
responsible for the day-to-day management of the Funds
portfolio.
Dividend
Reinvestment Plan
Unless the registered owner of Common Shares elects to receive
cash by contacting BNY (the Plan Agent), all
dividends declared on Common Shares of the Fund will be
automatically reinvested by the Plan Agent for shareholders in
additional Common Shares of the Fund through the Funds
Dividend Reinvestment Plan (the Plan). Shareholders
who elect not to participate in the Plan will receive all
dividends and other distributions in cash paid by check mailed
directly to the shareholder of record (or, if the Common Shares
are held in street or other nominee name, then to such nominee)
by the Plan Agent. Participation in the Plan is completely
voluntary and may be terminated or resumed at any time without
penalty by notice if received and processed by the Plan Agent
prior to the dividend record date; otherwise such termination or
resumption will be effective with respect to any subsequently
declared dividend or other distribution. Some brokers may
automatically elect to receive cash on your behalf and may
re-invest that cash in additional Common Shares of the Fund for
you. If you wish for all dividends declared on your Common
Shares of the Fund to be automatically reinvested pursuant to
the Plan, please contact your broker.
The Plan Agent will open an account for each Common Shareholder
under the Plan in the same name in which such Common
Shareholders Common Shares are registered. Whenever the
Fund declares a dividend or other distribution (together, a
Dividend) payable in cash,
non-participants
in the Plan will receive cash and participants in the Plan will
receive the equivalent in Common Shares. The Common Shares will
be acquired by the Plan Agent for the participants
accounts, depending upon the circumstances described below,
either (i) through receipt of additional unissued but
authorized Common Shares from the Fund (Newly Issued
Common Shares) or (ii) by purchase of outstanding
Common Shares on the open market (Open-Market
Purchases) on the NYSE or elsewhere. Open-market purchases
and sales are usually made through a broker affiliated with the
Plan Agent.
If, on the payment date for any Dividend, the closing market
price plus estimated brokerage commissions per Common Share is
equal to or greater than the net asset value per Common Share,
the Plan Agent will invest the Dividend amount in Newly Issued
Common Shares on behalf of the participants. The number of Newly
Issued Common Shares to be credited to each participants
account will be determined by dividing the dollar amount of the
Dividend by the net asset value per Common Share on the payment
date; provided that, if the net asset value is less than or
equal to 95% of the closing market value on the payment date,
the dollar amount of the Dividend will be divided by 95% of the
closing market price per Common Share on the payment date. If,
on the payment date for any Dividend, the net asset value per
Common Share is greater than the closing market value plus
estimated brokerage commissions, the Plan Agent will invest the
Dividend amount in Common Shares acquired on behalf of the
participants in Open-Market Purchases. In the event of a market
discount on the payment date for any Dividend, the Plan Agent
will have until the last business day before the next date on
which the Common Shares trade on an
ex-dividend
basis or 30 days after the payment date for such Dividend,
whichever is sooner (the Last Purchase Date), to
invest the Dividend amount in Common Shares acquired in
Open-Market Purchases.
It is contemplated that the Fund will pay quarterly Dividends.
Therefore, the period during which Open-Market Purchases can be
made will exist only from the payment date of each Dividend
through the date before the next
ex-dividend
date, which typically will be approximately ten days.
If, before the Plan Agent has completed its Open-Market
Purchases, the market price per common share exceeds the net
asset value per Common Share, the average per Common Share
purchase price paid by the Plan Administrator may exceed the net
asset value of the Common Shares, resulting in the acquisition
of fewer Common Shares than if the Dividend had been paid in
Newly Issued Common Shares on the Dividend payment date. Because
of the foregoing difficulty with respect to Open-Market
Purchases, the Plan provides that if the Plan Agent is unable to
invest the full Dividend amount in Open-Market Purchases during
the purchase period or if the market discount shifts to a market
premium during the purchase period, the Plan Agent will cease
making Open-Market Purchases and will invest the
un-invested
portion of the Dividend amount in Newly Issued Common Shares at
the net
37
ADDITIONAL
INFORMATION (Unaudited)
(continued)
asset value per common share at the close of business on the
Last Purchase Date provided that, if the net asset value is less
than or equal to 95% of the then current market price per Common
Share, the dollar amount of the Dividend will be divided by 95%
of the market price on the payment date.
The Plan Agent maintains all shareholders accounts in the
Plan and furnishes written confirmation of all transactions in
the accounts, including information needed by shareholders for
tax records. Common Shares in the account of each Plan
participant will be held by the Plan Agent on behalf of the Plan
participant, and each shareholder proxy will include those
shares purchased or received pursuant to the Plan. The Plan
Agent will forward all proxy solicitation materials to
participants and vote proxies for shares held under the Plan in
accordance with the instructions of the participants.
In the case of shareholders such as banks, brokers or nominees
which hold shares for others who are the beneficial owners, the
Plan Agent will administer the Plan on the basis of the number
of Common Shares certified from time to time by the record
shareholders name and held for the account of beneficial
owners who participate in the Plan.
There will be no brokerage charges with respect to Common Shares
issued directly by the Fund. However, each participant will pay
a pro rata share of brokerage commissions incurred in connection
with Open-Market Purchases. The automatic reinvestment of
Dividends will not relieve participants of any federal, state or
local income tax that may be payable (or required to be
withheld) on such Dividends. Participants that request a partial
or full sale of shares through the Plan Agent are subject to a
$15.00 sales fee and a $0.10 per share brokerage
commission on purchases or sales, and may be subject to certain
other service charges.
The Fund reserves the right to amend or terminate the Plan.
There is no direct service charge to participants with regard to
purchases in the Plan; however, the Fund reserves the right to
amend the Plan to include a service charge payable by the
participants.
All questions concerning the Plan should be directed to the
Funds Shareholder Service Department at
(800) 992-0180.
KEY FINANCIAL
DATES CALENDAR 2010 DISTRIBUTIONS:
|
|
|
|
|
DECLARATION
|
|
EX-DIVIDEND
|
|
PAYABLE
|
DATE
|
|
DATE
|
|
DATE
|
|
March 15, 2011
|
|
April 1, 2011
|
|
April 15, 2011
|
June 15, 2011
|
|
July 1, 2011
|
|
July 15, 2011
|
September 15, 2011
|
|
October 3, 2011
|
|
October 17, 2011
|
December 15, 2011
|
|
December 28, 2011
|
|
January 16, 2012
|
Record date will be two business days after each
Ex-Dividend
Date. These dates are subject to change.
Stock
Data
The Funds common shares are traded on the NYSE
(Symbol: IGA).
Repurchase of
Securities by Closed-End Companies
In accordance with Section 23(c) of the 1940 Act, and
Rule 23c-1
under the 1940 Act the Fund may from time to time purchase
shares of beneficial interest of the Fund in the open market, in
privately negotiated transactions and/or purchase shares to
correct erroneous transactions.
Number of
Shareholders
The approximate number of record holders of Common Stock as of
February 28, 2011 was 13,225, which does not include
beneficial owners of shares held in the name of brokers of other
nominees.
Certifications
In accordance with Section 303A.12 (a) of the New York
Stock Exchange Listed Company Manual, the Funds CEO
submitted the Annual CEO Certification on May 28, 2010
certifying that he was not aware, as of that date, of any
violation by the Fund of the NYSEs Corporate governance
listing standards. In addition, as required by Section 302
of the Sarbanes-Oxley Act of 2002 and related SEC rules,
the Funds principal executive and financial officers have
made quarterly certifications, included in filings with the SEC
on
Forms N-CSR
and N-Q,
relating to, among other things, the Funds disclosure
controls and procedures and internal controls over financial
reporting.
38
Investment Adviser
ING Investments, LLC
7337 East Doubletree Ranch Road,
Suite 100
Scottsdale, Arizona 85258
Administrator
ING Funds Services, LLC
7337 East Doubletree Ranch Road,
Suite 100
Scottsdale, Arizona 85258
Transfer Agent
BNY Mellon Shareowner Services
480 Washington Boulevard
Jersey City, NJ 07310-1900
Independent
Registered Public Accounting Firm
KPMG LLP
Two Financial Center
60 South Street
Boston, Massachusetts 02111
Custodian
The Bank of New York Mellon
One Wall Street
New York, New York 10286
Legal Counsel
Dechert LLP
1775 I Street, N.W.
Washington, D.C. 20006
Toll-Free
Shareholder Information
Call us from 9:00 a.m. to
7:00 p.m. Eastern time on any business day for account or
other information, at (800) 992-0180
Item 2. Code of Ethics.
As of the end of the period covered by this report, Registrant had adopted a code of ethics, as
defined in Item 2 of Form N-CSR, that applies to the Registrants principal executive officer and
principal financial officer. There were no amendments to the Code during the period covered by the
report. The Registrant did not grant any waivers, including implicit waivers, from any provisions
of the Code during the period covered by this report. The code of ethics is filed
herewith pursuant
to Item 10(a)(l), Exhibit 99,CODE ETH.
Item 3. Audit Committee Financial Expert.
The Board
of Trustees has determined that J. Michael Earley and Peter S. Drotch
are audit committee financial experts,
as defined in Item 3 of Form N-CSR. Mr. Earley and Mr.
Drotch are independent for purposes of Item 3 of Form
N-CSR.
Item 4. Principal Accountant Fees and Services.
(a) |
|
Audit Fees: The aggregate fees billed for each of the last two fiscal years for
professional services rendered by KPMG LLP (KPMG), the principal accountant for the audit of
the registrants annual financial statements, for services that are normally provided by the
accountant in connection with statutory and regulatory filings or engagements for the fiscal
year were $24,500 for the year ended February 28, 2011 and
$22,000 for year ended February 28, 2010. |
|
(b) |
|
Audit-Related Fees: The aggregate fees billed in each of the last two fiscal
years for assurance and related services by KPMG that are seasonably related to the
performance of the audit of the registrants financial statements and are not reported under
paragraph (a) of this Item were $2,150 for the year ended
February 28, 2011 and $2,150 for the
year ended February 28, 2010. |
|
(c) |
|
Tax Fees: The aggregate fees billed in each of the last two fiscal years for
professional services rendered by KPMG for tax compliance, tax advice, and tax planning were
$7,648 in the year ended February 28, 2011 and $6,550 in the year
ended February 28, 2010.
Such services included review of excise distribution calculations (if applicable),
preparation of the Funds federal state and excise tax returns, tax services related to
mergers and routine consulting. |
|
(d) |
|
All Other Fees: The aggregate fees billed in each of
the last two fiscal years for all other fees were $2,500 for the year
ended February 28, 2011 and $5,000 for the year ended February 28, 2010. |
|
(e)(1) |
|
Audit Committee Pre-Approval Policies and Procedures |
AUDIT AND NON-AUDIT SERVICES
PRE-APPROVAL POLICY
I. Statement of Principles
Under the Sarbanes-Oxley Act of 2002 (the Act), the Audit Committee of the Board of Directors or
Trustees (the Committee) of the ING Funds (each a Fund, collectively, the Funds) set out on
Exhibit A to this Audit and Non-Audit Services Pre-Approval Policy (Policy) is
responsible for the oversight of the work of the Funds independent auditors. As part of its
responsibilities, the Committee must pre-approve the audit and non-audit services performed by the
auditors in order to assure that the provision of these services does not impair the auditors
independence from the Funds. The Committee has adopted, and the Board has ratified, this Policy,
which sets out the procedures and conditions under which the services of the independent auditors
may be pre-approved.
Under Securities and Exchange Commission (SEC) rules promulgated in accordance with the Act, the
Funds may establish two different approaches to pre-approving audit and non-audit services. The
Committee may approve services without consideration of specific case-by-case services (general
pre-approval) or it may pre-approve specific services (specific pre-approval). The Committee
believes that the combination of these approaches contemplated in this Policy results in an
effective and efficient method for pre-approving audit and non-audit services to be performed by
the Funds independent auditors. Under this Policy, services that are not of a type that may
receive general pre-approval require specific pre-approval by the Committee. Any proposed services
that exceed pre-approved cost levels or budgeted amounts will also require the Committees specific
pre-approval.
For both types of approval, the Committee considers whether the subject services are consistent
with the SECs rules on auditor independence and that such services are compatible with maintaining
the auditors independence. The Committee also considers whether a particular audit firm is in the
best position to provide effective and efficient services to the Funds. Reasons that the auditors
are in the best position include the auditors familiarity with the Funds business, personnel,
culture, accounting systems, risk profile, and other factors, and whether the services will enhance
the Funds ability to manage and control risk or improve audit quality. Such factors will be
considered as a whole, with no one factor being determinative.
The appendices attached to this Policy describe the audit, audit-related, tax-related, and other
services that have the Committees general pre-approval. For any service that has been approved
through general pre-approval, the general pre-approval will remain in place for a period 12 months
from the date of pre-approval, unless the Committee determines that a different period is
appropriate. The Committee will annually review and pre-approve the services that may be provided
by the independent auditors without specific pre-approval. The Committee will revise the list of
services subject to general pre-approval as appropriate. This Policy does not serve as a
delegation to Fund management of the Committees duty to pre-approve services performed by the
Funds independent auditors.
II. Audit Services
The annual audit services engagement terms and fees are subject to the Committees specific
pre-approval. Audit services are those services that are normally provided by auditors in
connection with statutory and regulatory filings or engagements or those that generally only
independent auditors can reasonably provide. They include the Funds annual financial statement
audit and procedures that the independent auditors must perform in order to form an opinion on the
Funds financial statements (e.g., information systems and procedural reviews and testing). The
Committee will monitor the audit services engagement and approve any changes in terms, conditions
or fees deemed by the Committee to be necessary or appropriate.
The Committee may grant general pre-approval to other audit services, such as statutory audits and
services associated with SEC registration statements, periodic reports and other documents filed
with the SEC or issued in connection with securities offerings.
The Committee has pre-approved the audit services listed on Appendix A. The Committee must
specifically approve all audit services not listed on Appendix A.
III. Audit-related Services
Audit-related services are assurance and related services that are reasonably related to the
performance of the audit or the review of the Funds financial statements or are traditionally
performed by the independent auditors. The Committee believes that the provision of audit-related
services will not impair the independent auditors independence, and therefore may grant
pre-approval to audit-related services. Audit-related services include accounting consultations
related to accounting, financial reporting or disclosure matters not classified as audit
services; assistance with understanding and implementing new accounting and financial reporting
guidance from rulemaking authorities; agreed-upon or expanded audit procedures relating to
accounting and/or billing records required to respond to or comply with financial, accounting or
regulatory reporting matters; and assistance with internal control reporting requirements under
Form N-SAR or Form N-CSR.
The Committee has pre-approved the audit-related services listed on Appendix B. The Committee must
specifically approve all audit-related services not listed on Appendix B.
IV. Tax Services
The Committee believes the independent auditors can provide tax services to the Funds, including
tax compliance, tax planning, and tax advice, without compromising the auditors independence.
Therefore, the Committee may grant general pre-approval with respect to tax services historically
provided by the Funds independent auditors that do not, in the Committees view, impair auditor
independence and that are consistent with the SECs rules on auditor independence.
The Committee will not grant pre-approval if the independent auditors initially recommends a
transaction the sole business purpose of which is tax avoidance and the tax treatment of which may
not be supported in the Internal Revenue Code and related regulations. The Committee may consult
2
outside counsel to determine that tax planning and reporting positions are consistent with this
Policy.
The Committee has pre-approved the tax-related services listed on Appendix C. The Committee must
specifically approve all tax-related services not listed on Appendix C.
V. Other Services
The Committee believes it may grant approval of non-audit services that are permissible services
for independent auditors to a Fund. The Committee has determined to grant general pre-approval to
other services that it believes are routine and recurring, do not impair auditor independence, and
are consistent with SEC rules on auditor independence.
The Committee has pre-approved the non-audit services listed on Appendix D. The Committee must
specifically approve all non-audit services not listed on Appendix D.
A list of the SECs prohibited non-audit services is attached to this Policy as Appendix E. The
SECs rules and relevant guidance should be consulted to determine the precise definitions of these
impermissible services and the applicability of exceptions to certain of the SECs prohibitions.
VI. Pre-approval of Fee levels and Budgeted Amounts
The Committee will annually establish pre-approval fee levels or budgeted amounts for audit,
audit-related, tax and non-audit services to be provided to the Funds by the independent auditors.
Any proposed services exceeding these levels or amounts require the Committees specific
pre-approval. The Committee considers fees for audit and non-audit services when deciding whether
to pre-approve services. The Committee may determine, for a pre-approval period of 12 months, the
appropriate ratio between the total amount of fees for the Funds audit, audit-related, and tax
services (including fees for services provided to Fund affiliates that are subject to
pre-approval), and the total amount of fees for certain permissible non-audit services for the Fund
classified as other services (including any such services provided to Fund affiliates that are
subject to pre-approval).
VII. Procedures
Requests or applications for services to be provided by the independent auditors will be submitted
to management. If management determines that the services do not fall within those services
generally pre-approved by the Committee and set out in the appendices to these procedures,
management will submit the services to the Committee or its delagee. Any such submission will
include a detailed description of the services to be rendered. Notwithstanding this paragraph, the
Committee will, on a quarterly basis, receive from the independent auditors a list of services
provided for the previous calendar quarter on a cumulative basis by the auditors during the
Pre-Approval Period.
3
VIII. Delegation
The Committee may delegate pre-approval authority to one or more of the Committees members. Any
member or members to whom such pre-approval authority is delegated must report any pre-approval
decisions, including any pre-approved services, to the Committee at its next scheduled meeting.
The Committee will identify any member to whom pre-approval authority is delegated in writing. The
member will retain such authority for a period of 12 months from the date of pre-approval unless
the Committee determines that a different period is appropriate. The period of delegated authority
may be terminated by the Committee or at the option of the member.
IX. Additional Requirements
The Committee will take any measures the Committee deems necessary or appropriate to oversee the
work of the independent auditors and to assure the auditors independence from the Funds. This may
include reviewing a formal written statement from the independent auditors delineating all
relationships between the auditors and the Funds, consistent with Independence Standards Board No.
1, and discussing with the auditors their methods and procedures for ensuring independence.
Effective April 23, 2008, the KPMG LLP (KPMG) audit team for the ING Funds accepted the global
responsibility for monitoring the auditor independence for KPMG relative to the ING Funds. Using a
proprietary system called Sentinel, the audit team is able to identify and manage potential
conflicts of interest across the member firms of the KPMG International Network and prevent the
provision of prohibited services to the ING entities that would impair KPMG independence with the
respect to the ING Funds. In addition to receiving pre-approval from the ING Funds Audit Committee
for services provided to the ING Funds and for services for ING entities in the Investment Company
Complex, the audit team has developed a process for periodic notification via email to the ING
Funds Audit Committee Chairpersons regarding requests to provide services to ING Groep NV and its
affiliates from KPMG offices worldwide. Additionally, KPMG provides a quarterly summary of the
fees for services that have commenced for ING Groep NV and Affiliates at each Audit Committee
Meeting.
4
Last Approved: September 29, 2010
5
Appendix A
Pre-Approved Audit Services for the Pre-Approval Period September 29, 2010 through December 31,
2011
Service
|
|
|
|
|
|
|
The Fund(s) |
|
Fee Range |
Statutory audits or
financial audits (including
tax services associated
with audit services)
|
|
Ö
|
|
As presented to Audit
Committee1 |
|
|
|
|
|
Services associated with
SEC registration
statements, periodic
reports and other documents
filed with the SEC or other
documents issued in
connection with securities
offerings (e.g., consents),
and assistance in
responding to SEC comment
letters.
|
|
Ö
|
|
Not to exceed $9,750 per
filing |
|
|
|
|
|
Consultations by Fund
management with respect to
accounting or disclosure
treatment of transactions
or events and/or the actual
or potential effect of
final or proposed rules,
standards or
interpretations by the SEC,
Financial Accounting
Standards Board, or other
regulatory or standard
setting bodies.
|
|
Ö
|
|
Not to exceed $8,000 during
the Pre-Approval Period |
|
|
|
|
|
Seed capital audit and
related review and issuance
of consent on the N-2
registration statement
|
|
Ö
|
|
Not to exceed $13,000 per
audit |
|
|
|
1 |
|
For new Funds launched during the
Pre-Approval Period, the fee ranges pre-approved will be the same as those for
existing Funds, pro-rated in accordance with inception dates as provided in the
auditors Proposal or any Engagement Letter covering the period at issue. Fees
in the Engagement Letter will be controlling. |
6
Appendix B
Pre-Approved Audit-Related Services for the Pre-Approval Period September 29, 2010 through
December 31, 2011
Service
|
|
|
|
|
|
|
|
|
The Fund(s) |
|
Fund Affiliates |
|
Fee Range |
Services related to Fund
mergers (Excludes tax services
See Appendix C for tax
services associated with Fund
mergers)
|
|
Ö
|
|
Ö
|
|
Not to exceed
$10,000 per merger |
|
|
|
|
|
|
|
Consultations by Fund
management with respect to
accounting or disclosure
treatment of transactions or
events and/or the actual or
potential effect of final or
proposed rules, standards or
interpretations by the SEC,
Financial Accounting Standards
Board, or other regulatory or
standard setting bodies.
[Note: Under SEC rules some
consultations may be audit
services and others may be
audit-related services.]
|
|
Ö
|
|
|
|
Not to exceed
$5,000 per
occurrence during
the Pre-Approval
Period |
|
|
|
|
|
|
|
Review of the Funds
semi-annual and quarterly
financial statements
|
|
Ö
|
|
|
|
Not to exceed
$2,400 per set of
financial
statements per fund |
|
|
|
|
|
|
|
Reports to regulatory or
government agencies related to
the annual engagement
|
|
Ö
|
|
|
|
Up to $5,000 per
occurrence during
the Pre-Approval
Period |
|
|
|
|
|
|
|
Regulatory compliance assistance
|
|
Ö
|
|
Ö
|
|
Not to exceed
$5,000 per quarter |
|
|
|
|
|
|
|
Training courses
|
|
|
|
Ö
|
|
Not to exceed
$2,000 per course |
|
|
|
|
|
|
|
For Prime Rate Trust, agreed
upon procedures for quarterly
reports to rating agencies
|
|
Ö
|
|
|
|
Not to exceed
$9,450 per quarter |
7
Appendix C
Pre-Approved Tax Services for the Pre-Approval Period September 29, 2010 through December 31,
2011
Service
|
|
|
|
|
|
|
|
|
The Fund(s) |
|
Fund Affiliates |
|
Fee Range |
Preparation of
federal and state
income tax returns
and federal excise
tax returns for the
Funds including
assistance and
review with excise
tax distributions
|
|
Ö
|
|
|
|
As presented to Audit
Committee2 |
|
|
|
|
|
|
|
Review of IRC
Sections 851(b) and
817(h)
diversification
testing on a
real-time basis
|
|
Ö
|
|
|
|
As presented to Audit
Committee2 |
|
|
|
|
|
|
|
Assistance and
advice regarding
year-end reporting
for 1099s
|
|
Ö
|
|
|
|
As presented to Audit
Committee2 |
|
|
|
|
|
|
|
Tax assistance and
advice regarding
statutory,
regulatory or
administrative
developments
|
|
Ö
|
|
Ö
|
|
Not to exceed $5,000
for the Funds or for
the Funds investment
adviser during the
Pre-Approval Period |
|
|
|
2 |
|
For new Funds launched during the
Pre-Approval Period, the fee ranges pre-approved will be the same as those for
existing Funds, pro-rated in accordance with inception dates as provided in the
auditors Proposal or any Engagement Letter covering the period at issue. Fees
in the Engagement Letter will be controlling. |
8
Appendix C, continued
Service
|
|
|
|
|
|
|
|
|
The Fund(s) |
|
Fund Affiliates |
|
Fee Range |
Tax training courses
|
|
|
|
Ö
|
|
Not to exceed
$2,000 per course
during the
Pre-Approval Period |
|
|
|
|
|
|
|
Tax services associated with Fund mergers
|
|
Ö
|
|
Ö
|
|
Not to exceed
$4,000 per fund per
merger during the
Pre-Approval Period |
|
|
|
|
|
|
|
Other tax-related assistance and
consultation, including, without
limitation, assistance in evaluating
derivative financial instruments and
international tax issues, qualification
and distribution issues, and similar
routine tax consultations.
|
|
Ö
|
|
|
|
Not to exceed
$120,000 during the
Pre-Approval Period |
9
Appendix D
Pre-Approved Other Services for the Pre-Approval Period September 29 , 2010 through December 31,
2011
Service
|
|
|
|
|
|
|
|
|
The Fund(s) |
|
Fund Affiliates |
|
Fee Range |
Agreed-upon
procedures for
Class B share 12b-1
programs
|
|
|
|
Ö
|
|
Not to exceed
$60,000 during the
Pre-Approval Period |
|
|
|
|
|
|
|
Security counts
performed pursuant
to Rule 17f-2 of
the 1940 Act (i.e.,
counts for Funds
holding securities
with affiliated
sub-custodians)
Cost to be borne
50% by the Funds
and 50% by ING
Investments, LLC.
|
|
Ö
|
|
Ö
|
|
Not to exceed
$5,000 per Fund
during the
Pre-Approval Period |
|
|
|
|
|
|
|
Agreed upon
procedures for 15
(c) FACT Books
|
|
Ö
|
|
|
|
Not to exceed
$35,000 during the
Pre-Approval Period |
10
Appendix E
Prohibited Non-Audit Services
Dated: September 29. 2010 to December 31, 2011
|
|
|
Bookkeeping or other services related to the accounting records or financial
statements of the Funds |
|
|
|
|
Financial information systems design and implementation |
|
|
|
|
Appraisal or valuation services, fairness opinions, or contribution-in-kind reports |
|
|
|
|
Actuarial services |
|
|
|
|
Internal audit outsourcing services |
|
|
|
|
Management functions |
|
|
|
|
Human resources |
|
|
|
|
Broker-dealer, investment adviser, or investment banking services |
|
|
|
|
Legal services |
|
|
|
|
Expert services unrelated to the audit |
|
|
|
|
Any other service that the Public Company Accounting Oversight Board determines, by
regulation, is impermissible |
11
EXHIBIT A
ING EQUITY TRUST
ING FUNDS TRUST
ING ASIA PACIFIC HIGH DIVIDEND EQUITY INCOME FUND
ING GLOBAL ADVANTAGE AND PREMIUM OPPORTUNITY FUND
ING GLOBAL EQUITY DIVIDEND AND PREMIUM OPPORTUNITY FUND
ING INTERNATIONAL HIGH DIVIDEND EQUITY INCOME FUND
ING INFRASTRUCTURE, INDUSTRIALS, AND MATERIALS FUND
ING RISK MANAGED NATURAL RESOURCES FUNDING INVESTORS TRUST
ING MAYFLOWER TRUST
ING MUTUAL FUNDS
ING PARTNERS, INC.
ING PRIME RATE TRUST
ING SENIOR INCOME FUND
ING SEPARATE PORTFOLIOS TRUST
ING VARIABLE INSURANCE TRUST
ING VARIABLE PRODUCTS TRUST
(e)(2) |
|
Percentage of services referred to in 4(b) (4)(d) that were approved by the
audit committee |
|
|
|
100% of the services were approved by the audit committee. |
|
(f) |
|
Percentage of hours expended attributable to work
performed by other than full time
employees of KPMG if greater than 50%. |
|
|
|
Not applicable. |
|
(g) |
|
Non-Audit Fees: The non-audit fees billed by the registrants accountant for services
rendered to the registrant, and rendered to the registrants investment adviser, and any entity controlling, controlled by, or under
common control with the adviser that provides ongoing services to the
registrant were $1,084,113 for the year ended February 28, 2011
and $2,011,031 for year ended February 28, 2010. |
|
(h) |
|
Principal Accountants Independence: The Registrants Audit committee has considered
whether the provision of non-audit services that were rendered to the registrants investment
adviser and any entity controlling, controlled by, or under common control with the
investment adviser that provides ongoing services to the registrant that were not pre-approved
pursuant to Rule 2-01(c)(7)(ii) of Regulation S-X is compatible with maintaining KPMGs
independence. |
Item 5. Audit Committee of Listed Registrants.
a. |
|
The registrant has a separately-designated standing audit committee. The members are J.
Michael Earley, Patricia W. Chadwick and Peter S. Drotch. |
|
b. |
|
Not applicable. |
Item 6. Schedule of Investments.
Report of Independent Registered Public Accounting Firm
The Shareholders and Board of Trustees
ING Global Advantage and Premium Opportunity Fund
We have audited, in accordance with the standards of the Public Company Accounting Oversight Board
(United States), the statement of assets and liabilities, including the summary portfolio of
investments, of ING Global Advantage and Premium Opportunity Fund as of February 28, 2011, and the
related statement of operations for the year then ended, the statements of changes in net assets
for each of the years in the two-year period then ended, and the financial highlights for each of
the years in the five-year period then ended and have issued our unqualified report thereon dated
April 25, 2011 (which report and financial statements are included in Item 1 of this Certified
Shareholder Report on Form N-CSR). In connection with our audit of the aforementioned financial
statements and financial highlights, we also audited the related portfolio of investments included
in Item 6 of this Form N-CSR. The portfolio of investments is the responsibility of management.
Our responsibility is to express an opinion on the portfolio of investments based on our audits.
In our opinion, the portfolio of investments, when considered in relation to the basic financial
statements taken as a whole, presents fairly, in all material respects, the information set forth
therein.
Boston, Massachusetts
April 25, 2011
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as of February 28, 2011
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
COMMON STOCK: |
|
|
98.7 |
% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Australia: |
|
|
|
|
|
|
3.2 |
% |
|
|
|
|
|
2,440 |
|
|
|
|
|
|
Alumina Ltd. |
|
|
|
|
|
|
|
|
|
$ |
5,978 |
|
|
24,603 |
|
|
|
|
|
|
Amcor Ltd. |
|
|
|
|
|
|
|
|
|
|
174,393 |
|
|
901 |
|
|
|
|
|
|
AMP Ltd. |
|
|
|
|
|
|
|
|
|
|
4,891 |
|
|
130 |
|
|
|
|
|
|
ASX Ltd. |
|
|
|
|
|
|
|
|
|
|
4,844 |
|
|
25,160 |
|
|
|
|
|
|
Australia & New Zealand Banking Group Ltd. |
|
|
|
|
|
|
|
|
|
|
621,841 |
|
|
454 |
|
|
|
|
|
|
AXA Asia Pacific Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
2,938 |
|
|
12,092 |
|
|
|
|
|
|
Bendigo Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
115,696 |
|
|
29,647 |
|
|
|
|
|
|
BHP Billiton Ltd. |
|
|
|
|
|
|
|
|
|
|
1,400,950 |
|
|
1,875 |
|
|
|
|
|
|
BlueScope Steel Ltd. |
|
|
|
|
|
|
|
|
|
|
4,018 |
|
|
661 |
|
|
|
|
|
|
Boral Ltd. |
|
|
|
|
|
|
|
|
|
|
3,719 |
|
|
9,855 |
|
|
|
|
|
|
Brambles Ltd. |
|
|
|
|
|
|
|
|
|
|
71,532 |
|
|
14,295 |
|
|
|
|
|
|
Caltex Australia Ltd. |
|
|
|
|
|
|
|
|
|
|
232,065 |
|
|
654 |
|
|
|
|
|
|
Coca-Cola Amatil Ltd. |
|
|
|
|
|
|
|
|
|
|
7,912 |
|
|
743 |
|
|
|
|
|
|
Cochlear Ltd. |
|
|
|
|
|
|
|
|
|
|
58,695 |
|
|
14,979 |
|
|
|
|
|
|
Commonwealth Bank of Australia |
|
|
|
|
|
|
|
|
|
|
814,224 |
|
|
7,752 |
|
|
|
|
|
|
Computershare Ltd. |
|
|
|
|
|
|
|
|
|
|
76,128 |
|
|
323 |
|
|
|
|
|
|
Crown Ltd. |
|
|
|
|
|
|
|
|
|
|
2,758 |
|
|
4,372 |
|
|
|
|
|
|
CSL Ltd. |
|
|
|
|
|
|
|
|
|
|
158,825 |
|
|
16,707 |
|
|
|
@ |
|
|
Fortescue Metals Group Ltd. |
|
|
|
|
|
|
|
|
|
|
112,948 |
|
|
2,312 |
|
|
|
|
|
|
Fosters Group Ltd. |
|
|
|
|
|
|
|
|
|
|
13,478 |
|
|
220,855 |
|
|
|
|
|
|
Goodman Fielder Ltd. |
|
|
|
|
|
|
|
|
|
|
281,216 |
|
|
1,442 |
|
|
|
|
|
|
Incitec Pivot Ltd. |
|
|
|
|
|
|
|
|
|
|
6,506 |
|
|
996 |
|
|
|
|
|
|
Insurance Australia Group |
|
|
|
|
|
|
|
|
|
|
3,708 |
|
|
257 |
|
|
|
|
|
|
Macquarie Airports Management Ltd. |
|
|
|
|
|
|
|
|
|
|
814 |
|
|
3,309 |
|
|
|
|
|
|
Macquarie Group Ltd. |
|
|
|
|
|
|
|
|
|
|
128,626 |
|
|
55,349 |
|
|
|
|
|
|
Metcash Ltd. |
|
|
|
|
|
|
|
|
|
|
229,268 |
|
|
21,786 |
|
|
|
|
|
|
National Australia Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
576,000 |
|
|
11,991 |
|
|
|
|
|
|
Newcrest Mining Ltd. |
|
|
|
|
|
|
|
|
|
|
463,457 |
|
|
1,244 |
|
|
|
|
|
|
OneSteel Ltd. |
|
|
|
|
|
|
|
|
|
|
3,450 |
|
|
349 |
|
|
|
|
|
|
Orica Ltd. |
|
|
|
|
|
|
|
|
|
|
9,225 |
|
|
4,303 |
|
|
|
|
|
|
Origin Energy Ltd. |
|
|
|
|
|
|
|
|
|
|
73,617 |
|
|
3,110 |
|
|
|
|
|
|
Oz Minerals Ltd. |
|
|
|
|
|
|
|
|
|
|
5,174 |
|
|
853 |
|
|
|
@ |
|
|
Qantas Airways Ltd. |
|
|
|
|
|
|
|
|
|
|
2,044 |
|
|
7,387 |
|
|
|
|
|
|
QBE Insurance Group Ltd. |
|
|
|
|
|
|
|
|
|
|
136,848 |
|
|
3,933 |
|
|
|
|
|
|
Ramsay Health Care Ltd. |
|
|
|
|
|
|
|
|
|
|
71,303 |
|
|
6,202 |
|
|
|
|
|
|
Rio Tinto Ltd. |
|
|
|
|
|
|
|
|
|
|
541,534 |
|
|
1,114 |
|
|
|
|
|
|
Santos Ltd. |
|
|
|
|
|
|
|
|
|
|
16,361 |
|
|
195 |
|
|
|
|
|
|
Sims Group Ltd. |
|
|
|
|
|
|
|
|
|
|
3,755 |
|
|
281 |
|
|
|
|
|
|
Sonic Healthcare Ltd. |
|
|
|
|
|
|
|
|
|
|
3,239 |
|
|
21,819 |
|
|
|
|
|
|
Suncorp-Metway Ltd. |
|
|
|
|
|
|
|
|
|
|
187,308 |
|
|
486 |
|
|
|
|
|
|
TABCORP Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
3,776 |
|
|
1,006 |
|
|
|
|
|
|
Tattersalls Ltd. |
|
|
|
|
|
|
|
|
|
|
2,497 |
|
|
30,292 |
|
|
|
|
|
|
Telstra Corp., Ltd. |
|
|
|
|
|
|
|
|
|
|
86,256 |
|
|
446 |
|
|
|
|
|
|
Toll Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
2,743 |
|
|
913 |
|
|
|
|
|
|
Transurban Group |
|
|
|
|
|
|
|
|
|
|
4,981 |
|
|
1,948 |
|
|
|
|
|
|
Wesfarmers Ltd. |
|
|
|
|
|
|
|
|
|
|
65,987 |
|
|
21,688 |
|
|
|
|
|
|
Westpac Banking Corp. |
|
|
|
|
|
|
|
|
|
|
523,451 |
|
|
7,356 |
|
|
|
|
|
|
Woodside Petroleum Ltd. |
|
|
|
|
|
|
|
|
|
|
320,784 |
|
|
14,913 |
|
|
|
|
|
|
Woolworths Ltd. |
|
|
|
|
|
|
|
|
|
|
409,135 |
|
|
250 |
|
|
|
|
|
|
WorleyParsons Ltd. |
|
|
|
|
|
|
|
|
|
|
7,732 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
8,058,628 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Austria: |
|
|
|
|
|
|
0.2 |
% |
|
|
|
|
|
203 |
|
|
|
|
|
|
Erste Bank der Oesterreichischen Sparkassen AG |
|
|
|
|
|
|
|
|
|
|
10,709 |
|
|
8,434 |
|
|
|
|
|
|
OMV AG |
|
|
|
|
|
|
|
|
|
|
358,405 |
|
|
25 |
|
|
|
|
|
|
Raiffeisen International Bank Holding AG |
|
|
|
|
|
|
|
|
|
|
1,502 |
|
|
4,583 |
|
|
|
|
|
|
Voestalpine AG |
|
|
|
|
|
|
|
|
|
|
211,907 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
582,523 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Barbados: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
8,400 |
|
|
|
@ |
|
|
Nabors Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
239,148 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
239,148 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Belgium: |
|
|
|
|
|
|
0.5 |
% |
|
|
|
|
|
698 |
|
|
|
|
|
|
Ageas |
|
|
|
|
|
|
|
|
|
|
2,214 |
|
|
13,068 |
|
|
|
|
|
|
Anheuser-Busch InBev NV |
|
|
|
|
|
|
|
|
|
|
729,823 |
|
|
22,364 |
|
|
|
@ |
|
|
Anheuser-Busch InBev NV |
|
|
|
|
|
|
|
|
|
|
123 |
|
|
1,703 |
|
|
|
|
|
|
Bekaert SA |
|
|
|
|
|
|
|
|
|
|
184,747 |
|
|
145 |
|
|
|
|
|
|
Colruyt S.A. |
|
|
|
|
|
|
|
|
|
|
7,287 |
|
|
184 |
|
|
|
|
|
|
Delhaize Group |
|
|
|
|
|
|
|
|
|
|
14,213 |
|
|
217 |
|
|
|
@ |
|
|
Dexia S.A. |
|
|
|
|
|
|
|
|
|
|
948 |
|
|
1,824 |
|
|
|
|
|
|
Groupe Bruxelles Lambert S.A. |
|
|
|
|
|
|
|
|
|
|
167,656 |
|
|
63 |
|
|
|
|
|
|
KBC Groep NV |
|
|
|
|
|
|
|
|
|
|
2,635 |
|
|
102 |
|
|
|
|
|
|
Solvay S.A. |
|
|
|
|
|
|
|
|
|
|
11,962 |
|
|
190 |
|
|
|
|
|
|
Umicore |
|
|
|
|
|
|
|
|
|
|
9,580 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
15
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1,131,188 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Bermuda: |
|
|
|
|
|
|
0.3 |
% |
|
|
|
|
|
13,189 |
|
|
|
|
|
|
SeaDrill Ltd. ADR |
|
|
|
|
|
|
|
|
|
|
503,775 |
|
|
3,900 |
|
|
|
|
|
|
Tyco International Ltd. |
|
|
|
|
|
|
|
|
|
|
176,826 |
|
|
3,100 |
|
|
|
|
|
|
XL Group PLC |
|
|
|
|
|
|
|
|
|
|
72,385 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
752,986 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Denmark: |
|
|
|
|
|
|
0.3 |
% |
|
|
|
|
|
74 |
|
|
|
|
|
|
Carlsberg A/S |
|
|
|
|
|
|
|
|
|
|
7,860 |
|
|
1,465 |
|
|
|
|
|
|
Coloplast A/S |
|
|
|
|
|
|
|
|
|
|
206,208 |
|
|
9,381 |
|
|
|
@ |
|
|
Danske Bank A/S |
|
|
|
|
|
|
|
|
|
|
219,902 |
|
|
48 |
|
|
|
|
|
|
DSV A/S |
|
|
|
|
|
|
|
|
|
|
1,109 |
|
|
2,738 |
|
|
|
|
|
|
Novo-Nordisk A/S |
|
|
|
|
|
|
|
|
|
|
345,104 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
780,183 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Finland: |
|
|
|
|
|
|
1.3 |
% |
|
|
|
|
|
582 |
|
|
|
|
|
|
Fortum OYJ |
|
|
|
|
|
|
|
|
|
|
18,023 |
|
|
10,002 |
|
|
|
|
|
|
Kesko OYJ |
|
|
|
|
|
|
|
|
|
|
430,802 |
|
|
7,665 |
|
|
|
|
|
|
Kone OYJ |
|
|
|
|
|
|
|
|
|
|
418,344 |
|
|
51 |
|
|
|
|
|
|
Metso OYJ |
|
|
|
|
|
|
|
|
|
|
2,638 |
|
|
64,758 |
|
|
|
|
|
|
Nokia OYJ |
|
|
|
|
|
|
|
|
|
|
558,325 |
|
|
4,942 |
|
|
|
|
|
|
Orion OYJ |
|
|
|
|
|
|
|
|
|
|
113,070 |
|
|
557 |
|
|
|
|
|
|
Outokumpu OYJ |
|
|
|
|
|
|
|
|
|
|
10,000 |
|
|
8,408 |
|
|
|
|
|
|
Pohjola Bank PLC |
|
|
|
|
|
|
|
|
|
|
115,098 |
|
|
352 |
|
|
|
|
|
|
Rautaruukki OYJ |
|
|
|
|
|
|
|
|
|
|
8,177 |
|
|
4,055 |
|
|
|
|
|
|
Sampo OYJ |
|
|
|
|
|
|
|
|
|
|
125,505 |
|
|
39,449 |
|
|
|
|
|
|
Stora Enso OYJ (Euro Denominated Security) |
|
|
|
|
|
|
|
|
|
|
444,395 |
|
|
25,413 |
|
|
|
|
|
|
UPM-Kymmene OYJ |
|
|
|
|
|
|
|
|
|
|
504,656 |
|
|
5,502 |
|
|
|
|
|
|
Wartsila OYJ |
|
|
|
|
|
|
|
|
|
|
423,060 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
3,172,093 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
France: |
|
|
|
|
|
|
2.9 |
% |
|
|
|
|
|
258 |
|
|
|
|
|
|
Accor S.A. |
|
|
|
|
|
|
|
|
|
|
12,139 |
|
|
90 |
|
|
|
|
|
|
Air Liquide |
|
|
|
|
|
|
|
|
|
|
11,652 |
|
|
58 |
|
|
|
|
|
|
Alstom |
|
|
|
|
|
|
|
|
|
|
3,461 |
|
|
25 |
|
|
|
|
|
|
Atos Origin |
|
|
|
|
|
|
|
|
|
|
1,448 |
|
|
20,512 |
|
|
|
|
|
|
AXA S.A. |
|
|
|
|
|
|
|
|
|
|
430,940 |
|
|
9,887 |
|
|
|
|
|
|
BNP Paribas |
|
|
|
|
|
|
|
|
|
|
771,637 |
|
|
73 |
|
|
|
|
|
|
Bouygues S.A. |
|
|
|
|
|
|
|
|
|
|
3,372 |
|
|
76 |
|
|
|
|
|
|
Capgemini S.A. |
|
|
|
|
|
|
|
|
|
|
4,443 |
|
|
263 |
|
|
|
|
|
|
Carrefour S.A. |
|
|
|
|
|
|
|
|
|
|
12,916 |
|
|
29 |
|
|
|
|
|
|
Casino Guichard Perrachon S.A. |
|
|
|
|
|
|
|
|
|
|
2,840 |
|
|
1,930 |
|
|
|
|
|
|
Christian Dior S.A. |
|
|
|
|
|
|
|
|
|
|
278,186 |
|
|
119 |
|
|
|
|
|
|
Cie de Saint-Gobain |
|
|
|
|
|
|
|
|
|
|
7,108 |
|
|
155 |
|
|
|
@ |
|
|
Cie Generale de Geophysique-Veritas |
|
|
|
|
|
|
|
|
|
|
5,742 |
|
|
326 |
|
|
|
|
|
|
Cie Generale des Etablissements Michelin |
|
|
|
|
|
|
|
|
|
|
26,571 |
|
|
150 |
|
|
|
|
|
|
Cie Generale DOptique Essilor International S.A. |
|
|
|
|
|
|
|
|
|
|
10,719 |
|
|
4,915 |
|
|
|
|
|
|
CNP Assurances |
|
|
|
|
|
|
|
|
|
|
109,063 |
|
|
13,650 |
|
|
|
|
|
|
Credit Agricole S.A. |
|
|
|
|
|
|
|
|
|
|
239,630 |
|
|
35 |
|
|
|
|
|
|
Dassault Systemes S.A. |
|
|
|
|
|
|
|
|
|
|
2,681 |
|
|
39 |
|
|
|
|
|
|
Electricite de France SA |
|
|
|
|
|
|
|
|
|
|
1,739 |
|
|
132 |
|
|
|
|
|
|
Eutelsat Communications |
|
|
|
|
|
|
|
|
|
|
5,268 |
|
|
9,186 |
|
|
|
|
|
|
France Telecom S.A. |
|
|
|
|
|
|
|
|
|
|
203,276 |
|
|
939 |
|
|
|
|
|
|
Gaz de France |
|
|
|
|
|
|
|
|
|
|
38,086 |
|
|
100 |
|
|
|
|
|
|
Groupe Danone |
|
|
|
|
|
|
|
|
|
|
6,268 |
|
|
14 |
|
|
|
|
|
|
Iliad S.A. |
|
|
|
|
|
|
|
|
|
|
1,569 |
|
|
66 |
|
|
|
|
|
|
Lafarge S.A. |
|
|
|
|
|
|
|
|
|
|
4,009 |
|
|
155 |
|
|
|
|
|
|
Lagardere SCA |
|
|
|
|
|
|
|
|
|
|
6,977 |
|
|
55 |
|
|
|
|
|
|
Legrand S.A. |
|
|
|
|
|
|
|
|
|
|
2,309 |
|
|
75 |
|
|
|
|
|
|
LOreal S.A. |
|
|
|
|
|
|
|
|
|
|
8,726 |
|
|
991 |
|
|
|
|
|
|
LVMH Moet Hennessy Louis Vuitton S.A. |
|
|
|
|
|
|
|
|
|
|
156,293 |
|
|
733 |
|
|
|
|
|
|
Natixis |
|
|
|
|
|
|
|
|
|
|
4,373 |
|
|
170 |
|
|
|
|
|
|
PagesJaunes Groupe S.A. |
|
|
|
|
|
|
|
|
|
|
1,658 |
|
|
2,968 |
|
|
|
|
|
|
Pernod-Ricard S.A. |
|
|
|
|
|
|
|
|
|
|
273,457 |
|
|
299 |
|
|
|
@ |
|
|
Peugeot S.A. |
|
|
|
|
|
|
|
|
|
|
11,976 |
|
|
1,890 |
|
|
|
|
|
|
PPR |
|
|
|
|
|
|
|
|
|
|
286,745 |
|
|
167 |
|
|
|
|
|
|
Publicis Groupe |
|
|
|
|
|
|
|
|
|
|
9,526 |
|
|
6,522 |
|
|
|
@ |
|
|
Renault S.A. |
|
|
|
|
|
|
|
|
|
|
399,948 |
|
|
57 |
|
|
|
|
|
|
Safran S.A. |
|
|
|
|
|
|
|
|
|
|
2,029 |
|
|
11,833 |
|
|
|
|
|
|
Sanofi-Aventis |
|
|
|
|
|
|
|
|
|
|
818,232 |
|
|
4,425 |
|
|
|
|
|
|
Schneider Electric S.A. |
|
|
|
|
|
|
|
|
|
|
732,930 |
|
|
290 |
|
|
|
|
|
|
Scor S.A. |
|
|
|
|
|
|
|
|
|
|
8,519 |
|
|
1,373 |
|
|
|
|
|
|
Societe BIC S.A. |
|
|
|
|
|
|
|
|
|
|
117,343 |
|
|
6,991 |
|
|
|
|
|
|
Societe Generale |
|
|
|
|
|
|
|
|
|
|
491,580 |
|
|
149 |
|
|
|
|
|
|
Societe Television Francaise (T.F.1) |
|
|
|
|
|
|
|
|
|
|
2,896 |
|
|
1,880 |
|
|
|
|
|
|
Sodexho Alliance S.A. |
|
|
|
|
|
|
|
|
|
|
129,386 |
|
|
40 |
|
|
|
|
|
|
Suez Environnement S.A. |
|
|
|
|
|
|
|
|
|
|
867 |
|
|
105 |
|
|
|
|
|
|
Technip S.A. |
|
|
|
|
|
|
|
|
|
|
10,377 |
|
|
28 |
|
|
|
|
|
|
Thales S.A. |
|
|
|
|
|
|
|
|
|
|
1,061 |
|
|
15,642 |
|
|
|
|
|
|
Total S.A. |
|
|
|
|
|
|
|
|
|
|
958,860 |
|
|
36 |
|
|
|
|
|
|
Vallourec |
|
|
|
|
|
|
|
|
|
|
3,737 |
|
|
49 |
|
|
|
|
|
|
Veolia Environnement |
|
|
|
|
|
|
|
|
|
|
1,612 |
|
16
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
135 |
|
|
|
|
|
|
Vinci S.A. |
|
|
|
|
|
|
|
|
|
|
8,120 |
|
|
25,234 |
|
|
|
|
|
|
Vivendi |
|
|
|
|
|
|
|
|
|
|
719,194 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
7,363,494 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Germany: |
|
|
|
|
|
|
3.7 |
% |
|
|
|
|
|
109 |
|
|
|
|
|
|
Adidas AG |
|
|
|
|
|
|
|
|
|
|
7,000 |
|
|
4,768 |
|
|
|
|
|
|
Allianz AG |
|
|
|
|
|
|
|
|
|
|
688,552 |
|
|
13,197 |
|
|
|
|
|
|
BASF AG |
|
|
|
|
|
|
|
|
|
|
1,100,372 |
|
|
4,827 |
|
|
|
|
|
|
Bayer AG |
|
|
|
|
|
|
|
|
|
|
375,105 |
|
|
6,528 |
|
|
|
|
|
|
Bayerische Motoren Werke AG |
|
|
|
|
|
|
|
|
|
|
530,354 |
|
|
36 |
|
|
|
|
|
|
Beiersdorf AG |
|
|
|
|
|
|
|
|
|
|
2,161 |
|
|
50 |
|
|
|
|
|
|
Celesio AG |
|
|
|
|
|
|
|
|
|
|
1,385 |
|
|
27 |
|
|
|
@ |
|
|
Continental AG |
|
|
|
|
|
|
|
|
|
|
2,288 |
|
|
2,926 |
|
|
|
@ |
|
|
DaimlerChrysler AG |
|
|
|
|
|
|
|
|
|
|
206,779 |
|
|
6,728 |
|
|
|
|
|
|
Deutsche Bank AG |
|
|
|
|
|
|
|
|
|
|
433,894 |
|
|
657 |
|
|
|
|
|
|
Deutsche Boerse AG |
|
|
|
|
|
|
|
|
|
|
50,519 |
|
|
107 |
|
|
|
@ |
|
|
Deutsche Lufthansa AG |
|
|
|
|
|
|
|
|
|
|
2,192 |
|
|
353 |
|
|
|
|
|
|
Deutsche Post AG |
|
|
|
|
|
|
|
|
|
|
6,491 |
|
|
54,879 |
|
|
|
|
|
|
Deutsche Telekom AG |
|
|
|
|
|
|
|
|
|
|
738,530 |
|
|
23,928 |
|
|
|
|
|
|
E.ON AG |
|
|
|
|
|
|
|
|
|
|
785,915 |
|
|
15 |
|
|
|
|
|
|
Fraport AG Frankfurt Airport Services Worldwide |
|
|
|
|
|
|
|
|
|
|
1,071 |
|
|
327 |
|
|
|
|
|
|
Fresenius AG |
|
|
|
|
|
|
|
|
|
|
29,892 |
|
|
111 |
|
|
|
|
|
|
Fresenius Medical Care AG & Co. KGaA |
|
|
|
|
|
|
|
|
|
|
7,362 |
|
|
108 |
|
|
|
|
|
|
GEA Group AG |
|
|
|
|
|
|
|
|
|
|
3,347 |
|
|
2,014 |
|
|
|
|
|
|
Hannover Rueckversicheru Reg |
|
|
|
|
|
|
|
|
|
|
117,369 |
|
|
143 |
|
|
|
|
|
|
HeidelbergCement AG |
|
|
|
|
|
|
|
|
|
|
10,043 |
|
|
7,019 |
|
|
|
|
|
|
Henkel KGaA Vorzug |
|
|
|
|
|
|
|
|
|
|
422,912 |
|
|
29 |
|
|
|
|
|
|
Hochtief AG |
|
|
|
|
|
|
|
|
|
|
2,861 |
|
|
18,819 |
|
|
|
|
|
|
Infineon Technologies AG |
|
|
|
|
|
|
|
|
|
|
206,737 |
|
|
149 |
|
|
|
|
|
|
K+S AG |
|
|
|
|
|
|
|
|
|
|
11,518 |
|
|
5,320 |
|
|
|
|
|
|
Lanxess |
|
|
|
|
|
|
|
|
|
|
396,416 |
|
|
183 |
|
|
|
|
|
|
Linde AG |
|
|
|
|
|
|
|
|
|
|
27,968 |
|
|
74 |
|
|
|
|
|
|
MAN AG |
|
|
|
|
|
|
|
|
|
|
9,431 |
|
|
10 |
|
|
|
|
|
|
Merck KGaA |
|
|
|
|
|
|
|
|
|
|
905 |
|
|
2,852 |
|
|
|
|
|
|
Metro AG |
|
|
|
|
|
|
|
|
|
|
208,955 |
|
|
2,390 |
|
|
|
|
|
|
Muenchener Rueckversicherungs AG |
|
|
|
|
|
|
|
|
|
|
399,601 |
|
|
3 |
|
|
|
|
|
|
Puma AG Rudolf Dassler Sport |
|
|
|
|
|
|
|
|
|
|
892 |
|
|
6,615 |
|
|
|
|
|
|
RWE AG |
|
|
|
|
|
|
|
|
|
|
447,336 |
|
|
42 |
|
|
|
|
|
|
Salzgitter AG |
|
|
|
|
|
|
|
|
|
|
3,495 |
|
|
9,092 |
|
|
|
|
|
|
SAP AG |
|
|
|
|
|
|
|
|
|
|
549,421 |
|
|
10,267 |
|
|
|
|
|
|
Siemens AG |
|
|
|
|
|
|
|
|
|
|
1,388,156 |
|
|
368 |
|
|
|
|
|
|
ThyssenKrupp AG |
|
|
|
|
|
|
|
|
|
|
15,358 |
|
|
6,880 |
|
|
|
@ |
|
|
TUI AG |
|
|
|
|
|
|
|
|
|
|
90,454 |
|
|
160 |
|
|
|
|
|
|
United Internet AG |
|
|
|
|
|
|
|
|
|
|
2,776 |
|
|
16 |
|
|
|
|
|
|
Volkswagen AG |
|
|
|
|
|
|
|
|
|
|
2,434 |
|
|
16 |
|
|
|
|
|
|
Wacker Chemie AG |
|
|
|
|
|
|
|
|
|
|
2,953 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
9,291,200 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Greece: |
|
|
|
|
|
|
0.2 |
% |
|
|
|
|
|
24,502 |
|
|
|
|
|
|
Public Power Corp. |
|
|
|
|
|
|
|
|
|
|
378,923 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
378,923 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Guernsey: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
33,398 |
|
|
|
|
|
|
Resolution Ltd. |
|
|
|
|
|
|
|
|
|
|
156,996 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
156,996 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Hong Kong: |
|
|
|
|
|
|
1.2 |
% |
|
|
|
|
|
38,170 |
|
|
|
@ |
|
|
AIA Group Ltd. |
|
|
|
|
|
|
|
|
|
|
111,256 |
|
|
1,000 |
|
|
|
|
|
|
Bank of East Asia Ltd. |
|
|
|
|
|
|
|
|
|
|
4,351 |
|
|
56,000 |
|
|
|
|
|
|
BOC Hong Kong Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
174,140 |
|
|
162,000 |
|
|
|
|
|
|
Cathay Pacific Airways Ltd. |
|
|
|
|
|
|
|
|
|
|
377,779 |
|
|
11,000 |
|
|
|
|
|
|
Cheung Kong Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
172,271 |
|
|
22,500 |
|
|
|
|
|
|
CLP Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
183,121 |
|
|
500 |
|
|
|
|
|
|
Esprit Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
2,467 |
|
|
41,000 |
|
|
|
|
|
|
Hang Lung Properties Ltd. |
|
|
|
|
|
|
|
|
|
|
175,647 |
|
|
3,300 |
|
|
|
|
|
|
Hang Seng Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
52,702 |
|
|
9,000 |
|
|
|
|
|
|
Henderson Land Development Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
57,482 |
|
|
3,000 |
|
|
|
|
|
|
Hong Kong & China Gas |
|
|
|
|
|
|
|
|
|
|
6,731 |
|
|
5,700 |
|
|
|
|
|
|
Hong Kong Exchanges and Clearing Ltd. |
|
|
|
|
|
|
|
|
|
|
123,921 |
|
|
34,500 |
|
|
|
|
|
|
HongKong Electric Holdings |
|
|
|
|
|
|
|
|
|
|
225,260 |
|
|
13,000 |
|
|
|
|
|
|
Hutchison Whampoa Ltd. |
|
|
|
|
|
|
|
|
|
|
153,612 |
|
|
23,000 |
|
|
|
|
|
|
Hysan Development Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
103,897 |
|
|
500 |
|
|
|
|
|
|
Kerry Properties Ltd. |
|
|
|
|
|
|
|
|
|
|
2,439 |
|
|
32,000 |
|
|
|
|
|
|
Li & Fung Ltd. |
|
|
|
|
|
|
|
|
|
|
195,519 |
|
|
2,000 |
|
|
|
|
|
|
New World Development Ltd. |
|
|
|
|
|
|
|
|
|
|
3,624 |
|
|
1,000 |
|
|
|
|
|
|
Noble Group Ltd. |
|
|
|
|
|
|
|
|
|
|
1,622 |
|
|
4,500 |
|
|
|
|
|
|
Orient Overseas International Ltd. |
|
|
|
|
|
|
|
|
|
|
36,403 |
|
|
240,000 |
|
|
|
|
|
|
PCCW Ltd. |
|
|
|
|
|
|
|
|
|
|
103,927 |
|
|
2,000 |
|
|
|
|
|
|
Sino Land Co. |
|
|
|
|
|
|
|
|
|
|
3,654 |
|
|
19,000 |
|
|
|
|
|
|
Sun Hung Kai Properties Ltd. |
|
|
|
|
|
|
|
|
|
|
309,273 |
|
|
12,000 |
|
|
|
|
|
|
Swire Pacific Ltd. |
|
|
|
|
|
|
|
|
|
|
168,561 |
|
|
27,000 |
|
|
|
|
|
|
Wharf Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
178,040 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
2,927,699 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
17
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
|
|
|
|
|
|
|
Ireland: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
3,883 |
|
|
|
|
|
|
CRH PLC |
|
|
|
|
|
|
|
|
|
|
89,429 |
|
|
3,500 |
|
|
|
|
|
|
Ingersoll-Rand PLC |
|
|
|
|
|
|
|
|
|
|
158,550 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
247,979 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Israel: |
|
|
|
|
|
|
0.3 |
% |
|
|
|
|
|
30,166 |
|
|
|
|
|
|
Bank Leumi Le-Israel BM |
|
|
|
|
|
|
|
|
|
|
139,000 |
|
|
11,693 |
|
|
|
|
|
|
Bezeq Israeli Telecommunication Corp., Ltd. |
|
|
|
|
|
|
|
|
|
|
31,729 |
|
|
5,618 |
|
|
|
|
|
|
Israel Chemicals Ltd. |
|
|
|
|
|
|
|
|
|
|
93,553 |
|
|
28,733 |
|
|
|
@ |
|
|
Israel Discount Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
58,208 |
|
|
10,487 |
|
|
|
|
|
|
Mizrahi Tefahot Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
106,319 |
|
|
7,690 |
|
|
|
|
|
|
Teva Phaemaceutical Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
386,244 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
815,053 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Italy: |
|
|
|
|
|
|
1.2 |
% |
|
|
|
|
|
2,231 |
|
|
|
|
|
|
AEM S.p.A. |
|
|
|
|
|
|
|
|
|
|
3,572 |
|
|
8,806 |
|
|
|
|
|
|
Assicurazioni Generali S.p.A. |
|
|
|
|
|
|
|
|
|
|
199,282 |
|
|
2,124 |
|
|
|
@ |
|
|
Banca Monte dei Paschi di Siena S.p.A. |
|
|
|
|
|
|
|
|
|
|
2,831 |
|
|
13,735 |
|
|
|
|
|
|
Banco Popolare Scarl |
|
|
|
|
|
|
|
|
|
|
47,950 |
|
|
133,267 |
|
|
|
|
|
|
Enel S.p.A. |
|
|
|
|
|
|
|
|
|
|
794,179 |
|
|
32,016 |
|
|
|
|
|
|
ENI S.p.A. |
|
|
|
|
|
|
|
|
|
|
780,637 |
|
|
10,064 |
|
|
|
|
|
|
Fiat S.p.A |
|
|
|
|
|
|
|
|
|
|
93,461 |
|
|
96,085 |
|
|
|
|
|
|
Intesa Sanpaolo S.p.A. |
|
|
|
|
|
|
|
|
|
|
324,239 |
|
|
844 |
|
|
|
|
|
|
Intesa Sanpaolo S.p.A. RNC |
|
|
|
|
|
|
|
|
|
|
2,473 |
|
|
1,480 |
|
|
|
|
|
|
Pirelli & C S.p.A. |
|
|
|
|
|
|
|
|
|
|
11,930 |
|
|
828 |
|
|
|
|
|
|
Saipem S.p.A. |
|
|
|
|
|
|
|
|
|
|
41,829 |
|
|
3,007 |
|
|
|
|
|
|
Snam Rete Gas S.p.A. |
|
|
|
|
|
|
|
|
|
|
16,453 |
|
|
231,825 |
|
|
|
|
|
|
Telecom Italia S.p.A. |
|
|
|
|
|
|
|
|
|
|
361,932 |
|
|
146,874 |
|
|
|
|
|
|
Telecom Italia S.p.A. RNC |
|
|
|
|
|
|
|
|
|
|
194,397 |
|
|
2,778 |
|
|
|
|
|
|
Terna S.p.A |
|
|
|
|
|
|
|
|
|
|
12,815 |
|
|
89,687 |
|
|
|
|
|
|
UniCredito Italiano S.p.A. |
|
|
|
|
|
|
|
|
|
|
230,749 |
|
|
583 |
|
|
|
|
|
|
Unione di Banche Italiane SCPA |
|
|
|
|
|
|
|
|
|
|
5,892 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
3,124,621 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Japan: |
|
|
|
|
|
|
9.4 |
% |
|
|
|
|
|
17,000 |
|
|
|
|
|
|
77 Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
107,304 |
|
|
400 |
|
|
|
|
|
|
Advantest Corp. |
|
|
|
|
|
|
|
|
|
|
8,342 |
|
|
1,000 |
|
|
|
|
|
|
Aeon Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
12,617 |
|
|
6,500 |
|
|
|
|
|
|
Aisin Seiki Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
248,953 |
|
|
1,000 |
|
|
|
@ |
|
|
All Nippon Airways Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,617 |
|
|
300 |
|
|
|
|
|
|
Asahi Breweries Ltd. |
|
|
|
|
|
|
|
|
|
|
5,799 |
|
|
21,050 |
|
|
|
|
|
|
Asahi Glass Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
294,327 |
|
|
1,000 |
|
|
|
|
|
|
Asahi Kasei Corp. |
|
|
|
|
|
|
|
|
|
|
6,935 |
|
|
9,900 |
|
|
|
|
|
|
Astellas Pharma, Inc. |
|
|
|
|
|
|
|
|
|
|
389,279 |
|
|
11,000 |
|
|
|
|
|
|
Bank of Kyoto Ltd. |
|
|
|
|
|
|
|
|
|
|
106,026 |
|
|
1,000 |
|
|
|
|
|
|
Bank of Yokohama Ltd. |
|
|
|
|
|
|
|
|
|
|
5,398 |
|
|
14,500 |
|
|
|
|
|
|
Bridgestone Corp. |
|
|
|
|
|
|
|
|
|
|
298,156 |
|
|
13,200 |
|
|
|
|
|
|
Brother Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
208,477 |
|
|
13,400 |
|
|
|
|
|
|
Canon, Inc. |
|
|
|
|
|
|
|
|
|
|
648,016 |
|
|
300 |
|
|
|
|
|
|
Casio Computer Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,661 |
|
|
33 |
|
|
|
|
|
|
Central Japan Railway Co. |
|
|
|
|
|
|
|
|
|
|
295,768 |
|
|
1,000 |
|
|
|
|
|
|
Chiba Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
6,862 |
|
|
600 |
|
|
|
|
|
|
Chubu Electric Power Co., Inc. |
|
|
|
|
|
|
|
|
|
|
15,837 |
|
|
200 |
|
|
|
|
|
|
Chugai Pharmaceutical Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,854 |
|
|
300 |
|
|
|
|
|
|
Chugoku Electric Power Co., Inc. |
|
|
|
|
|
|
|
|
|
|
6,435 |
|
|
1,000 |
|
|
|
|
|
|
Chuo Mitsui Trust Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
4,271 |
|
|
300 |
|
|
|
|
|
|
Citizen Watch Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
1,946 |
|
|
36,000 |
|
|
|
|
|
|
Cosmo Oil Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
130,770 |
|
|
200 |
|
|
|
|
|
|
Credit Saison Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,927 |
|
|
14,000 |
|
|
|
|
|
|
Daihatsu Motor Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
221,416 |
|
|
107 |
|
|
|
|
|
|
Dai-ichi Life Insurance Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
193,530 |
|
|
500 |
|
|
|
|
|
|
Daiichi Sankyo Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
10,738 |
|
|
300 |
|
|
|
|
|
|
Daikin Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
10,186 |
|
|
100 |
|
|
|
|
|
|
Dainippon Sumitomo Pharma Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
972 |
|
|
1,900 |
|
|
|
|
|
|
Daito Trust Construction Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
155,693 |
|
|
2,000 |
|
|
|
|
|
|
Daiwa Securities Group, Inc. |
|
|
|
|
|
|
|
|
|
|
10,819 |
|
|
1,000 |
|
|
|
|
|
|
Denki Kagaku Kogyo K K |
|
|
|
|
|
|
|
|
|
|
5,388 |
|
|
500 |
|
|
|
|
|
|
Denso Corp. |
|
|
|
|
|
|
|
|
|
|
18,784 |
|
|
3,100 |
|
|
|
|
|
|
Dentsu, Inc. |
|
|
|
|
|
|
|
|
|
|
98,969 |
|
|
8,981 |
|
|
|
|
|
|
East Japan Railway Co. |
|
|
|
|
|
|
|
|
|
|
626,240 |
|
|
200 |
|
|
|
|
|
|
Eisai Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
7,492 |
|
|
10,600 |
|
|
|
|
|
|
Electric Power Development Co. |
|
|
|
|
|
|
|
|
|
|
334,895 |
|
|
300 |
|
|
|
@ |
|
|
Elpida Memory, Inc. |
|
|
|
|
|
|
|
|
|
|
4,527 |
|
|
100 |
|
|
|
|
|
|
FamilyMart Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,787 |
|
|
200 |
|
|
|
|
|
|
Fanuc Ltd. |
|
|
|
|
|
|
|
|
|
|
31,242 |
|
|
1,000 |
|
|
|
|
|
|
Fuji Electric Holdings Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,395 |
|
|
1,000 |
|
|
|
|
|
|
Fuji Heavy Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
8,617 |
|
|
500 |
|
|
|
|
|
|
Fuji Photo Film Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
17,604 |
|
|
2,000 |
|
|
|
|
|
|
Fujitsu Ltd. |
|
|
|
|
|
|
|
|
|
|
13,562 |
|
|
25,000 |
|
|
|
|
|
|
Fukuoka Financial Group, Inc. |
|
|
|
|
|
|
|
|
|
|
113,521 |
|
|
1,000 |
|
|
|
|
|
|
Furukawa Electric Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
4,271 |
|
|
18,000 |
|
|
|
|
|
|
Gunma Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
111,467 |
|
18
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
9,000 |
|
|
|
|
|
|
Hachijuni Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
57,141 |
|
|
100 |
|
|
|
|
|
|
Hitachi Chemical Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,324 |
|
|
100 |
|
|
|
|
|
|
Hitachi Construction Machinery Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,511 |
|
|
4,000 |
|
|
|
|
|
|
Hitachi Ltd. |
|
|
|
|
|
|
|
|
|
|
24,346 |
|
|
200 |
|
|
|
|
|
|
Hokkaido Electric Power Co., Inc. |
|
|
|
|
|
|
|
|
|
|
4,296 |
|
|
200 |
|
|
|
|
|
|
Hokuriku Electric Power Co. |
|
|
|
|
|
|
|
|
|
|
5,043 |
|
|
11,000 |
|
|
|
|
|
|
Honda Motor Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
480,064 |
|
|
500 |
|
|
|
|
|
|
Hoya Corp. |
|
|
|
|
|
|
|
|
|
|
11,997 |
|
|
9,900 |
|
|
|
|
|
|
Ibiden Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
343,373 |
|
|
1,900 |
|
|
|
|
|
|
Idemitsu Kosan Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
224,670 |
|
|
1 |
|
|
|
|
|
|
Inpex Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
7,027 |
|
|
100 |
|
|
|
|
|
|
Isetan Mitsukoshi Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
1,212 |
|
|
1,000 |
|
|
|
|
|
|
Ishikawajima Harima Heavy Industries Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,631 |
|
|
1,000 |
|
|
|
|
|
|
Isuzu Motors Ltd. |
|
|
|
|
|
|
|
|
|
|
4,522 |
|
|
47,900 |
|
|
|
|
|
|
Itochu Corp. |
|
|
|
|
|
|
|
|
|
|
498,116 |
|
|
101 |
|
|
|
|
|
|
Japan Tobacco, Inc. |
|
|
|
|
|
|
|
|
|
|
417,797 |
|
|
14,700 |
|
|
|
|
|
|
JFE Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
465,540 |
|
|
300 |
|
|
|
|
|
|
JS Group Corp. |
|
|
|
|
|
|
|
|
|
|
7,307 |
|
|
200 |
|
|
|
|
|
|
JSR Corp. |
|
|
|
|
|
|
|
|
|
|
4,301 |
|
|
200 |
|
|
|
|
|
|
JTEKT Corp. |
|
|
|
|
|
|
|
|
|
|
2,960 |
|
|
600 |
|
|
|
|
|
|
JX Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
4,227 |
|
|
1,000 |
|
|
|
|
|
|
Kajima Corp. |
|
|
|
|
|
|
|
|
|
|
2,681 |
|
|
17,700 |
|
|
|
|
|
|
Kansai Electric Power Co., Inc. |
|
|
|
|
|
|
|
|
|
|
464,854 |
|
|
18,000 |
|
|
|
|
|
|
Kansai Paint Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
171,467 |
|
|
9,000 |
|
|
|
|
|
|
Kao Corp. |
|
|
|
|
|
|
|
|
|
|
243,098 |
|
|
1,000 |
|
|
|
|
|
|
Kawasaki Heavy Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
4,047 |
|
|
1,000 |
|
|
|
|
|
|
Kawasaki Kisen Kaisha Ltd. |
|
|
|
|
|
|
|
|
|
|
4,376 |
|
|
10 |
|
|
|
|
|
|
KDDI Corp. |
|
|
|
|
|
|
|
|
|
|
64,941 |
|
|
1,000 |
|
|
|
|
|
|
Keio Corp. |
|
|
|
|
|
|
|
|
|
|
6,693 |
|
|
400 |
|
|
|
|
|
|
Keyence Corp. |
|
|
|
|
|
|
|
|
|
|
109,499 |
|
|
2,000 |
|
|
|
|
|
|
Kintetsu Corp. |
|
|
|
|
|
|
|
|
|
|
6,323 |
|
|
1,000 |
|
|
|
@ |
|
|
Kirin Brewery Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
14,318 |
|
|
2,000 |
|
|
|
|
|
|
Kobe Steel Ltd. |
|
|
|
|
|
|
|
|
|
|
5,474 |
|
|
1,000 |
|
|
|
|
|
|
Komatsu Ltd. |
|
|
|
|
|
|
|
|
|
|
30,679 |
|
|
500 |
|
|
|
|
|
|
Konica Minolta Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
4,632 |
|
|
1,000 |
|
|
|
|
|
|
Kubota Corp. |
|
|
|
|
|
|
|
|
|
|
10,308 |
|
|
400 |
|
|
|
|
|
|
Kuraray Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
5,681 |
|
|
100 |
|
|
|
|
|
|
Kurita Water Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
2,845 |
|
|
200 |
|
|
|
|
|
|
Kyocera Corp. |
|
|
|
|
|
|
|
|
|
|
20,879 |
|
|
14,800 |
|
|
|
|
|
|
Kyushu Electric Power Co., Inc. |
|
|
|
|
|
|
|
|
|
|
343,843 |
|
|
100 |
|
|
|
|
|
|
Lawson, Inc. |
|
|
|
|
|
|
|
|
|
|
4,924 |
|
|
100 |
|
|
|
|
|
|
Makita Corp. |
|
|
|
|
|
|
|
|
|
|
4,234 |
|
|
62,000 |
|
|
|
|
|
|
Marubeni Corp. |
|
|
|
|
|
|
|
|
|
|
475,884 |
|
|
87,000 |
|
|
|
|
|
|
Mazda Motor Corp. |
|
|
|
|
|
|
|
|
|
|
225,316 |
|
|
3,300 |
|
|
|
|
|
|
McDonalds Holdings Co. Japan Ltd. |
|
|
|
|
|
|
|
|
|
|
80,957 |
|
|
19,000 |
|
|
|
|
|
|
Minebea Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
113,031 |
|
|
5,986 |
|
|
|
|
|
|
Miraca Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
231,592 |
|
|
1,000 |
|
|
|
|
|
|
Mitsubishi Chemical Holdings Corp. |
|
|
|
|
|
|
|
|
|
|
7,334 |
|
|
24,700 |
|
|
|
|
|
|
Mitsubishi Corp. |
|
|
|
|
|
|
|
|
|
|
687,210 |
|
|
2,000 |
|
|
|
|
|
|
Mitsubishi Electric Corp. |
|
|
|
|
|
|
|
|
|
|
23,765 |
|
|
6,000 |
|
|
|
|
|
|
Mitsubishi Estate Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
123,018 |
|
|
3,000 |
|
|
|
|
|
|
Mitsubishi Heavy Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
12,774 |
|
|
1,000 |
|
|
|
@ |
|
|
Mitsubishi Materials Corp. |
|
|
|
|
|
|
|
|
|
|
3,873 |
|
|
26,000 |
|
|
|
@ |
|
|
Mitsubishi Motors Corp. |
|
|
|
|
|
|
|
|
|
|
37,008 |
|
|
200 |
|
|
|
|
|
|
Mitsubishi Tanabe Pharma Corp. |
|
|
|
|
|
|
|
|
|
|
3,391 |
|
|
128,400 |
|
|
|
|
|
|
Mitsubishi UFJ Financial Group, Inc. |
|
|
|
|
|
|
|
|
|
|
713,264 |
|
|
2,430 |
|
|
|
|
|
|
Mitsubishi UFJ Lease & Finance Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
107,968 |
|
|
35,900 |
|
|
|
|
|
|
Mitsui & Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
656,251 |
|
|
1,000 |
|
|
|
|
|
|
Mitsui Chemicals, Inc. |
|
|
|
|
|
|
|
|
|
|
3,756 |
|
|
1,000 |
|
|
|
|
|
|
Mitsui Engineering & Shipbuilding Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,764 |
|
|
3,497 |
|
|
|
|
|
|
Mitsui Fudosan Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
74,736 |
|
|
1,000 |
|
|
|
|
|
|
Mitsui Mining & Smelting Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,980 |
|
|
1,000 |
|
|
|
|
|
|
Mitsui OSK Lines Ltd. |
|
|
|
|
|
|
|
|
|
|
6,650 |
|
|
1,700 |
|
|
|
|
|
|
Mitsui Sumitomo Insurance Group Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
44,904 |
|
|
100 |
|
|
|
|
|
|
Mitsumi Electric Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
1,662 |
|
|
143,403 |
|
|
|
|
|
|
Mizuho Financial Group, Inc. |
|
|
|
|
|
|
|
|
|
|
295,601 |
|
|
32,000 |
|
|
|
|
|
|
Mizuho Securities Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
98,808 |
|
|
5,700 |
|
|
|
|
|
|
Murata Manufacturing Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
424,928 |
|
|
200 |
|
|
|
|
|
|
Namco Bandai Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
2,361 |
|
|
3,000 |
|
|
|
|
|
|
NEC Corp. |
|
|
|
|
|
|
|
|
|
|
8,285 |
|
|
6,000 |
|
|
|
|
|
|
NGK Spark Plug Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
89,892 |
|
|
100 |
|
|
|
|
|
|
Nidec Corp. |
|
|
|
|
|
|
|
|
|
|
9,328 |
|
|
300 |
|
|
|
|
|
|
Nikon Corp. |
|
|
|
|
|
|
|
|
|
|
7,047 |
|
|
300 |
|
|
|
|
|
|
Nintendo Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
88,226 |
|
|
17,000 |
|
|
|
|
|
|
Nippon Express Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
73,471 |
|
|
1,200 |
|
|
|
|
|
|
Nippon Paper Group, Inc. |
|
|
|
|
|
|
|
|
|
|
33,006 |
|
|
1,000 |
|
|
|
|
|
|
Nippon Sheet Glass Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,879 |
|
|
5,000 |
|
|
|
|
|
|
Nippon Steel Corp. |
|
|
|
|
|
|
|
|
|
|
18,184 |
|
|
8,000 |
|
|
|
|
|
|
Nippon Telegraph & Telephone Corp. |
|
|
|
|
|
|
|
|
|
|
391,343 |
|
19
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
2,000 |
|
|
|
|
|
|
Nippon Yusen KK |
|
|
|
|
|
|
|
|
|
|
8,846 |
|
|
35,163 |
|
|
|
|
|
|
Nishi-Nippon City Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
117,698 |
|
|
200 |
|
|
|
|
|
|
Nissan Chemical Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
2,335 |
|
|
5,100 |
|
|
|
|
|
|
Nissan Motor Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
52,403 |
|
|
12,000 |
|
|
|
|
|
|
Nisshin Seifun Group, Inc. |
|
|
|
|
|
|
|
|
|
|
158,304 |
|
|
100 |
|
|
|
|
|
|
Nitto Denko Corp. |
|
|
|
|
|
|
|
|
|
|
6,064 |
|
|
1,579 |
|
|
|
@ |
|
|
NKSJ Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
11,944 |
|
|
100 |
|
|
|
|
|
|
NOK Corp. |
|
|
|
|
|
|
|
|
|
|
1,993 |
|
|
21,100 |
|
|
|
|
|
|
Nomura Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
133,807 |
|
|
100 |
|
|
|
|
|
|
Nomura Real Estate Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
2,036 |
|
|
1,000 |
|
|
|
|
|
|
NSK Ltd. |
|
|
|
|
|
|
|
|
|
|
9,569 |
|
|
1,000 |
|
|
|
|
|
|
NTN Corp. |
|
|
|
|
|
|
|
|
|
|
5,384 |
|
|
19 |
|
|
|
|
|
|
NTT Data Corp. |
|
|
|
|
|
|
|
|
|
|
67,905 |
|
|
26 |
|
|
|
|
|
|
NTT DoCoMo, Inc. |
|
|
|
|
|
|
|
|
|
|
48,843 |
|
|
99 |
|
|
|
|
|
|
NTT Urban Development Corp. |
|
|
|
|
|
|
|
|
|
|
103,182 |
|
|
1,000 |
|
|
|
|
|
|
Obayashi Corp. |
|
|
|
|
|
|
|
|
|
|
4,499 |
|
|
1,522 |
|
|
|
|
|
|
Obic Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
307,160 |
|
|
1,000 |
|
|
|
|
|
|
Odakyu Electric Railway Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
9,325 |
|
|
1,000 |
|
|
|
|
|
|
OJI Paper Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
4,978 |
|
|
100 |
|
|
|
|
|
|
Olympus Corp. |
|
|
|
|
|
|
|
|
|
|
2,939 |
|
|
200 |
|
|
|
|
|
|
Omron Corp. |
|
|
|
|
|
|
|
|
|
|
5,577 |
|
|
100 |
|
|
|
|
|
|
Ono Pharmaceutical Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
5,236 |
|
|
1,670 |
|
|
|
|
|
|
ORIX Corp. |
|
|
|
|
|
|
|
|
|
|
188,078 |
|
|
2,000 |
|
|
|
|
|
|
Osaka Gas Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
7,616 |
|
|
47,300 |
|
|
|
|
|
|
Panasonic Corp. |
|
|
|
|
|
|
|
|
|
|
638,926 |
|
|
1 |
|
|
|
|
|
|
Rakuten, Inc. |
|
|
|
|
|
|
|
|
|
|
889 |
|
|
700 |
|
|
|
|
|
|
Resona Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
3,824 |
|
|
26,000 |
|
|
|
|
|
|
Ricoh Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
346,916 |
|
|
200 |
|
|
|
|
|
|
Rohm Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
14,135 |
|
|
5,700 |
|
|
|
|
|
|
Sankyo Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
322,839 |
|
|
100 |
|
|
|
|
|
|
Santen Pharmaceutical Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,912 |
|
|
100 |
|
|
|
|
|
|
Secom Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
5,048 |
|
|
200 |
|
|
|
|
|
|
Sega Sammy Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
4,564 |
|
|
200 |
|
|
|
|
|
|
Seiko Epson Corp. |
|
|
|
|
|
|
|
|
|
|
3,364 |
|
|
1,000 |
|
|
|
|
|
|
Sekisui Chemical Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
7,902 |
|
|
1,000 |
|
|
|
|
|
|
Sekisui House Ltd. |
|
|
|
|
|
|
|
|
|
|
10,375 |
|
|
12,500 |
|
|
|
|
|
|
Seven & I Holdings Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
348,915 |
|
|
49 |
|
|
|
|
|
|
Seven Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
105,051 |
|
|
1,000 |
|
|
|
|
|
|
Sharp Corp. |
|
|
|
|
|
|
|
|
|
|
10,895 |
|
|
200 |
|
|
|
|
|
|
Shikoku Electric Power Co. |
|
|
|
|
|
|
|
|
|
|
6,053 |
|
|
100 |
|
|
|
|
|
|
Shimano, Inc. |
|
|
|
|
|
|
|
|
|
|
4,980 |
|
|
1,000 |
|
|
|
|
|
|
Shimizu Corp. |
|
|
|
|
|
|
|
|
|
|
4,300 |
|
|
9,300 |
|
|
|
|
|
|
Shin-Etsu Chemical Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
537,678 |
|
|
14,100 |
|
|
|
|
|
|
Shinko Electric Industries |
|
|
|
|
|
|
|
|
|
|
165,157 |
|
|
1,000 |
|
|
|
|
|
|
Shinsei Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
1,280 |
|
|
200 |
|
|
|
|
|
|
Shionogi & Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,800 |
|
|
200 |
|
|
|
|
|
|
Shiseido Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
4,082 |
|
|
1,000 |
|
|
|
|
|
|
Shizuoka Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
9,425 |
|
|
2,000 |
|
|
|
|
|
|
Showa Denko KK |
|
|
|
|
|
|
|
|
|
|
4,409 |
|
|
100 |
|
|
|
|
|
|
Showa Shell Sekiyu KK |
|
|
|
|
|
|
|
|
|
|
907 |
|
|
100 |
|
|
|
|
|
|
SMC Corp. |
|
|
|
|
|
|
|
|
|
|
17,165 |
|
|
10,500 |
|
|
|
|
|
|
Softbank Corp. |
|
|
|
|
|
|
|
|
|
|
431,698 |
|
|
28 |
|
|
|
|
|
|
Softbank Investment Corp. |
|
|
|
|
|
|
|
|
|
|
4,436 |
|
|
1,300 |
|
|
|
|
|
|
Sojitz Corp. |
|
|
|
|
|
|
|
|
|
|
2,932 |
|
|
1,200 |
|
|
|
|
|
|
Sony Corp. |
|
|
|
|
|
|
|
|
|
|
44,182 |
|
|
1 |
|
|
|
|
|
|
Sony Financial Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
4,262 |
|
|
200 |
|
|
|
|
|
|
Stanley Electric Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
3,684 |
|
|
200 |
|
|
|
|
|
|
Sumco Corp. |
|
|
|
|
|
|
|
|
|
|
3,678 |
|
|
2,000 |
|
|
|
|
|
|
Sumitomo Chemical Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
10,825 |
|
|
34,300 |
|
|
|
|
|
|
Sumitomo Corp. |
|
|
|
|
|
|
|
|
|
|
509,602 |
|
|
800 |
|
|
|
|
|
|
Sumitomo Electric Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
11,740 |
|
|
1,000 |
|
|
|
|
|
|
Sumitomo Heavy Industries |
|
|
|
|
|
|
|
|
|
|
7,054 |
|
|
3,000 |
|
|
|
|
|
|
Sumitomo Metal Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
7,623 |
|
|
6,000 |
|
|
|
|
|
|
Sumitomo Metal Mining Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
113,666 |
|
|
10,000 |
|
|
|
|
|
|
Sumitomo Mitsui Financial Group, Inc. |
|
|
|
|
|
|
|
|
|
|
378,417 |
|
|
200 |
|
|
|
|
|
|
Sumitomo Rubber Industries, Inc. |
|
|
|
|
|
|
|
|
|
|
2,169 |
|
|
1,000 |
|
|
|
|
|
|
Sumitomo Trust & Banking Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
6,372 |
|
|
1,700 |
|
|
|
|
|
|
Suzuki Motor Corp. |
|
|
|
|
|
|
|
|
|
|
40,406 |
|
|
5,750 |
|
|
|
|
|
|
T&D Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
166,992 |
|
|
1,000 |
|
|
|
|
|
|
Taisei Corp. |
|
|
|
|
|
|
|
|
|
|
2,372 |
|
|
12,632 |
|
|
|
|
|
|
Takeda Pharmaceutical Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
629,326 |
|
|
3,300 |
|
|
|
|
|
|
TDK Corp. |
|
|
|
|
|
|
|
|
|
|
223,375 |
|
|
1,000 |
|
|
|
|
|
|
Teijin Ltd. |
|
|
|
|
|
|
|
|
|
|
4,847 |
|
|
100 |
|
|
|
|
|
|
Terumo Corp. |
|
|
|
|
|
|
|
|
|
|
5,492 |
|
|
100 |
|
|
|
|
|
|
THK Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,645 |
|
|
1,000 |
|
|
|
|
|
|
Tobu Railway Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
4,871 |
|
|
400 |
|
|
|
|
|
|
Tohoku Electric Power Co., Inc. |
|
|
|
|
|
|
|
|
|
|
9,319 |
|
|
9,189 |
|
|
|
|
|
|
Tokio Marine Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
302,132 |
|
|
2,500 |
|
|
|
|
|
|
Tokyo Electric Power Co., Inc. |
|
|
|
|
|
|
|
|
|
|
64,712 |
|
20
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
1,200 |
|
|
|
|
|
|
Tokyo Electron Ltd. |
|
|
|
|
|
|
|
|
|
|
78,936 |
|
|
3,000 |
|
|
|
|
|
|
Tokyo Gas Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
13,412 |
|
|
100 |
|
|
|
|
|
|
Tokyo Steel Manufacturing Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
1,117 |
|
|
23,000 |
|
|
|
|
|
|
Tokyo Tatemono Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
108,573 |
|
|
2,000 |
|
|
|
|
|
|
Tokyu Corp. |
|
|
|
|
|
|
|
|
|
|
9,289 |
|
|
21,000 |
|
|
|
|
|
|
Toppan Printing Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
193,209 |
|
|
1,000 |
|
|
|
|
|
|
Toray Industries, Inc. |
|
|
|
|
|
|
|
|
|
|
7,591 |
|
|
4,000 |
|
|
|
|
|
|
Toshiba Corp. |
|
|
|
|
|
|
|
|
|
|
26,284 |
|
|
1,000 |
|
|
|
|
|
|
Tosoh Corp. |
|
|
|
|
|
|
|
|
|
|
3,594 |
|
|
20,800 |
|
|
|
|
|
|
Toyo Seikan Kaisha Ltd. |
|
|
|
|
|
|
|
|
|
|
382,752 |
|
|
2,200 |
|
|
|
|
|
|
Toyoda Gosei Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
51,834 |
|
|
100 |
|
|
|
|
|
|
Toyota Boshoku Corp. |
|
|
|
|
|
|
|
|
|
|
1,671 |
|
|
200 |
|
|
|
|
|
|
Toyota Industries Corp. |
|
|
|
|
|
|
|
|
|
|
6,937 |
|
|
25,400 |
|
|
|
|
|
|
Toyota Motor Corp. |
|
|
|
|
|
|
|
|
|
|
1,186,876 |
|
|
200 |
|
|
|
|
|
|
Toyota Tsusho Corp. |
|
|
|
|
|
|
|
|
|
|
3,798 |
|
|
100 |
|
|
|
|
|
|
Tsumura & Co. |
|
|
|
|
|
|
|
|
|
|
3,244 |
|
|
1,000 |
|
|
|
|
|
|
Ube Industries Ltd. |
|
|
|
|
|
|
|
|
|
|
3,249 |
|
|
100 |
|
|
|
|
|
|
Uni-Charm Corp. |
|
|
|
|
|
|
|
|
|
|
3,872 |
|
|
300 |
|
|
|
|
|
|
UNY Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,994 |
|
|
100 |
|
|
|
|
|
|
Ushio, Inc. |
|
|
|
|
|
|
|
|
|
|
2,056 |
|
|
4,530 |
|
|
|
|
|
|
USS Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
367,593 |
|
|
2 |
|
|
|
|
|
|
West Japan Railway Co. |
|
|
|
|
|
|
|
|
|
|
8,309 |
|
|
3 |
|
|
|
|
|
|
Yahoo! Japan Corp. |
|
|
|
|
|
|
|
|
|
|
1,131 |
|
|
100 |
|
|
|
|
|
|
Yakult Honsha Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
2,830 |
|
|
10 |
|
|
|
|
|
|
Yamada Denki Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
764 |
|
|
11,000 |
|
|
|
|
|
|
Yamaguchi Financial Group, Inc. |
|
|
|
|
|
|
|
|
|
|
114,092 |
|
|
200 |
|
|
|
|
|
|
Yamaha Corp. |
|
|
|
|
|
|
|
|
|
|
2,578 |
|
|
300 |
|
|
|
@ |
|
|
Yamaha Motor Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
5,336 |
|
|
500 |
|
|
|
|
|
|
Yamato Holdings Co., Ltd. |
|
|
|
|
|
|
|
|
|
|
8,047 |
|
|
300 |
|
|
|
|
|
|
Yokogawa Electric Corp. |
|
|
|
|
|
|
|
|
|
|
2,330 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
23,559,979 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Kazakhstan: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
11,841 |
|
|
|
|
|
|
Eurasian Natural Resources Corp. |
|
|
|
|
|
|
|
|
|
|
185,783 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
185,783 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Luxembourg: |
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
1,235 |
|
|
|
|
|
|
ArcelorMittal |
|
|
|
|
|
|
|
|
|
|
45,357 |
|
|
402 |
|
|
|
|
|
|
SES S.A. |
|
|
|
|
|
|
|
|
|
|
10,351 |
|
|
1,581 |
|
|
|
|
|
|
Tenaris S.A. |
|
|
|
|
|
|
|
|
|
|
35,721 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
91,429 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Macau: |
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
11,200 |
|
|
|
@ |
|
|
Wynn Macau Ltd. |
|
|
|
|
|
|
|
|
|
|
30,484 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
30,484 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Malaysia: |
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
17,000 |
|
|
|
@ |
|
|
Genting International PLC |
|
|
|
|
|
|
|
|
|
|
25,599 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
25,599 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Mauritius: |
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
4,000 |
|
|
|
|
|
|
Golden Agri-Resources Ltd. |
|
|
|
|
|
|
|
|
|
|
2,052 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
2,052 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Mexico: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
6,288 |
|
|
|
|
|
|
Fresnillo PLC |
|
|
|
|
|
|
|
|
|
|
163,147 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
163,147 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Netherlands: |
|
|
|
|
|
|
2.0 |
% |
|
|
|
|
|
4,943 |
|
|
|
@ |
|
|
Aegon NV |
|
|
|
|
|
|
|
|
|
|
38,048 |
|
|
159 |
|
|
|
|
|
|
Akzo Nobel NV |
|
|
|
|
|
|
|
|
|
|
10,808 |
|
|
11,609 |
|
|
|
|
|
|
ASML Holding NV |
|
|
|
|
|
|
|
|
|
|
505,642 |
|
|
4,416 |
|
|
|
|
|
|
Delta Lloyd NV |
|
|
|
|
|
|
|
|
|
|
106,849 |
|
|
108 |
|
|
|
@ |
|
|
European Aeronautic Defence and Space Co. NV |
|
|
|
|
|
|
|
|
|
|
3,124 |
|
|
134 |
|
|
|
|
|
|
Heineken Holding NV |
|
|
|
|
|
|
|
|
|
|
6,156 |
|
|
297 |
|
|
|
|
|
|
Heineken NV |
|
|
|
|
|
|
|
|
|
|
15,317 |
|
|
1,092 |
|
|
|
|
|
|
Koninklijke Ahold NV |
|
|
|
|
|
|
|
|
|
|
14,668 |
|
|
65 |
|
|
|
|
|
|
Koninklijke Boskalis Westminster NV |
|
|
|
|
|
|
|
|
|
|
3,378 |
|
|
108 |
|
|
|
|
|
|
Koninklijke DSM NV |
|
|
|
|
|
|
|
|
|
|
6,344 |
|
|
27,115 |
|
|
|
|
|
|
Koninklijke KPN NV |
|
|
|
|
|
|
|
|
|
|
438,996 |
|
|
20,260 |
|
|
|
|
|
|
Koninklijke Philips Electronics NV |
|
|
|
|
|
|
|
|
|
|
662,039 |
|
|
20 |
|
|
|
|
|
|
Koninklijke Vopak NV |
|
|
|
|
|
|
|
|
|
|
967 |
|
|
37 |
|
|
|
@ |
|
|
Qiagen NV |
|
|
|
|
|
|
|
|
|
|
767 |
|
|
416 |
|
|
|
|
|
|
Reed Elsevier NV |
|
|
|
|
|
|
|
|
|
|
5,487 |
|
|
38,149 |
|
|
|
|
|
|
Royal Dutch Shell PLC Class A |
|
|
|
|
|
|
|
|
|
|
1,372,325 |
|
|
27,050 |
|
|
|
|
|
|
Royal Dutch Shell PLC Class B |
|
|
|
|
|
|
|
|
|
|
966,990 |
|
|
1,274 |
|
|
|
|
|
|
TNT NV |
|
|
|
|
|
|
|
|
|
|
33,437 |
|
|
27,463 |
|
|
|
|
|
|
Unilever NV |
|
|
|
|
|
|
|
|
|
|
828,342 |
|
|
183 |
|
|
|
|
|
|
Wolters Kluwer NV |
|
|
|
|
|
|
|
|
|
|
4,322 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
5,024,006 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
New Zealand: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
132,285 |
|
|
|
|
|
|
Telecom Corp. of New Zealand Ltd. |
|
|
|
|
|
|
|
|
|
|
208,245 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
208,245 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Norway: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
337 |
|
|
|
|
|
|
Aker Kvaerner ASA |
|
|
|
|
|
|
|
|
|
|
7,143 |
|
|
2,879 |
|
|
|
|
|
|
DnB NOR ASA |
|
|
|
|
|
|
|
|
|
|
44,559 |
|
21
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
332 |
|
|
|
|
|
|
Norsk Hydro ASA |
|
|
|
|
|
|
|
|
|
|
2,739 |
|
|
5,996 |
|
|
|
|
|
|
Statoil ASA |
|
|
|
|
|
|
|
|
|
|
158,319 |
|
|
4,911 |
|
|
|
|
|
|
Telenor ASA |
|
|
|
|
|
|
|
|
|
|
81,476 |
|
|
1,270 |
|
|
|
|
|
|
Yara International ASA |
|
|
|
|
|
|
|
|
|
|
67,432 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
361,668 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Portugal: |
|
|
|
|
|
|
0.3 |
% |
|
|
|
|
|
8,422 |
|
|
|
|
|
|
Banco Comercial Portugues S.A. |
|
|
|
|
|
|
|
|
|
|
7,511 |
|
|
27,348 |
|
|
|
|
|
|
Banco Espirito Santo S.A. |
|
|
|
|
|
|
|
|
|
|
123,950 |
|
|
25,355 |
|
|
|
|
|
|
Jeronimo Martins |
|
|
|
|
|
|
|
|
|
|
406,400 |
|
|
23,525 |
|
|
|
|
|
|
Portugal Telecom SGPS S.A. |
|
|
|
|
|
|
|
|
|
|
274,433 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
812,294 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Singapore: |
|
|
|
|
|
|
0.6 |
% |
|
|
|
|
|
1,000 |
|
|
|
|
|
|
CapitaLand Ltd. |
|
|
|
|
|
|
|
|
|
|
2,574 |
|
|
1,000 |
|
|
|
|
|
|
CapitaMalls Asia Ltd. |
|
|
|
|
|
|
|
|
|
|
1,358 |
|
|
8,000 |
|
|
|
|
|
|
DBS Group Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
89,383 |
|
|
15,000 |
|
|
|
|
|
|
Jardine Cycle & Carriage Ltd. |
|
|
|
|
|
|
|
|
|
|
399,225 |
|
|
36,000 |
|
|
|
|
|
|
Oversea-Chinese Banking Corp. |
|
|
|
|
|
|
|
|
|
|
261,342 |
|
|
37,000 |
|
|
|
|
|
|
Singapore Airlines Ltd. |
|
|
|
|
|
|
|
|
|
|
397,308 |
|
|
2,000 |
|
|
|
|
|
|
Singapore Telecommunications Ltd. |
|
|
|
|
|
|
|
|
|
|
4,684 |
|
|
11,000 |
|
|
|
|
|
|
United Overseas Bank Ltd. |
|
|
|
|
|
|
|
|
|
|
156,480 |
|
|
24,000 |
|
|
|
|
|
|
United Overseas Land Ltd. |
|
|
|
|
|
|
|
|
|
|
84,167 |
|
|
1,000 |
|
|
|
|
|
|
Wilmar International Ltd. |
|
|
|
|
|
|
|
|
|
|
4,004 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
1,400,525 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Spain: |
|
|
|
|
|
|
1.6 |
% |
|
|
|
|
|
29 |
|
|
|
|
|
|
Acciona S.A. |
|
|
|
|
|
|
|
|
|
|
2,823 |
|
|
584 |
|
|
|
|
|
|
ACS Actividades de Construccion y Servicios S.A. |
|
|
|
|
|
|
|
|
|
|
26,792 |
|
|
731 |
|
|
|
@ |
|
|
Amadeus IT Holding S.A. |
|
|
|
|
|
|
|
|
|
|
14,247 |
|
|
48,468 |
|
|
|
|
|
|
Banco Bilbao Vizcaya Argentaria S.A. |
|
|
|
|
|
|
|
|
|
|
597,495 |
|
|
1,607 |
|
|
|
|
|
|
Banco De Sabadell S.A. |
|
|
|
|
|
|
|
|
|
|
6,971 |
|
|
5,646 |
|
|
|
|
|
|
Banco Popular Espanol S.A. |
|
|
|
|
|
|
|
|
|
|
34,150 |
|
|
84,015 |
|
|
|
|
|
|
Banco Santander Central Hispano S.A. |
|
|
|
|
|
|
|
|
|
|
1,034,377 |
|
|
420 |
|
|
|
|
|
|
Bankinter S.A. |
|
|
|
|
|
|
|
|
|
|
2,770 |
|
|
32,777 |
|
|
|
|
|
|
Corp. Mapfre S.A. |
|
|
|
|
|
|
|
|
|
|
121,803 |
|
|
21,058 |
|
|
|
|
|
|
Criteria Caixacorp S.A. |
|
|
|
|
|
|
|
|
|
|
152,521 |
|
|
244 |
|
|
|
|
|
|
Enagas |
|
|
|
|
|
|
|
|
|
|
5,225 |
|
|
1,456 |
|
|
|
|
|
|
Ferrovial SA |
|
|
|
|
|
|
|
|
|
|
17,536 |
|
|
170 |
|
|
|
|
|
|
Fomento de Construcciones y Contratas S.A. |
|
|
|
|
|
|
|
|
|
|
5,435 |
|
|
436 |
|
|
|
|
|
|
Gas Natural SDG S.A. |
|
|
|
|
|
|
|
|
|
|
7,449 |
|
|
1,192 |
|
|
|
|
|
|
Iberdrola Renovables |
|
|
|
|
|
|
|
|
|
|
4,473 |
|
|
5,295 |
|
|
|
|
|
|
Iberdrola S.A. |
|
|
|
|
|
|
|
|
|
|
46,199 |
|
|
1,071 |
|
|
|
|
|
|
Inditex S.A. |
|
|
|
|
|
|
|
|
|
|
77,615 |
|
|
286 |
|
|
|
|
|
|
Indra Sistemas S.A. |
|
|
|
|
|
|
|
|
|
|
5,569 |
|
|
1,555 |
|
|
|
|
|
|
Red Electrica de Espana |
|
|
|
|
|
|
|
|
|
|
83,569 |
|
|
24,546 |
|
|
|
|
|
|
Repsol YPF S.A. |
|
|
|
|
|
|
|
|
|
|
823,989 |
|
|
40,173 |
|
|
|
@ |
|
|
Telefonica S.A. |
|
|
|
|
|
|
|
|
|
|
1,021,372 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
4,092,380 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Sweden: |
|
|
|
|
|
|
1.9 |
% |
|
|
|
|
|
603 |
|
|
|
|
|
|
Alfa Laval AB |
|
|
|
|
|
|
|
|
|
|
12,319 |
|
|
530 |
|
|
|
|
|
|
Assa Abloy AB |
|
|
|
|
|
|
|
|
|
|
14,843 |
|
|
21,685 |
|
|
|
|
|
|
Atlas Copco AB Class A |
|
|
|
|
|
|
|
|
|
|
545,219 |
|
|
695 |
|
|
|
|
|
|
Atlas Copco AB Class B |
|
|
|
|
|
|
|
|
|
|
15,798 |
|
|
20,421 |
|
|
|
|
|
|
Boliden AB |
|
|
|
|
|
|
|
|
|
|
436,659 |
|
|
9,828 |
|
|
|
|
|
|
Getinge AB |
|
|
|
|
|
|
|
|
|
|
240,044 |
|
|
363 |
|
|
|
|
|
|
Hennes & Mauritz AB |
|
|
|
|
|
|
|
|
|
|
11,861 |
|
|
429 |
|
|
|
|
|
|
Hexagon AB |
|
|
|
|
|
|
|
|
|
|
9,474 |
|
|
6,682 |
|
|
|
|
|
|
Industrivarden AB |
|
|
|
|
|
|
|
|
|
|
116,392 |
|
|
8,083 |
|
|
|
|
|
|
Investor AB |
|
|
|
|
|
|
|
|
|
|
186,002 |
|
|
5,253 |
|
|
|
|
|
|
Kinnevik Investment AB |
|
|
|
|
|
|
|
|
|
|
117,809 |
|
|
11 |
|
|
|
|
|
|
Millicom International Cellular S.A. |
|
|
|
|
|
|
|
|
|
|
964 |
|
|
35,654 |
|
|
|
|
|
|
Nordea Bank AB |
|
|
|
|
|
|
|
|
|
|
405,596 |
|
|
2,640 |
|
|
|
|
|
|
Ratos AB |
|
|
|
|
|
|
|
|
|
|
98,511 |
|
|
24,119 |
|
|
|
|
|
|
Sandvik AB |
|
|
|
|
|
|
|
|
|
|
462,907 |
|
|
21,746 |
|
|
|
|
|
|
Scania AB B Shares |
|
|
|
|
|
|
|
|
|
|
485,014 |
|
|
3,352 |
|
|
|
|
|
|
Skandinaviska Enskilda Banken AB |
|
|
|
|
|
|
|
|
|
|
30,490 |
|
|
10,951 |
|
|
|
|
|
|
Skanska AB |
|
|
|
|
|
|
|
|
|
|
224,969 |
|
|
18,714 |
|
|
|
|
|
|
SKF AB B Shares |
|
|
|
|
|
|
|
|
|
|
522,313 |
|
|
236 |
|
|
|
|
|
|
SSAB Svenskt Staal AB Class A |
|
|
|
|
|
|
|
|
|
|
3,710 |
|
|
26,909 |
|
|
|
|
|
|
Svenska Cellulosa AB B Shares |
|
|
|
|
|
|
|
|
|
|
444,712 |
|
|
3,775 |
|
|
|
|
|
|
Svenska Handelsbanken AB |
|
|
|
|
|
|
|
|
|
|
127,517 |
|
|
1,833 |
|
|
|
@ |
|
|
Swedbank AB |
|
|
|
|
|
|
|
|
|
|
32,298 |
|
|
38 |
|
|
|
|
|
|
Tele2 AB B Shares |
|
|
|
|
|
|
|
|
|
|
868 |
|
|
21,576 |
|
|
|
|
|
|
Telefonaktiebolaget LM Ericsson |
|
|
|
|
|
|
|
|
|
|
277,122 |
|
|
279 |
|
|
|
|
|
|
TeliaSonera AB |
|
|
|
|
|
|
|
|
|
|
2,348 |
|
|
2,397 |
|
|
|
@ |
|
|
Volvo AB B Shares |
|
|
|
|
|
|
|
|
|
|
41,487 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
4,867,246 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Switzerland: |
|
|
|
|
|
|
2.7 |
% |
|
|
|
|
|
4,067 |
|
|
|
@ |
|
|
ABB Ltd. |
|
|
|
|
|
|
|
|
|
|
99,584 |
|
|
3,600 |
|
|
|
|
|
|
ACE Ltd. |
|
|
|
|
|
|
|
|
|
|
227,700 |
|
|
77 |
|
|
|
@ |
|
|
Actelion Ltd. Reg |
|
|
|
|
|
|
|
|
|
|
4,273 |
|
22
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
47 |
|
|
|
|
|
|
Adecco S.A. |
|
|
|
|
|
|
|
|
|
|
3,169 |
|
|
59 |
|
|
|
|
|
|
Baloise Holding AG |
|
|
|
|
|
|
|
|
|
|
6,380 |
|
|
10,340 |
|
|
|
|
|
|
Compagnie Financiere Richemont S.A. |
|
|
|
|
|
|
|
|
|
|
591,696 |
|
|
12,064 |
|
|
|
|
|
|
Credit Suisse Group |
|
|
|
|
|
|
|
|
|
|
557,935 |
|
|
7,262 |
|
|
|
@ |
|
|
GAM Holding AG |
|
|
|
|
|
|
|
|
|
|
131,222 |
|
|
3 |
|
|
|
|
|
|
Geberit AG Reg |
|
|
|
|
|
|
|
|
|
|
647 |
|
|
2 |
|
|
|
|
|
|
Givaudan |
|
|
|
|
|
|
|
|
|
|
1,994 |
|
|
46 |
|
|
|
|
|
|
Holcim Ltd. |
|
|
|
|
|
|
|
|
|
|
3,380 |
|
|
126 |
|
|
|
|
|
|
Julius Baer Group Ltd. |
|
|
|
|
|
|
|
|
|
|
5,652 |
|
|
35 |
|
|
|
|
|
|
Lonza Group AG |
|
|
|
|
|
|
|
|
|
|
2,963 |
|
|
21,734 |
|
|
|
|
|
|
Nestle S.A. |
|
|
|
|
|
|
|
|
|
|
1,230,557 |
|
|
22,387 |
|
|
|
|
|
|
Novartis AG |
|
|
|
|
|
|
|
|
|
|
1,258,074 |
|
|
7,453 |
|
|
|
|
|
|
Roche Holding AG Genusschein |
|
|
|
|
|
|
|
|
|
|
1,124,229 |
|
|
3 |
|
|
|
|
|
|
Schindler Holding AG |
|
|
|
|
|
|
|
|
|
|
338 |
|
|
2 |
|
|
|
|
|
|
SGS S.A. |
|
|
|
|
|
|
|
|
|
|
3,484 |
|
|
22 |
|
|
|
|
|
|
Sonova Holding AG Reg |
|
|
|
|
|
|
|
|
|
|
2,925 |
|
|
7 |
|
|
|
|
|
|
Swatch Group AG BR |
|
|
|
|
|
|
|
|
|
|
2,982 |
|
|
34 |
|
|
|
@ |
|
|
Swiss Life Holding |
|
|
|
|
|
|
|
|
|
|
5,620 |
|
|
1,868 |
|
|
|
|
|
|
Swiss Reinsurance |
|
|
|
|
|
|
|
|
|
|
114,482 |
|
|
15 |
|
|
|
|
|
|
Syngenta AG |
|
|
|
|
|
|
|
|
|
|
5,039 |
|
|
240 |
|
|
|
|
|
|
Synthes, Inc. |
|
|
|
|
|
|
|
|
|
|
32,950 |
|
|
27,809 |
|
|
|
@ |
|
|
UBS AG Reg |
|
|
|
|
|
|
|
|
|
|
551,808 |
|
|
12,112 |
|
|
|
|
|
|
Xstrata PLC |
|
|
|
|
|
|
|
|
|
|
277,014 |
|
|
1,669 |
|
|
|
|
|
|
Zurich Financial Services AG |
|
|
|
|
|
|
|
|
|
|
484,817 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
6,730,914 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
United Kingdom: |
|
|
|
|
|
|
7.7 |
% |
|
|
|
|
|
27,633 |
|
|
|
|
|
|
3i Group PLC |
|
|
|
|
|
|
|
|
|
|
140,288 |
|
|
222 |
|
|
|
|
|
|
Admiral Group PLC |
|
|
|
|
|
|
|
|
|
|
6,094 |
|
|
14,589 |
|
|
|
|
|
|
Aggreko PLC |
|
|
|
|
|
|
|
|
|
|
343,296 |
|
|
297 |
|
|
|
|
|
|
Amec PLC |
|
|
|
|
|
|
|
|
|
|
5,621 |
|
|
8,469 |
|
|
|
|
|
|
Anglo American PLC |
|
|
|
|
|
|
|
|
|
|
459,390 |
|
|
378 |
|
|
|
|
|
|
Antofagasta PLC |
|
|
|
|
|
|
|
|
|
|
8,657 |
|
|
420 |
|
|
|
|
|
|
Associated British Foods PLC |
|
|
|
|
|
|
|
|
|
|
6,601 |
|
|
17,321 |
|
|
|
|
|
|
AstraZeneca PLC |
|
|
|
|
|
|
|
|
|
|
847,555 |
|
|
8,218 |
|
|
|
@ |
|
|
Autonomy Corp. PLC |
|
|
|
|
|
|
|
|
|
|
219,608 |
|
|
38,558 |
|
|
|
|
|
|
Aviva PLC |
|
|
|
|
|
|
|
|
|
|
292,672 |
|
|
1,960 |
|
|
|
|
|
|
BAE Systems PLC |
|
|
|
|
|
|
|
|
|
|
10,481 |
|
|
376 |
|
|
|
|
|
|
Balfour Beatty PLC |
|
|
|
|
|
|
|
|
|
|
2,137 |
|
|
82,580 |
|
|
|
|
|
|
Barclays PLC |
|
|
|
|
|
|
|
|
|
|
428,559 |
|
|
14,977 |
|
|
|
|
|
|
BG Group PLC |
|
|
|
|
|
|
|
|
|
|
364,698 |
|
|
28,837 |
|
|
|
|
|
|
BHP Billiton PLC |
|
|
|
|
|
|
|
|
|
|
1,143,080 |
|
|
184,364 |
|
|
|
|
|
|
BP PLC |
|
|
|
|
|
|
|
|
|
|
1,486,278 |
|
|
27,813 |
|
|
|
|
|
|
British American Tobacco PLC |
|
|
|
|
|
|
|
|
|
|
1,114,298 |
|
|
290 |
|
|
|
|
|
|
British Sky Broadcasting PLC |
|
|
|
|
|
|
|
|
|
|
3,710 |
|
|
123,828 |
|
|
|
|
|
|
BT Group PLC |
|
|
|
|
|
|
|
|
|
|
367,797 |
|
|
185 |
|
|
|
|
|
|
Bunzl PLC |
|
|
|
|
|
|
|
|
|
|
2,286 |
|
|
9,061 |
|
|
|
|
|
|
Burberry Group PLC |
|
|
|
|
|
|
|
|
|
|
176,592 |
|
|
59,110 |
|
|
|
|
|
|
Cable & Wireless Worldwide PLC |
|
|
|
|
|
|
|
|
|
|
69,042 |
|
|
1,301 |
|
|
|
@ |
|
|
Cairn Energy PLC |
|
|
|
|
|
|
|
|
|
|
9,034 |
|
|
895 |
|
|
|
|
|
|
Capita Group PLC |
|
|
|
|
|
|
|
|
|
|
10,555 |
|
|
229 |
|
|
|
|
|
|
Carnival PLC |
|
|
|
|
|
|
|
|
|
|
10,237 |
|
|
10,443 |
|
|
|
|
|
|
Centrica PLC |
|
|
|
|
|
|
|
|
|
|
57,748 |
|
|
649 |
|
|
|
|
|
|
Cobham PLC |
|
|
|
|
|
|
|
|
|
|
2,379 |
|
|
57,694 |
|
|
|
|
|
|
Compass Group PLC |
|
|
|
|
|
|
|
|
|
|
519,139 |
|
|
40,782 |
|
|
|
|
|
|
Diageo PLC |
|
|
|
|
|
|
|
|
|
|
797,311 |
|
|
19,509 |
|
|
|
|
|
|
Experian Group Ltd. |
|
|
|
|
|
|
|
|
|
|
247,406 |
|
|
46,755 |
|
|
|
|
|
|
Firstgroup PLC |
|
|
|
|
|
|
|
|
|
|
277,444 |
|
|
48,939 |
|
|
|
|
|
|
GlaxoSmithKline PLC |
|
|
|
|
|
|
|
|
|
|
939,451 |
|
|
1,943 |
|
|
|
|
|
|
Group 4 Securicor PLC |
|
|
|
|
|
|
|
|
|
|
8,339 |
|
|
391 |
|
|
|
|
|
|
Home Retail Group |
|
|
|
|
|
|
|
|
|
|
1,403 |
|
|
150,004 |
|
|
|
|
|
|
HSBC Holdings PLC |
|
|
|
|
|
|
|
|
|
|
1,652,014 |
|
|
16,256 |
|
|
|
|
|
|
ICAP PLC |
|
|
|
|
|
|
|
|
|
|
137,603 |
|
|
10,086 |
|
|
|
|
|
|
Imperial Tobacco Group PLC |
|
|
|
|
|
|
|
|
|
|
323,662 |
|
|
266 |
|
|
|
|
|
|
Inmarsat PLC |
|
|
|
|
|
|
|
|
|
|
2,897 |
|
|
330 |
|
|
|
|
|
|
Intercontinental Hotels Group PLC |
|
|
|
|
|
|
|
|
|
|
7,339 |
|
|
2,170 |
|
|
|
|
|
|
International Power PLC |
|
|
|
|
|
|
|
|
|
|
11,797 |
|
|
224 |
|
|
|
|
|
|
Intertek Group PLC |
|
|
|
|
|
|
|
|
|
|
6,567 |
|
|
500 |
|
|
|
|
|
|
Invensys PLC |
|
|
|
|
|
|
|
|
|
|
2,889 |
|
|
17,441 |
|
|
|
|
|
|
Investec PLC |
|
|
|
|
|
|
|
|
|
|
133,998 |
|
|
779 |
|
|
|
@ |
|
|
ITV PLC |
|
|
|
|
|
|
|
|
|
|
1,104 |
|
|
434 |
|
|
|
|
|
|
J Sainsbury PLC |
|
|
|
|
|
|
|
|
|
|
2,681 |
|
|
186 |
|
|
|
|
|
|
Johnson Matthey PLC |
|
|
|
|
|
|
|
|
|
|
5,612 |
|
|
1,395 |
|
|
|
|
|
|
Kingfisher PLC |
|
|
|
|
|
|
|
|
|
|
5,768 |
|
|
99,284 |
|
|
|
|
|
|
Legal & General Group PLC |
|
|
|
|
|
|
|
|
|
|
191,809 |
|
|
333,327 |
|
|
|
@ |
|
|
Lloyds TSB Group PLC |
|
|
|
|
|
|
|
|
|
|
336,616 |
|
|
235 |
|
|
|
|
|
|
London Stock Exchange Group PLC |
|
|
|
|
|
|
|
|
|
|
3,439 |
|
|
146 |
|
|
|
|
|
|
Lonmin PLC |
|
|
|
|
|
|
|
|
|
|
4,362 |
|
|
2,929 |
|
|
|
|
|
|
Man Group PLC |
|
|
|
|
|
|
|
|
|
|
13,686 |
|
|
924 |
|
|
|
|
|
|
Marks & Spencer Group PLC |
|
|
|
|
|
|
|
|
|
|
5,203 |
|
23
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
73,128 |
|
|
|
|
|
|
National Grid PLC |
|
|
|
|
|
|
|
|
|
|
679,542 |
|
|
104 |
|
|
|
|
|
|
Next PLC |
|
|
|
|
|
|
|
|
|
|
3,341 |
|
|
74,392 |
|
|
|
|
|
|
Old Mutual PLC |
|
|
|
|
|
|
|
|
|
|
159,171 |
|
|
24,307 |
|
|
|
|
|
|
Pearson PLC |
|
|
|
|
|
|
|
|
|
|
414,584 |
|
|
15,848 |
|
|
|
|
|
|
Petrofac Ltd. |
|
|
|
|
|
|
|
|
|
|
358,832 |
|
|
18,465 |
|
|
|
|
|
|
Prudential PLC |
|
|
|
|
|
|
|
|
|
|
213,597 |
|
|
84 |
|
|
|
@ |
|
|
Randgold Resources Ltd. |
|
|
|
|
|
|
|
|
|
|
6,802 |
|
|
6,176 |
|
|
|
|
|
|
Reckitt Benckiser PLC |
|
|
|
|
|
|
|
|
|
|
318,408 |
|
|
296 |
|
|
|
|
|
|
Reed Elsevier PLC |
|
|
|
|
|
|
|
|
|
|
2,643 |
|
|
678 |
|
|
|
|
|
|
Rexam PLC |
|
|
|
|
|
|
|
|
|
|
4,022 |
|
|
12,360 |
|
|
|
|
|
|
Rio Tinto PLC |
|
|
|
|
|
|
|
|
|
|
870,348 |
|
|
12,055 |
|
|
|
|
|
|
Rolls-Royce Group PLC |
|
|
|
|
|
|
|
|
|
|
120,997 |
|
|
3,885 |
|
|
|
|
|
|
Royal & Sun Alliance Insurance Group |
|
|
|
|
|
|
|
|
|
|
8,855 |
|
|
57,434 |
|
|
|
@ |
|
|
Royal Bank of Scotland Group PLC |
|
|
|
|
|
|
|
|
|
|
42,129 |
|
|
1,062 |
|
|
|
|
|
|
SABMiller PLC |
|
|
|
|
|
|
|
|
|
|
35,777 |
|
|
1,087 |
|
|
|
|
|
|
Sage Group PLC |
|
|
|
|
|
|
|
|
|
|
5,024 |
|
|
8,888 |
|
|
|
|
|
|
Scottish & Southern Energy PLC |
|
|
|
|
|
|
|
|
|
|
179,002 |
|
|
714 |
|
|
|
|
|
|
Serco Group PLC |
|
|
|
|
|
|
|
|
|
|
6,322 |
|
|
266 |
|
|
|
|
|
|
Severn Trent PLC |
|
|
|
|
|
|
|
|
|
|
6,434 |
|
|
718 |
|
|
|
|
|
|
Shire PLC |
|
|
|
|
|
|
|
|
|
|
20,334 |
|
|
6,941 |
|
|
|
|
|
|
Smith & Nephew PLC |
|
|
|
|
|
|
|
|
|
|
80,400 |
|
|
3,890 |
|
|
|
|
|
|
Smiths Group PLC |
|
|
|
|
|
|
|
|
|
|
84,564 |
|
|
23,042 |
|
|
|
|
|
|
Standard Chartered PLC |
|
|
|
|
|
|
|
|
|
|
609,433 |
|
|
2,572 |
|
|
|
|
|
|
Standard Life PLC |
|
|
|
|
|
|
|
|
|
|
9,992 |
|
|
39,840 |
|
|
|
|
|
|
Tesco PLC |
|
|
|
|
|
|
|
|
|
|
261,679 |
|
|
1,054 |
|
|
|
|
|
|
Thomas Cook Group PLC |
|
|
|
|
|
|
|
|
|
|
3,241 |
|
|
710 |
|
|
|
|
|
|
TUI Travel PLC |
|
|
|
|
|
|
|
|
|
|
2,800 |
|
|
727 |
|
|
|
|
|
|
Tullow Oil PLC |
|
|
|
|
|
|
|
|
|
|
16,984 |
|
|
9,272 |
|
|
|
|
|
|
Unilever PLC |
|
|
|
|
|
|
|
|
|
|
274,903 |
|
|
776 |
|
|
|
|
|
|
United Utilities Group PLC |
|
|
|
|
|
|
|
|
|
|
7,472 |
|
|
3,850 |
|
|
|
|
|
|
Vedanta Resources PLC |
|
|
|
|
|
|
|
|
|
|
150,955 |
|
|
406,879 |
|
|
|
|
|
|
Vodafone Group PLC |
|
|
|
|
|
|
|
|
|
|
1,155,166 |
|
|
133 |
|
|
|
|
|
|
Weir Group PLC |
|
|
|
|
|
|
|
|
|
|
3,708 |
|
|
3,394 |
|
|
|
|
|
|
Whitbread PLC |
|
|
|
|
|
|
|
|
|
|
98,334 |
|
|
751 |
|
|
|
|
|
|
WM Morrison Supermarkets PLC |
|
|
|
|
|
|
|
|
|
|
3,380 |
|
|
388 |
|
|
|
@ |
|
|
Wolseley PLC |
|
|
|
|
|
|
|
|
|
|
13,510 |
|
|
310 |
|
|
|
|
|
|
WPP PLC |
|
|
|
|
|
|
|
|
|
|
4,266 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
19,465,183 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
United States: |
|
|
|
|
|
|
56.5 |
% |
|
|
|
|
|
7,900 |
|
|
|
|
|
|
3M Co. |
|
|
|
|
|
|
|
|
|
|
728,617 |
|
|
16,801 |
|
|
|
|
|
|
Abbott Laboratories |
|
|
|
|
|
|
|
|
|
|
808,128 |
|
|
200 |
|
|
|
|
|
|
Abercrombie & Fitch Co. |
|
|
|
|
|
|
|
|
|
|
11,474 |
|
|
3,500 |
|
|
|
@ |
|
|
Adobe Systems, Inc. |
|
|
|
|
|
|
|
|
|
|
120,750 |
|
|
16,300 |
|
|
|
@, S |
|
|
Advanced Micro Devices, Inc. |
|
|
|
|
|
|
|
|
|
|
150,123 |
|
|
20,300 |
|
|
|
@, S |
|
|
AES Corp. |
|
|
|
|
|
|
|
|
|
|
251,111 |
|
|
2,611 |
|
|
|
|
|
|
Aetna, Inc. |
|
|
|
|
|
|
|
|
|
|
97,547 |
|
|
4,578 |
|
|
|
|
|
|
Aflac, Inc. |
|
|
|
|
|
|
|
|
|
|
269,461 |
|
|
2,300 |
|
|
|
@ |
|
|
Agilent Technologies, Inc. |
|
|
|
|
|
|
|
|
|
|
96,784 |
|
|
816 |
|
|
|
|
|
|
Air Products & Chemicals, Inc. |
|
|
|
|
|
|
|
|
|
|
75,072 |
|
|
312 |
|
|
|
|
|
|
Airgas, Inc. |
|
|
|
|
|
|
|
|
|
|
19,525 |
|
|
6,800 |
|
|
|
|
|
|
AK Steel Holding Corp. |
|
|
|
|
|
|
|
|
|
|
108,664 |
|
|
4,000 |
|
|
|
@ |
|
|
Akamai Technologies, Inc. |
|
|
|
|
|
|
|
|
|
|
150,120 |
|
|
13,000 |
|
|
|
|
|
|
Alcoa, Inc. |
|
|
|
|
|
|
|
|
|
|
219,050 |
|
|
5,000 |
|
|
|
|
|
|
Allergan, Inc. |
|
|
|
|
|
|
|
|
|
|
370,850 |
|
|
5,000 |
|
|
|
|
|
|
Allstate Corp. |
|
|
|
|
|
|
|
|
|
|
158,900 |
|
|
5,000 |
|
|
|
|
|
|
Altera Corp. |
|
|
|
|
|
|
|
|
|
|
209,300 |
|
|
27,400 |
|
|
|
|
|
|
Altria Group, Inc. |
|
|
|
|
|
|
|
|
|
|
695,138 |
|
|
2,900 |
|
|
|
@ |
|
|
Amazon.com, Inc. |
|
|
|
|
|
|
|
|
|
|
502,541 |
|
|
3,100 |
|
|
|
|
|
|
Ameren Corp. |
|
|
|
|
|
|
|
|
|
|
86,676 |
|
|
6,100 |
|
|
|
|
|
|
American Electric Power Co., Inc. |
|
|
|
|
|
|
|
|
|
|
218,258 |
|
|
10,500 |
|
|
|
|
|
|
American Express Co. |
|
|
|
|
|
|
|
|
|
|
457,485 |
|
|
1,300 |
|
|
|
@ |
|
|
American International Group, Inc. |
|
|
|
|
|
|
|
|
|
|
48,178 |
|
|
6,900 |
|
|
|
@ |
|
|
American Tower Corp. |
|
|
|
|
|
|
|
|
|
|
372,324 |
|
|
4,500 |
|
|
|
|
|
|
Ameriprise Financial, Inc. |
|
|
|
|
|
|
|
|
|
|
284,940 |
|
|
5,452 |
|
|
|
|
|
|
AmerisourceBergen Corp. |
|
|
|
|
|
|
|
|
|
|
206,685 |
|
|
9,369 |
|
|
|
@ |
|
|
Amgen, Inc. |
|
|
|
|
|
|
|
|
|
|
480,911 |
|
|
1,200 |
|
|
|
|
|
|
Amphenol Corp. |
|
|
|
|
|
|
|
|
|
|
68,976 |
|
|
5,300 |
|
|
|
|
|
|
Anadarko Petroleum Corp. |
|
|
|
|
|
|
|
|
|
|
433,699 |
|
|
1,300 |
|
|
|
|
|
|
Analog Devices, Inc. |
|
|
|
|
|
|
|
|
|
|
51,844 |
|
|
6,800 |
|
|
|
|
|
|
AON Corp. |
|
|
|
|
|
|
|
|
|
|
357,952 |
|
|
4,200 |
|
|
|
|
|
|
Apache Corp. |
|
|
|
|
|
|
|
|
|
|
523,404 |
|
|
4,200 |
|
|
|
@ |
|
|
Apollo Group, Inc. Class A |
|
|
|
|
|
|
|
|
|
|
190,092 |
|
|
9,303 |
|
|
|
@, S |
|
|
Apple, Inc. |
|
|
|
|
|
|
|
|
|
|
3,285,913 |
|
|
6,158 |
|
|
|
|
|
|
Applied Materials, Inc. |
|
|
|
|
|
|
|
|
|
|
101,176 |
|
|
8,766 |
|
|
|
|
|
|
Archer-Daniels-Midland Co. |
|
|
|
|
|
|
|
|
|
|
325,920 |
|
|
3,700 |
|
|
|
|
|
|
Assurant, Inc. |
|
|
|
|
|
|
|
|
|
|
150,331 |
|
|
86,800 |
|
|
|
S |
|
|
AT&T, Inc. |
|
|
|
|
|
|
|
|
|
|
2,463,384 |
|
|
1,600 |
|
|
|
@ |
|
|
Autodesk, Inc. |
|
|
|
|
|
|
|
|
|
|
67,280 |
|
|
3,400 |
|
|
|
|
|
|
Automatic Data Processing, Inc. |
|
|
|
|
|
|
|
|
|
|
170,000 |
|
24
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
200 |
|
|
|
@ |
|
|
Autozone, Inc. |
|
|
|
|
|
|
|
|
|
|
51,590 |
|
|
3,209 |
|
|
|
|
|
|
Avery Dennison Corp. |
|
|
|
|
|
|
|
|
|
|
128,103 |
|
|
7,100 |
|
|
|
|
|
|
Avon Products, Inc. |
|
|
|
|
|
|
|
|
|
|
197,451 |
|
|
8,500 |
|
|
|
|
|
|
Baker Hughes, Inc. |
|
|
|
|
|
|
|
|
|
|
603,925 |
|
|
112,340 |
|
|
|
|
|
|
Bank of America Corp. |
|
|
|
|
|
|
|
|
|
|
1,605,339 |
|
|
11,300 |
|
|
|
|
|
|
Bank of New York Mellon Corp. |
|
|
|
|
|
|
|
|
|
|
343,407 |
|
|
7,851 |
|
|
|
|
|
|
Baxter International, Inc. |
|
|
|
|
|
|
|
|
|
|
417,281 |
|
|
5,000 |
|
|
|
|
|
|
BB&T Corp. |
|
|
|
|
|
|
|
|
|
|
138,000 |
|
|
3,200 |
|
|
|
|
|
|
Becton Dickinson & Co. |
|
|
|
|
|
|
|
|
|
|
256,000 |
|
|
4,500 |
|
|
|
@ |
|
|
Bed Bath & Beyond, Inc. |
|
|
|
|
|
|
|
|
|
|
216,675 |
|
|
23,700 |
|
|
|
@ |
|
|
Berkshire Hathaway, Inc. |
|
|
|
|
|
|
|
|
|
|
2,068,536 |
|
|
2,200 |
|
|
|
|
|
|
Best Buy Co., Inc. |
|
|
|
|
|
|
|
|
|
|
70,928 |
|
|
2,900 |
|
|
|
@ |
|
|
Big Lots, Inc. |
|
|
|
|
|
|
|
|
|
|
118,987 |
|
|
4,500 |
|
|
|
@ |
|
|
Biogen Idec, Inc. |
|
|
|
|
|
|
|
|
|
|
307,800 |
|
|
3,900 |
|
|
|
@ |
|
|
BMC Software, Inc. |
|
|
|
|
|
|
|
|
|
|
193,050 |
|
|
10,200 |
|
|
|
|
|
|
Boeing Co. |
|
|
|
|
|
|
|
|
|
|
734,502 |
|
|
40,400 |
|
|
|
@, S |
|
|
Boston Scientific Corp. |
|
|
|
|
|
|
|
|
|
|
289,264 |
|
|
16,800 |
|
|
|
|
|
|
Bristol-Myers Squibb Co. |
|
|
|
|
|
|
|
|
|
|
433,608 |
|
|
2,400 |
|
|
|
|
|
|
Broadcom Corp. |
|
|
|
|
|
|
|
|
|
|
98,928 |
|
|
3,269 |
|
|
|
|
|
|
Brown-Forman Corp. |
|
|
|
|
|
|
|
|
|
|
226,051 |
|
|
2,892 |
|
|
|
|
|
|
CA, Inc. |
|
|
|
|
|
|
|
|
|
|
71,664 |
|
|
400 |
|
|
|
|
|
|
Cablevision Systems Corp. |
|
|
|
|
|
|
|
|
|
|
14,740 |
|
|
3,600 |
|
|
|
|
|
|
Cabot Oil & Gas Corp. |
|
|
|
|
|
|
|
|
|
|
164,376 |
|
|
5,600 |
|
|
|
@ |
|
|
Cameron International Corp. |
|
|
|
|
|
|
|
|
|
|
331,128 |
|
|
4,864 |
|
|
|
|
|
|
Campbell Soup Co. |
|
|
|
|
|
|
|
|
|
|
163,722 |
|
|
3,300 |
|
|
|
|
|
|
Capital One Financial Corp. |
|
|
|
|
|
|
|
|
|
|
164,241 |
|
|
2,700 |
|
|
|
|
|
|
Cardinal Health, Inc. |
|
|
|
|
|
|
|
|
|
|
112,428 |
|
|
7,600 |
|
|
|
@ |
|
|
CareFusion Corp. |
|
|
|
|
|
|
|
|
|
|
207,632 |
|
|
4,600 |
|
|
|
@ |
|
|
Carmax, Inc. |
|
|
|
|
|
|
|
|
|
|
162,702 |
|
|
4,100 |
|
|
|
|
|
|
Carnival Corp. |
|
|
|
|
|
|
|
|
|
|
174,947 |
|
|
8,600 |
|
|
|
|
|
|
Caterpillar, Inc. |
|
|
|
|
|
|
|
|
|
|
885,198 |
|
|
7,400 |
|
|
|
@ |
|
|
CB Richard Ellis Group, Inc. |
|
|
|
|
|
|
|
|
|
|
185,296 |
|
|
4,100 |
|
|
|
|
|
|
CBS Corp. Class B |
|
|
|
|
|
|
|
|
|
|
97,826 |
|
|
4,000 |
|
|
|
@ |
|
|
Celgene Corp. |
|
|
|
|
|
|
|
|
|
|
212,400 |
|
|
14,000 |
|
|
|
|
|
|
CenterPoint Energy, Inc. |
|
|
|
|
|
|
|
|
|
|
222,040 |
|
|
3,500 |
|
|
|
|
|
|
CenturyTel, Inc. |
|
|
|
|
|
|
|
|
|
|
144,130 |
|
|
2,600 |
|
|
|
@ |
|
|
Cephalon, Inc. |
|
|
|
|
|
|
|
|
|
|
146,406 |
|
|
500 |
|
|
|
@ |
|
|
Cerner Corp. |
|
|
|
|
|
|
|
|
|
|
50,225 |
|
|
700 |
|
|
|
|
|
|
CF Industries Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
98,896 |
|
|
500 |
|
|
|
|
|
|
CH Robinson Worldwide, Inc. |
|
|
|
|
|
|
|
|
|
|
36,195 |
|
|
7,100 |
|
|
|
|
|
|
Charles Schwab Corp. |
|
|
|
|
|
|
|
|
|
|
134,687 |
|
|
5,500 |
|
|
|
|
|
|
Chesapeake Energy Corp. |
|
|
|
|
|
|
|
|
|
|
195,855 |
|
|
25,242 |
|
|
|
|
|
|
Chevron Corp. |
|
|
|
|
|
|
|
|
|
|
2,618,858 |
|
|
2,900 |
|
|
|
|
|
|
Chubb Corp. |
|
|
|
|
|
|
|
|
|
|
175,972 |
|
|
1,900 |
|
|
|
|
|
|
Cigna Corp. |
|
|
|
|
|
|
|
|
|
|
79,933 |
|
|
5,000 |
|
|
|
|
|
|
Cincinnati Financial Corp. |
|
|
|
|
|
|
|
|
|
|
170,250 |
|
|
64,292 |
|
|
|
@ |
|
|
Cisco Systems, Inc. |
|
|
|
|
|
|
|
|
|
|
1,193,260 |
|
|
358,600 |
|
|
|
@, S |
|
|
Citigroup, Inc. |
|
|
|
|
|
|
|
|
|
|
1,678,248 |
|
|
3,700 |
|
|
|
@ |
|
|
Citrix Systems, Inc. |
|
|
|
|
|
|
|
|
|
|
259,592 |
|
|
700 |
|
|
|
|
|
|
Cliffs Natural Resources, Inc. |
|
|
|
|
|
|
|
|
|
|
67,949 |
|
|
800 |
|
|
|
|
|
|
Clorox Co. |
|
|
|
|
|
|
|
|
|
|
54,208 |
|
|
228 |
|
|
|
|
|
|
CME Group, Inc. |
|
|
|
|
|
|
|
|
|
|
70,972 |
|
|
10,100 |
|
|
|
|
|
|
CMS Energy Corp. |
|
|
|
|
|
|
|
|
|
|
194,526 |
|
|
3,900 |
|
|
|
|
|
|
Coach, Inc. |
|
|
|
|
|
|
|
|
|
|
214,188 |
|
|
33,772 |
|
|
|
|
|
|
Coca-Cola Co. |
|
|
|
|
|
|
|
|
|
|
2,158,706 |
|
|
3,882 |
|
|
|
|
|
|
Coca-Cola Enterprises, Inc. |
|
|
|
|
|
|
|
|
|
|
102,097 |
|
|
4,600 |
|
|
|
@ |
|
|
Cognizant Technology Solutions Corp. |
|
|
|
|
|
|
|
|
|
|
353,602 |
|
|
2,700 |
|
|
|
|
|
|
Colgate-Palmolive Co. |
|
|
|
|
|
|
|
|
|
|
212,004 |
|
|
21,555 |
|
|
|
S |
|
|
Comcast Corp. Class A |
|
|
|
|
|
|
|
|
|
|
555,257 |
|
|
1,200 |
|
|
|
|
|
|
Comerica, Inc. |
|
|
|
|
|
|
|
|
|
|
46,680 |
|
|
1,000 |
|
|
|
|
|
|
Computer Sciences Corp. |
|
|
|
|
|
|
|
|
|
|
48,130 |
|
|
11,600 |
|
|
|
@, S |
|
|
Compuware Corp. |
|
|
|
|
|
|
|
|
|
|
130,616 |
|
|
3,100 |
|
|
|
|
|
|
ConAgra Foods, Inc. |
|
|
|
|
|
|
|
|
|
|
71,796 |
|
|
17,700 |
|
|
|
|
|
|
ConocoPhillips |
|
|
|
|
|
|
|
|
|
|
1,378,299 |
|
|
1,900 |
|
|
|
|
|
|
Consol Energy, Inc. |
|
|
|
|
|
|
|
|
|
|
96,349 |
|
|
4,200 |
|
|
|
|
|
|
Consolidated Edison, Inc. |
|
|
|
|
|
|
|
|
|
|
209,916 |
|
|
7,400 |
|
|
|
@ |
|
|
Constellation Brands, Inc. |
|
|
|
|
|
|
|
|
|
|
150,368 |
|
|
6,600 |
|
|
|
|
|
|
Constellation Energy Group, Inc. |
|
|
|
|
|
|
|
|
|
|
205,062 |
|
|
12,300 |
|
|
|
|
|
|
Corning, Inc. |
|
|
|
|
|
|
|
|
|
|
283,638 |
|
|
4,100 |
|
|
|
|
|
|
Costco Wholesale Corp. |
|
|
|
|
|
|
|
|
|
|
306,639 |
|
|
5,000 |
|
|
|
@ |
|
|
Coventry Health Care, Inc. |
|
|
|
|
|
|
|
|
|
|
151,000 |
|
|
1,200 |
|
|
|
|
|
|
CR Bard, Inc. |
|
|
|
|
|
|
|
|
|
|
117,312 |
|
|
4,863 |
|
|
|
|
|
|
CSX Corp. |
|
|
|
|
|
|
|
|
|
|
363,072 |
|
|
3,700 |
|
|
|
|
|
|
Cummins, Inc. |
|
|
|
|
|
|
|
|
|
|
374,144 |
|
|
14,200 |
|
|
|
|
|
|
CVS Caremark Corp. |
|
|
|
|
|
|
|
|
|
|
469,452 |
|
|
12,200 |
|
|
|
S |
|
|
D.R. Horton, Inc. |
|
|
|
|
|
|
|
|
|
|
144,448 |
|
|
5,988 |
|
|
|
|
|
|
Danaher Corp. |
|
|
|
|
|
|
|
|
|
|
302,993 |
|
|
1,100 |
|
|
|
|
|
|
Darden Restaurants, Inc. |
|
|
|
|
|
|
|
|
|
|
51,843 |
|
|
2,500 |
|
|
|
@ |
|
|
DaVita, Inc. |
|
|
|
|
|
|
|
|
|
|
198,425 |
|
25
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
10,500 |
|
|
|
@, S |
|
|
Dean Foods Co. |
|
|
|
|
|
|
|
|
|
|
110,880 |
|
|
5,400 |
|
|
|
|
|
|
Deere & Co. |
|
|
|
|
|
|
|
|
|
|
486,810 |
|
|
9,900 |
|
|
|
@ |
|
|
Dell, Inc. |
|
|
|
|
|
|
|
|
|
|
156,717 |
|
|
9,900 |
|
|
|
@ |
|
|
Denbury Resources, Inc. |
|
|
|
|
|
|
|
|
|
|
239,877 |
|
|
1,900 |
|
|
|
|
|
|
Densply International, Inc. |
|
|
|
|
|
|
|
|
|
|
71,003 |
|
|
4,700 |
|
|
|
|
|
|
Devon Energy Corp. |
|
|
|
|
|
|
|
|
|
|
429,768 |
|
|
2,800 |
|
|
|
|
|
|
DeVry, Inc. |
|
|
|
|
|
|
|
|
|
|
151,900 |
|
|
2,500 |
|
|
|
|
|
|
Diamond Offshore Drilling |
|
|
|
|
|
|
|
|
|
|
195,575 |
|
|
5,400 |
|
|
|
@ |
|
|
DIRECTV |
|
|
|
|
|
|
|
|
|
|
248,238 |
|
|
11,000 |
|
|
|
|
|
|
Discover Financial Services |
|
|
|
|
|
|
|
|
|
|
239,250 |
|
|
5,100 |
|
|
|
@ |
|
|
Discovery Communications, Inc. Class A |
|
|
|
|
|
|
|
|
|
|
219,861 |
|
|
8,200 |
|
|
|
|
|
|
Dominion Resources, Inc. |
|
|
|
|
|
|
|
|
|
|
374,166 |
|
|
4,050 |
|
|
|
|
|
|
Dover Corp. |
|
|
|
|
|
|
|
|
|
|
260,213 |
|
|
6,400 |
|
|
|
|
|
|
Dow Chemical Co. |
|
|
|
|
|
|
|
|
|
|
237,824 |
|
|
6,531 |
|
|
|
|
|
|
Dr Pepper Snapple Group, Inc. |
|
|
|
|
|
|
|
|
|
|
235,508 |
|
|
2,390 |
|
|
|
|
|
|
DTE Energy Co. |
|
|
|
|
|
|
|
|
|
|
112,521 |
|
|
17,300 |
|
|
|
|
|
|
Duke Energy Corp. |
|
|
|
|
|
|
|
|
|
|
311,227 |
|
|
1,541 |
|
|
|
|
|
|
Dun & Bradstreet Corp. |
|
|
|
|
|
|
|
|
|
|
124,513 |
|
|
1,437 |
|
|
|
@ |
|
|
E*Trade Financial Corp. |
|
|
|
|
|
|
|
|
|
|
22,963 |
|
|
3,400 |
|
|
|
|
|
|
Eaton Corp. |
|
|
|
|
|
|
|
|
|
|
376,652 |
|
|
10,316 |
|
|
|
@ |
|
|
eBay, Inc. |
|
|
|
|
|
|
|
|
|
|
345,638 |
|
|
3,641 |
|
|
|
|
|
|
Ecolab, Inc. |
|
|
|
|
|
|
|
|
|
|
177,098 |
|
|
3,900 |
|
|
|
|
|
|
Edison International |
|
|
|
|
|
|
|
|
|
|
144,768 |
|
|
5,300 |
|
|
|
|
|
|
EI Du Pont de Nemours & Co. |
|
|
|
|
|
|
|
|
|
|
290,811 |
|
|
6,544 |
|
|
|
S |
|
|
El Paso Corp. |
|
|
|
|
|
|
|
|
|
|
121,718 |
|
|
8,400 |
|
|
|
@ |
|
|
Electronic Arts, Inc. |
|
|
|
|
|
|
|
|
|
|
157,920 |
|
|
9,900 |
|
|
|
|
|
|
Eli Lilly & Co. |
|
|
|
|
|
|
|
|
|
|
342,144 |
|
|
17,950 |
|
|
|
@ |
|
|
EMC Corp. |
|
|
|
|
|
|
|
|
|
|
488,420 |
|
|
10,048 |
|
|
|
|
|
|
Emerson Electric Co. |
|
|
|
|
|
|
|
|
|
|
599,464 |
|
|
4,000 |
|
|
|
|
|
|
Entergy Corp. |
|
|
|
|
|
|
|
|
|
|
284,800 |
|
|
4,300 |
|
|
|
|
|
|
EOG Resources, Inc. |
|
|
|
|
|
|
|
|
|
|
482,933 |
|
|
3,800 |
|
|
|
|
|
|
EQT Corp. |
|
|
|
|
|
|
|
|
|
|
187,340 |
|
|
3,165 |
|
|
|
|
|
|
Equifax, Inc. |
|
|
|
|
|
|
|
|
|
|
113,149 |
|
|
2,100 |
|
|
|
|
|
|
Estee Lauder Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
198,261 |
|
|
8,431 |
|
|
|
|
|
|
Exelon Corp. |
|
|
|
|
|
|
|
|
|
|
352,079 |
|
|
5,700 |
|
|
|
|
|
|
Expedia, Inc. |
|
|
|
|
|
|
|
|
|
|
113,202 |
|
|
3,600 |
|
|
|
|
|
|
Expeditors International Washington, Inc. |
|
|
|
|
|
|
|
|
|
|
172,080 |
|
|
7,500 |
|
|
|
@ |
|
|
Express Scripts, Inc. |
|
|
|
|
|
|
|
|
|
|
421,650 |
|
|
64,169 |
|
|
|
S |
|
|
ExxonMobil Corp. |
|
|
|
|
|
|
|
|
|
|
5,488,356 |
|
|
1,800 |
|
|
|
@ |
|
|
F5 Networks, Inc. |
|
|
|
|
|
|
|
|
|
|
212,418 |
|
|
704 |
|
|
|
|
|
|
Family Dollar Stores, Inc. |
|
|
|
|
|
|
|
|
|
|
35,256 |
|
|
1,100 |
|
|
|
|
|
|
Fastenal Co. |
|
|
|
|
|
|
|
|
|
|
68,343 |
|
|
4,200 |
|
|
|
|
|
|
Federated Investors, Inc. |
|
|
|
|
|
|
|
|
|
|
115,752 |
|
|
896 |
|
|
|
|
|
|
FedEx Corp. |
|
|
|
|
|
|
|
|
|
|
80,658 |
|
|
893 |
|
|
|
|
|
|
Fidelity National Information Services, Inc. |
|
|
|
|
|
|
|
|
|
|
28,924 |
|
|
17,226 |
|
|
|
|
|
|
Fifth Third Bancorp. |
|
|
|
|
|
|
|
|
|
|
251,500 |
|
|
1,000 |
|
|
|
|
|
|
First Horizon National Corp. |
|
|
|
|
|
|
|
|
|
|
11,500 |
|
|
207 |
|
|
|
@ |
|
|
First Solar, Inc. |
|
|
|
|
|
|
|
|
|
|
30,510 |
|
|
5,167 |
|
|
|
|
|
|
FirstEnergy Corp. |
|
|
|
|
|
|
|
|
|
|
197,911 |
|
|
1,072 |
|
|
|
@ |
|
|
Fiserv, Inc. |
|
|
|
|
|
|
|
|
|
|
67,825 |
|
|
1,400 |
|
|
|
|
|
|
Flir Systems, Inc. |
|
|
|
|
|
|
|
|
|
|
45,220 |
|
|
1,500 |
|
|
|
|
|
|
Flowserve Corp. |
|
|
|
|
|
|
|
|
|
|
187,455 |
|
|
4,000 |
|
|
|
|
|
|
Fluor Corp. |
|
|
|
|
|
|
|
|
|
|
283,040 |
|
|
1,900 |
|
|
|
|
|
|
FMC Corp. |
|
|
|
|
|
|
|
|
|
|
147,136 |
|
|
2,900 |
|
|
|
@ |
|
|
FMC Technologies, Inc. |
|
|
|
|
|
|
|
|
|
|
272,745 |
|
|
21,827 |
|
|
|
@ |
|
|
Ford Motor Co. |
|
|
|
|
|
|
|
|
|
|
328,496 |
|
|
6,500 |
|
|
|
@ |
|
|
Forest Laboratories, Inc. |
|
|
|
|
|
|
|
|
|
|
210,600 |
|
|
4,300 |
|
|
|
|
|
|
Fortune Brands, Inc. |
|
|
|
|
|
|
|
|
|
|
265,998 |
|
|
2,400 |
|
|
|
|
|
|
Franklin Resources, Inc. |
|
|
|
|
|
|
|
|
|
|
301,488 |
|
|
5,400 |
|
|
|
|
|
|
Freeport-McMoRan Copper & Gold, Inc. |
|
|
|
|
|
|
|
|
|
|
285,930 |
|
|
26,000 |
|
|
|
S |
|
|
Frontier Communications Corp. |
|
|
|
|
|
|
|
|
|
|
220,740 |
|
|
500 |
|
|
|
@ |
|
|
GameStop Corp. |
|
|
|
|
|
|
|
|
|
|
9,975 |
|
|
700 |
|
|
|
|
|
|
Gannett Co., Inc. |
|
|
|
|
|
|
|
|
|
|
11,557 |
|
|
8,470 |
|
|
|
|
|
|
Gap, Inc. |
|
|
|
|
|
|
|
|
|
|
190,829 |
|
|
4,800 |
|
|
|
|
|
|
General Dynamics Corp. |
|
|
|
|
|
|
|
|
|
|
365,376 |
|
|
124,416 |
|
|
|
|
|
|
General Electric Co. |
|
|
|
|
|
|
|
|
|
|
2,602,783 |
|
|
3,538 |
|
|
|
|
|
|
General Mills, Inc. |
|
|
|
|
|
|
|
|
|
|
131,401 |
|
|
3,300 |
|
|
|
|
|
|
Genuine Parts Co. |
|
|
|
|
|
|
|
|
|
|
173,877 |
|
|
6,300 |
|
|
|
@ |
|
|
Genworth Financial, Inc. |
|
|
|
|
|
|
|
|
|
|
83,349 |
|
|
1,900 |
|
|
|
@ |
|
|
Genzyme Corp. |
|
|
|
|
|
|
|
|
|
|
143,355 |
|
|
12,200 |
|
|
|
@ |
|
|
Gilead Sciences, Inc. |
|
|
|
|
|
|
|
|
|
|
475,556 |
|
|
5,405 |
|
|
|
|
|
|
Goldman Sachs Group, Inc. |
|
|
|
|
|
|
|
|
|
|
885,231 |
|
|
2,900 |
|
|
|
|
|
|
Goodrich Corp. |
|
|
|
|
|
|
|
|
|
|
250,067 |
|
|
10,487 |
|
|
|
@, S |
|
|
Goodyear Tire & Rubber Co. |
|
|
|
|
|
|
|
|
|
|
148,706 |
|
|
2,669 |
|
|
|
@ |
|
|
Google, Inc. Class A |
|
|
|
|
|
|
|
|
|
|
1,637,165 |
|
|
2,100 |
|
|
|
S |
|
|
H&R Block, Inc. |
|
|
|
|
|
|
|
|
|
|
31,899 |
|
|
12,100 |
|
|
|
|
|
|
Halliburton Co. |
|
|
|
|
|
|
|
|
|
|
567,974 |
|
|
1,072 |
|
|
|
|
|
|
Harley-Davidson, Inc. |
|
|
|
|
|
|
|
|
|
|
43,759 |
|
|
3,000 |
|
|
|
|
|
|
Harman International Industries, Inc. |
|
|
|
|
|
|
|
|
|
|
145,920 |
|
26
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
3,543 |
|
|
|
|
|
|
Harris Corp. |
|
|
|
|
|
|
|
|
|
|
165,316 |
|
|
4,100 |
|
|
|
|
|
|
Hartford Financial Services Group, Inc. |
|
|
|
|
|
|
|
|
|
|
121,360 |
|
|
4,600 |
|
|
|
|
|
|
Hasbro, Inc. |
|
|
|
|
|
|
|
|
|
|
206,540 |
|
|
3,400 |
|
|
|
|
|
|
Helmerich & Payne, Inc. |
|
|
|
|
|
|
|
|
|
|
220,966 |
|
|
776 |
|
|
|
|
|
|
Hershey Co. |
|
|
|
|
|
|
|
|
|
|
40,600 |
|
|
2,600 |
|
|
|
|
|
|
Hess Corp. |
|
|
|
|
|
|
|
|
|
|
226,278 |
|
|
21,609 |
|
|
|
|
|
|
Hewlett-Packard Co. |
|
|
|
|
|
|
|
|
|
|
942,801 |
|
|
3,500 |
|
|
|
|
|
|
HJ Heinz Co. |
|
|
|
|
|
|
|
|
|
|
175,770 |
|
|
13,000 |
|
|
|
|
|
|
Home Depot, Inc. |
|
|
|
|
|
|
|
|
|
|
487,110 |
|
|
10,300 |
|
|
|
|
|
|
Honeywell International, Inc. |
|
|
|
|
|
|
|
|
|
|
596,473 |
|
|
800 |
|
|
|
|
|
|
Hormel Foods Corp. |
|
|
|
|
|
|
|
|
|
|
21,920 |
|
|
4,700 |
|
|
|
@ |
|
|
Hospira, Inc. |
|
|
|
|
|
|
|
|
|
|
248,395 |
|
|
14,781 |
|
|
|
S |
|
|
Hudson City Bancorp., Inc. |
|
|
|
|
|
|
|
|
|
|
169,982 |
|
|
1,133 |
|
|
|
@ |
|
|
Humana, Inc. |
|
|
|
|
|
|
|
|
|
|
73,656 |
|
|
22,300 |
|
|
|
S |
|
|
Huntington Bancshares, Inc. |
|
|
|
|
|
|
|
|
|
|
152,532 |
|
|
5,581 |
|
|
|
|
|
|
Illinois Tool Works, Inc. |
|
|
|
|
|
|
|
|
|
|
301,932 |
|
|
3,191 |
|
|
|
|
|
|
Integrys Energy Group, Inc. |
|
|
|
|
|
|
|
|
|
|
156,263 |
|
|
43,402 |
|
|
|
|
|
|
Intel Corp. |
|
|
|
|
|
|
|
|
|
|
931,841 |
|
|
500 |
|
|
|
@ |
|
|
IntercontinentalExchange, Inc. |
|
|
|
|
|
|
|
|
|
|
64,100 |
|
|
13,189 |
|
|
|
|
|
|
International Business Machines Corp. |
|
|
|
|
|
|
|
|
|
|
2,135,035 |
|
|
2,283 |
|
|
|
|
|
|
International Flavors & Fragrances, Inc. |
|
|
|
|
|
|
|
|
|
|
130,017 |
|
|
8,600 |
|
|
|
|
|
|
International Game Technology |
|
|
|
|
|
|
|
|
|
|
141,556 |
|
|
2,268 |
|
|
|
|
|
|
International Paper Co. |
|
|
|
|
|
|
|
|
|
|
63,005 |
|
|
12,500 |
|
|
|
@, S |
|
|
Interpublic Group of Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
165,000 |
|
|
2,100 |
|
|
|
@ |
|
|
Intuit, Inc. |
|
|
|
|
|
|
|
|
|
|
110,418 |
|
|
1,000 |
|
|
|
@ |
|
|
Intuitive Surgical, Inc. |
|
|
|
|
|
|
|
|
|
|
327,950 |
|
|
3,551 |
|
|
|
@ |
|
|
Invesco Ltd. |
|
|
|
|
|
|
|
|
|
|
95,309 |
|
|
5,246 |
|
|
|
|
|
|
Iron Mountain, Inc. |
|
|
|
|
|
|
|
|
|
|
136,396 |
|
|
4,286 |
|
|
|
|
|
|
ITT Corp. |
|
|
|
|
|
|
|
|
|
|
248,288 |
|
|
6,200 |
|
|
|
|
|
|
Jabil Circuit, Inc. |
|
|
|
|
|
|
|
|
|
|
132,866 |
|
|
4,000 |
|
|
|
@ |
|
|
Jacobs Engineering Group, Inc. |
|
|
|
|
|
|
|
|
|
|
200,240 |
|
|
8,700 |
|
|
|
S |
|
|
Janus Capital Group, Inc. |
|
|
|
|
|
|
|
|
|
|
116,841 |
|
|
1,300 |
|
|
|
|
|
|
JC Penney Co., Inc. |
|
|
|
|
|
|
|
|
|
|
45,448 |
|
|
6,700 |
|
|
|
@ |
|
|
JDS Uniphase Corp. |
|
|
|
|
|
|
|
|
|
|
165,289 |
|
|
2,400 |
|
|
|
|
|
|
JM Smucker Co. |
|
|
|
|
|
|
|
|
|
|
165,216 |
|
|
31,575 |
|
|
|
|
|
|
Johnson & Johnson |
|
|
|
|
|
|
|
|
|
|
1,939,968 |
|
|
2,415 |
|
|
|
|
|
|
Johnson Controls, Inc. |
|
|
|
|
|
|
|
|
|
|
98,532 |
|
|
43,657 |
|
|
|
|
|
|
JPMorgan Chase & Co. |
|
|
|
|
|
|
|
|
|
|
2,038,345 |
|
|
4,500 |
|
|
|
@ |
|
|
Juniper Networks, Inc. |
|
|
|
|
|
|
|
|
|
|
198,000 |
|
|
1,000 |
|
|
|
|
|
|
Kellogg Co. |
|
|
|
|
|
|
|
|
|
|
53,560 |
|
|
19,700 |
|
|
|
S |
|
|
Keycorp |
|
|
|
|
|
|
|
|
|
|
180,058 |
|
|
1,845 |
|
|
|
|
|
|
Kimberly-Clark Corp. |
|
|
|
|
|
|
|
|
|
|
121,586 |
|
|
900 |
|
|
|
|
|
|
KLA-Tencor Corp. |
|
|
|
|
|
|
|
|
|
|
43,938 |
|
|
1,900 |
|
|
|
@ |
|
|
Kohls Corp. |
|
|
|
|
|
|
|
|
|
|
102,391 |
|
|
13,200 |
|
|
|
|
|
|
Kraft Foods, Inc. |
|
|
|
|
|
|
|
|
|
|
420,288 |
|
|
12,000 |
|
|
|
|
|
|
Kroger Co. |
|
|
|
|
|
|
|
|
|
|
274,800 |
|
|
1,200 |
|
|
|
|
|
|
L-3 Communications Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
95,148 |
|
|
2,200 |
|
|
|
@ |
|
|
Laboratory Corp. of America Holdings |
|
|
|
|
|
|
|
|
|
|
198,286 |
|
|
600 |
|
|
|
|
|
|
Legg Mason, Inc. |
|
|
|
|
|
|
|
|
|
|
21,750 |
|
|
1,500 |
|
|
|
|
|
|
Leggett & Platt, Inc. |
|
|
|
|
|
|
|
|
|
|
34,590 |
|
|
1,700 |
|
|
|
|
|
|
Lennar Corp. |
|
|
|
|
|
|
|
|
|
|
34,272 |
|
|
800 |
|
|
|
|
|
|
Leucadia National Corp. |
|
|
|
|
|
|
|
|
|
|
26,504 |
|
|
3,100 |
|
|
|
@ |
|
|
Lexmark International, Inc. |
|
|
|
|
|
|
|
|
|
|
116,343 |
|
|
3,800 |
|
|
|
@ |
|
|
Life Technologies Corp. |
|
|
|
|
|
|
|
|
|
|
202,806 |
|
|
5,800 |
|
|
|
|
|
|
Limited Brands, Inc. |
|
|
|
|
|
|
|
|
|
|
185,716 |
|
|
2,900 |
|
|
|
|
|
|
Lincoln National Corp. |
|
|
|
|
|
|
|
|
|
|
91,988 |
|
|
1,100 |
|
|
|
|
|
|
Linear Technology Corp. |
|
|
|
|
|
|
|
|
|
|
38,016 |
|
|
3,340 |
|
|
|
|
|
|
Lockheed Martin Corp. |
|
|
|
|
|
|
|
|
|
|
264,394 |
|
|
6,900 |
|
|
|
|
|
|
Loews Corp. |
|
|
|
|
|
|
|
|
|
|
298,425 |
|
|
398 |
|
|
|
|
|
|
Lorillard, Inc. |
|
|
|
|
|
|
|
|
|
|
30,554 |
|
|
8,800 |
|
|
|
|
|
|
Lowes Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
230,296 |
|
|
19,600 |
|
|
|
@, S |
|
|
LSI Logic Corp. |
|
|
|
|
|
|
|
|
|
|
123,284 |
|
|
700 |
|
|
|
|
|
|
M&T Bank Corp. |
|
|
|
|
|
|
|
|
|
|
61,635 |
|
|
2,696 |
|
|
|
|
|
|
Macys, Inc. |
|
|
|
|
|
|
|
|
|
|
64,434 |
|
|
6,700 |
|
|
|
|
|
|
Marathon Oil Corp. |
|
|
|
|
|
|
|
|
|
|
332,320 |
|
|
2,800 |
|
|
|
|
|
|
Marriott International, Inc. |
|
|
|
|
|
|
|
|
|
|
109,788 |
|
|
11,300 |
|
|
|
|
|
|
Marsh & McLennan Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
343,972 |
|
|
17,200 |
|
|
|
S |
|
|
Marshall & Ilsley Corp. |
|
|
|
|
|
|
|
|
|
|
133,644 |
|
|
12,600 |
|
|
|
S |
|
|
Masco Corp. |
|
|
|
|
|
|
|
|
|
|
171,234 |
|
|
900 |
|
|
|
|
|
|
Massey Energy Co. |
|
|
|
|
|
|
|
|
|
|
56,997 |
|
|
704 |
|
|
|
|
|
|
Mastercard, Inc. |
|
|
|
|
|
|
|
|
|
|
169,354 |
|
|
5,500 |
|
|
|
|
|
|
Mattel, Inc. |
|
|
|
|
|
|
|
|
|
|
137,830 |
|
|
1,100 |
|
|
|
@ |
|
|
McAfee, Inc. |
|
|
|
|
|
|
|
|
|
|
52,745 |
|
|
800 |
|
|
|
|
|
|
McCormick & Co., Inc. |
|
|
|
|
|
|
|
|
|
|
38,120 |
|
|
12,600 |
|
|
|
|
|
|
McDonalds Corp. |
|
|
|
|
|
|
|
|
|
|
953,568 |
|
|
1,700 |
|
|
|
|
|
|
McGraw-Hill Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
65,756 |
|
|
1,789 |
|
|
|
|
|
|
McKesson Corp. |
|
|
|
|
|
|
|
|
|
|
141,832 |
|
|
3,225 |
|
|
|
|
|
|
Mead Johnson Nutrition Co. |
|
|
|
|
|
|
|
|
|
|
193,016 |
|
|
4,300 |
|
|
|
|
|
|
MeadWestvaco Corp. |
|
|
|
|
|
|
|
|
|
|
126,205 |
|
27
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
3,005 |
|
|
|
@ |
|
|
Medco Health Solutions, Inc. |
|
|
|
|
|
|
|
|
|
|
185,228 |
|
|
16,700 |
|
|
|
|
|
|
Medtronic, Inc. |
|
|
|
|
|
|
|
|
|
|
666,664 |
|
|
9,300 |
|
|
|
@, S |
|
|
MEMC Electronic Materials, Inc. |
|
|
|
|
|
|
|
|
|
|
126,201 |
|
|
34,427 |
|
|
|
|
|
|
Merck & Co., Inc. |
|
|
|
|
|
|
|
|
|
|
1,121,287 |
|
|
10,800 |
|
|
|
|
|
|
Metlife, Inc. |
|
|
|
|
|
|
|
|
|
|
511,488 |
|
|
11,100 |
|
|
|
@, S |
|
|
MetroPCS Communications, Inc. |
|
|
|
|
|
|
|
|
|
|
159,840 |
|
|
900 |
|
|
|
|
|
|
Microchip Technology, Inc. |
|
|
|
|
|
|
|
|
|
|
33,219 |
|
|
16,700 |
|
|
|
@, S |
|
|
Micron Technology, Inc. |
|
|
|
|
|
|
|
|
|
|
185,871 |
|
|
80,162 |
|
|
|
|
|
|
Microsoft Corp. |
|
|
|
|
|
|
|
|
|
|
2,130,706 |
|
|
5,200 |
|
|
|
|
|
|
Molex, Inc. |
|
|
|
|
|
|
|
|
|
|
145,236 |
|
|
4,300 |
|
|
|
|
|
|
Molson Coors Brewing Co. |
|
|
|
|
|
|
|
|
|
|
196,639 |
|
|
2,954 |
|
|
|
|
|
|
Monsanto Co. |
|
|
|
|
|
|
|
|
|
|
212,363 |
|
|
7,300 |
|
|
|
@ |
|
|
Monster Worldwide, Inc. |
|
|
|
|
|
|
|
|
|
|
125,195 |
|
|
900 |
|
|
|
|
|
|
Moodys Corp. |
|
|
|
|
|
|
|
|
|
|
28,710 |
|
|
14,500 |
|
|
|
|
|
|
Morgan Stanley |
|
|
|
|
|
|
|
|
|
|
430,360 |
|
|
7,387 |
|
|
|
@ |
|
|
Motorola Mobility Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
223,087 |
|
|
3,928 |
|
|
|
@ |
|
|
Motorola Solutions, Inc. |
|
|
|
|
|
|
|
|
|
|
151,778 |
|
|
1,600 |
|
|
|
|
|
|
Murphy Oil Corp. |
|
|
|
|
|
|
|
|
|
|
117,648 |
|
|
2,900 |
|
|
|
@ |
|
|
Mylan Laboratories |
|
|
|
|
|
|
|
|
|
|
66,323 |
|
|
4,600 |
|
|
|
@ |
|
|
Nasdaq Stock Market, Inc. |
|
|
|
|
|
|
|
|
|
|
131,606 |
|
|
5,240 |
|
|
|
|
|
|
National Oilwell Varco, Inc. |
|
|
|
|
|
|
|
|
|
|
416,947 |
|
|
5,310 |
|
|
|
@ |
|
|
NetApp, Inc. |
|
|
|
|
|
|
|
|
|
|
274,315 |
|
|
400 |
|
|
|
@ |
|
|
NetFlix, Inc. |
|
|
|
|
|
|
|
|
|
|
82,668 |
|
|
9,800 |
|
|
|
|
|
|
Newell Rubbermaid, Inc. |
|
|
|
|
|
|
|
|
|
|
189,532 |
|
|
3,000 |
|
|
|
@ |
|
|
Newfield Exploration Co. |
|
|
|
|
|
|
|
|
|
|
218,370 |
|
|
5,544 |
|
|
|
|
|
|
Newmont Mining Corp. |
|
|
|
|
|
|
|
|
|
|
306,417 |
|
|
25,900 |
|
|
|
|
|
|
News Corp. Class A |
|
|
|
|
|
|
|
|
|
|
449,883 |
|
|
5,500 |
|
|
|
|
|
|
NextEra Energy, Inc. |
|
|
|
|
|
|
|
|
|
|
305,085 |
|
|
585 |
|
|
|
|
|
|
Nicor, Inc. |
|
|
|
|
|
|
|
|
|
|
30,853 |
|
|
5,600 |
|
|
|
|
|
|
Nike, Inc. |
|
|
|
|
|
|
|
|
|
|
498,568 |
|
|
4,600 |
|
|
|
|
|
|
NiSource, Inc. |
|
|
|
|
|
|
|
|
|
|
88,136 |
|
|
5,600 |
|
|
|
@ |
|
|
Noble Corp. |
|
|
|
|
|
|
|
|
|
|
250,376 |
|
|
1,558 |
|
|
|
|
|
|
Noble Energy, Inc. |
|
|
|
|
|
|
|
|
|
|
144,364 |
|
|
900 |
|
|
|
|
|
|
Nordstrom, Inc. |
|
|
|
|
|
|
|
|
|
|
40,734 |
|
|
4,491 |
|
|
|
|
|
|
Norfolk Southern Corp. |
|
|
|
|
|
|
|
|
|
|
294,520 |
|
|
5,600 |
|
|
|
|
|
|
Northeast Utilities |
|
|
|
|
|
|
|
|
|
|
190,624 |
|
|
4,500 |
|
|
|
|
|
|
Northern Trust Corp. |
|
|
|
|
|
|
|
|
|
|
232,065 |
|
|
3,300 |
|
|
|
|
|
|
Northrop Grumman Corp. |
|
|
|
|
|
|
|
|
|
|
220,044 |
|
|
18,700 |
|
|
|
@, S |
|
|
Novell, Inc. |
|
|
|
|
|
|
|
|
|
|
109,956 |
|
|
3,300 |
|
|
|
@ |
|
|
Novellus Systems, Inc. |
|
|
|
|
|
|
|
|
|
|
131,868 |
|
|
6,667 |
|
|
|
@ |
|
|
NRG Energy, Inc. |
|
|
|
|
|
|
|
|
|
|
133,273 |
|
|
1,000 |
|
|
|
|
|
|
Nucor Corp. |
|
|
|
|
|
|
|
|
|
|
47,960 |
|
|
9,200 |
|
|
|
@ |
|
|
Nvidia Corp. |
|
|
|
|
|
|
|
|
|
|
208,472 |
|
|
1,900 |
|
|
|
|
|
|
NYSE Euronext |
|
|
|
|
|
|
|
|
|
|
70,300 |
|
|
9,600 |
|
|
|
|
|
|
Occidental Petroleum Corp. |
|
|
|
|
|
|
|
|
|
|
978,912 |
|
|
1,700 |
|
|
|
|
|
|
Omnicom Group |
|
|
|
|
|
|
|
|
|
|
86,530 |
|
|
1,700 |
|
|
|
|
|
|
Oneok, Inc. |
|
|
|
|
|
|
|
|
|
|
109,769 |
|
|
39,775 |
|
|
|
|
|
|
Oracle Corp. |
|
|
|
|
|
|
|
|
|
|
1,308,598 |
|
|
900 |
|
|
|
@ |
|
|
OReilly Automotive, Inc. |
|
|
|
|
|
|
|
|
|
|
50,022 |
|
|
4,000 |
|
|
|
@ |
|
|
Owens-Illinois, Inc. |
|
|
|
|
|
|
|
|
|
|
121,960 |
|
|
7,300 |
|
|
|
|
|
|
Paccar, Inc. |
|
|
|
|
|
|
|
|
|
|
365,949 |
|
|
9,100 |
|
|
|
|
|
|
Pacific Gas & Electric Co. |
|
|
|
|
|
|
|
|
|
|
419,146 |
|
|
1,538 |
|
|
|
|
|
|
Pall Corp. |
|
|
|
|
|
|
|
|
|
|
83,606 |
|
|
3,600 |
|
|
|
|
|
|
Parker Hannifin Corp. |
|
|
|
|
|
|
|
|
|
|
321,048 |
|
|
400 |
|
|
|
|
|
|
Patterson Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
13,352 |
|
|
2,200 |
|
|
|
|
|
|
Paychex, Inc. |
|
|
|
|
|
|
|
|
|
|
73,986 |
|
|
2,300 |
|
|
|
|
|
|
Peabody Energy Corp. |
|
|
|
|
|
|
|
|
|
|
150,627 |
|
|
11,200 |
|
|
|
|
|
|
Peoples United Financial, Inc. |
|
|
|
|
|
|
|
|
|
|
147,616 |
|
|
8,800 |
|
|
|
|
|
|
Pepco Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
164,824 |
|
|
22,500 |
|
|
|
|
|
|
PepsiCo, Inc. |
|
|
|
|
|
|
|
|
|
|
1,426,950 |
|
|
4,700 |
|
|
|
|
|
|
PerkinElmer, Inc. |
|
|
|
|
|
|
|
|
|
|
124,550 |
|
|
91,255 |
|
|
|
|
|
|
Pfizer, Inc. |
|
|
|
|
|
|
|
|
|
|
1,755,746 |
|
|
12,170 |
|
|
|
|
|
|
Philip Morris International, Inc. |
|
|
|
|
|
|
|
|
|
|
764,033 |
|
|
4,400 |
|
|
|
|
|
|
Pinnacle West Capital Corp. |
|
|
|
|
|
|
|
|
|
|
185,812 |
|
|
2,400 |
|
|
|
|
|
|
Pioneer Natural Resources Co. |
|
|
|
|
|
|
|
|
|
|
245,616 |
|
|
841 |
|
|
|
|
|
|
Pitney Bowes, Inc. |
|
|
|
|
|
|
|
|
|
|
21,176 |
|
|
4,500 |
|
|
|
|
|
|
PNC Financial Services Group, Inc. |
|
|
|
|
|
|
|
|
|
|
277,650 |
|
|
1,100 |
|
|
|
|
|
|
Polo Ralph Lauren Corp. |
|
|
|
|
|
|
|
|
|
|
139,381 |
|
|
466 |
|
|
|
|
|
|
PPG Industries, Inc. |
|
|
|
|
|
|
|
|
|
|
41,185 |
|
|
6,200 |
|
|
|
|
|
|
PPL Corp. |
|
|
|
|
|
|
|
|
|
|
157,666 |
|
|
1,415 |
|
|
|
|
|
|
Praxair, Inc. |
|
|
|
|
|
|
|
|
|
|
140,623 |
|
|
2,900 |
|
|
|
|
|
|
Precision Castparts Corp. |
|
|
|
|
|
|
|
|
|
|
411,075 |
|
|
600 |
|
|
|
@ |
|
|
Priceline.com, Inc. |
|
|
|
|
|
|
|
|
|
|
272,328 |
|
|
7,700 |
|
|
|
|
|
|
Principal Financial Group, Inc. |
|
|
|
|
|
|
|
|
|
|
263,802 |
|
|
21,550 |
|
|
|
|
|
|
Procter & Gamble Co. |
|
|
|
|
|
|
|
|
|
|
1,358,728 |
|
|
3,500 |
|
|
|
|
|
|
Progress Energy, Inc. |
|
|
|
|
|
|
|
|
|
|
159,985 |
|
|
6,200 |
|
|
|
|
|
|
Progressive Corp. |
|
|
|
|
|
|
|
|
|
|
129,146 |
|
|
5,500 |
|
|
|
|
|
|
Prudential Financial, Inc. |
|
|
|
|
|
|
|
|
|
|
362,065 |
|
|
7,500 |
|
|
|
|
|
|
Public Service Enterprise Group, Inc. |
|
|
|
|
|
|
|
|
|
|
245,250 |
|
28
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
19,600 |
|
|
|
@, S |
|
|
Pulte Homes, Inc. |
|
|
|
|
|
|
|
|
|
|
135,240 |
|
|
4,700 |
|
|
|
|
|
|
QEP Resources, Inc. |
|
|
|
|
|
|
|
|
|
|
185,885 |
|
|
17,805 |
|
|
|
|
|
|
Qualcomm, Inc. |
|
|
|
|
|
|
|
|
|
|
1,060,822 |
|
|
7,300 |
|
|
|
@ |
|
|
Quanta Services, Inc. |
|
|
|
|
|
|
|
|
|
|
166,513 |
|
|
3,000 |
|
|
|
|
|
|
Quest Diagnostics |
|
|
|
|
|
|
|
|
|
|
170,250 |
|
|
20,000 |
|
|
|
S |
|
|
Qwest Communications International, Inc. |
|
|
|
|
|
|
|
|
|
|
136,400 |
|
|
7,400 |
|
|
|
|
|
|
RadioShack Corp. |
|
|
|
|
|
|
|
|
|
|
109,520 |
|
|
4,300 |
|
|
|
|
|
|
Range Resources Corp. |
|
|
|
|
|
|
|
|
|
|
233,490 |
|
|
4,200 |
|
|
|
|
|
|
Raytheon Co. |
|
|
|
|
|
|
|
|
|
|
215,082 |
|
|
1,393 |
|
|
|
@ |
|
|
Red Hat, Inc. |
|
|
|
|
|
|
|
|
|
|
57,503 |
|
|
27,400 |
|
|
|
S |
|
|
Regions Financial Corp. |
|
|
|
|
|
|
|
|
|
|
209,336 |
|
|
5,686 |
|
|
|
|
|
|
Republic Services, Inc. |
|
|
|
|
|
|
|
|
|
|
168,362 |
|
|
8,200 |
|
|
|
|
|
|
Reynolds American, Inc. |
|
|
|
|
|
|
|
|
|
|
281,424 |
|
|
3,814 |
|
|
|
|
|
|
Robert Half International, Inc. |
|
|
|
|
|
|
|
|
|
|
121,667 |
|
|
3,300 |
|
|
|
|
|
|
Rockwell Automation, Inc. |
|
|
|
|
|
|
|
|
|
|
289,509 |
|
|
2,707 |
|
|
|
|
|
|
Rockwell Collins, Inc. |
|
|
|
|
|
|
|
|
|
|
174,439 |
|
|
2,500 |
|
|
|
|
|
|
Roper Industries, Inc. |
|
|
|
|
|
|
|
|
|
|
210,325 |
|
|
2,400 |
|
|
|
|
|
|
Ross Stores, Inc. |
|
|
|
|
|
|
|
|
|
|
172,896 |
|
|
4,100 |
|
|
|
@ |
|
|
Rowan Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
174,947 |
|
|
2,800 |
|
|
|
|
|
|
Ryder System, Inc. |
|
|
|
|
|
|
|
|
|
|
133,924 |
|
|
8,800 |
|
|
|
|
|
|
Safeway, Inc. |
|
|
|
|
|
|
|
|
|
|
192,016 |
|
|
1,100 |
|
|
|
@ |
|
|
SAIC, Inc. |
|
|
|
|
|
|
|
|
|
|
17,974 |
|
|
900 |
|
|
|
@ |
|
|
Salesforce.com, Inc. |
|
|
|
|
|
|
|
|
|
|
119,043 |
|
|
1,200 |
|
|
|
@ |
|
|
Sandisk Corp. |
|
|
|
|
|
|
|
|
|
|
59,520 |
|
|
11,300 |
|
|
|
|
|
|
Sara Lee Corp. |
|
|
|
|
|
|
|
|
|
|
193,456 |
|
|
1,632 |
|
|
|
|
|
|
SCANA Corp. |
|
|
|
|
|
|
|
|
|
|
66,063 |
|
|
20,705 |
|
|
|
|
|
|
Schlumberger Ltd. |
|
|
|
|
|
|
|
|
|
|
1,934,261 |
|
|
2,600 |
|
|
|
|
|
|
Scripps Networks Interactive Class A |
|
|
|
|
|
|
|
|
|
|
135,044 |
|
|
4,600 |
|
|
|
|
|
|
Sealed Air Corp. |
|
|
|
|
|
|
|
|
|
|
126,592 |
|
|
100 |
|
|
|
@ |
|
|
Sears Holding Corp. |
|
|
|
|
|
|
|
|
|
|
8,331 |
|
|
3,100 |
|
|
|
|
|
|
Sempra Energy |
|
|
|
|
|
|
|
|
|
|
165,013 |
|
|
554 |
|
|
|
|
|
|
Sigma-Aldrich Corp. |
|
|
|
|
|
|
|
|
|
|
35,395 |
|
|
5,000 |
|
|
|
@, S |
|
|
SLM Corp. |
|
|
|
|
|
|
|
|
|
|
74,100 |
|
|
400 |
|
|
|
|
|
|
Snap-On, Inc. |
|
|
|
|
|
|
|
|
|
|
22,972 |
|
|
12,100 |
|
|
|
|
|
|
Southern Co. |
|
|
|
|
|
|
|
|
|
|
461,131 |
|
|
13,300 |
|
|
|
S |
|
|
Southwest Airlines Co. |
|
|
|
|
|
|
|
|
|
|
157,339 |
|
|
7,100 |
|
|
|
@ |
|
|
Southwestern Energy Co. |
|
|
|
|
|
|
|
|
|
|
280,308 |
|
|
6,000 |
|
|
|
|
|
|
Spectra Energy Corp. |
|
|
|
|
|
|
|
|
|
|
160,500 |
|
|
67,300 |
|
|
|
@, S |
|
|
Sprint Nextel Corp. |
|
|
|
|
|
|
|
|
|
|
294,101 |
|
|
7,900 |
|
|
|
@ |
|
|
St. Jude Medical, Inc. |
|
|
|
|
|
|
|
|
|
|
378,252 |
|
|
2,400 |
|
|
|
|
|
|
Stanley Black & Decker, Inc. |
|
|
|
|
|
|
|
|
|
|
181,992 |
|
|
6,500 |
|
|
|
|
|
|
Staples, Inc. |
|
|
|
|
|
|
|
|
|
|
138,450 |
|
|
6,627 |
|
|
|
|
|
|
Starbucks Corp. |
|
|
|
|
|
|
|
|
|
|
218,558 |
|
|
1,900 |
|
|
|
|
|
|
Starwood Hotels & Resorts Worldwide, Inc. |
|
|
|
|
|
|
|
|
|
|
116,090 |
|
|
4,023 |
|
|
|
|
|
|
State Street Corp. |
|
|
|
|
|
|
|
|
|
|
179,909 |
|
|
354 |
|
|
|
@ |
|
|
Stericycle, Inc. |
|
|
|
|
|
|
|
|
|
|
30,593 |
|
|
4,700 |
|
|
|
|
|
|
Stryker Corp. |
|
|
|
|
|
|
|
|
|
|
297,322 |
|
|
1,200 |
|
|
|
|
|
|
Sunoco, Inc. |
|
|
|
|
|
|
|
|
|
|
50,232 |
|
|
3,600 |
|
|
|
|
|
|
SunTrust Bank |
|
|
|
|
|
|
|
|
|
|
108,612 |
|
|
15,500 |
|
|
|
S |
|
|
Supervalu, Inc. |
|
|
|
|
|
|
|
|
|
|
133,765 |
|
|
14,300 |
|
|
|
@ |
|
|
Symantec Corp. |
|
|
|
|
|
|
|
|
|
|
257,829 |
|
|
5,300 |
|
|
|
|
|
|
Sysco Corp. |
|
|
|
|
|
|
|
|
|
|
147,287 |
|
|
2,300 |
|
|
|
|
|
|
T. Rowe Price Group, Inc. |
|
|
|
|
|
|
|
|
|
|
154,054 |
|
|
5,208 |
|
|
|
|
|
|
Target Corp. |
|
|
|
|
|
|
|
|
|
|
273,680 |
|
|
2,300 |
|
|
|
|
|
|
TECO Energy, Inc. |
|
|
|
|
|
|
|
|
|
|
41,653 |
|
|
20,300 |
|
|
|
S |
|
|
Tellabs, Inc. |
|
|
|
|
|
|
|
|
|
|
109,417 |
|
|
19,800 |
|
|
|
@, S |
|
|
Tenet Healthcare Corp. |
|
|
|
|
|
|
|
|
|
|
142,164 |
|
|
4,293 |
|
|
|
@ |
|
|
Teradata Corp. |
|
|
|
|
|
|
|
|
|
|
205,291 |
|
|
6,138 |
|
|
|
@, S |
|
|
Teradyne, Inc. |
|
|
|
|
|
|
|
|
|
|
114,351 |
|
|
8,100 |
|
|
|
@ |
|
|
Tesoro Corp. |
|
|
|
|
|
|
|
|
|
|
192,618 |
|
|
7,600 |
|
|
|
|
|
|
Texas Instruments, Inc. |
|
|
|
|
|
|
|
|
|
|
270,636 |
|
|
2,103 |
|
|
|
|
|
|
Textron, Inc. |
|
|
|
|
|
|
|
|
|
|
56,970 |
|
|
2,986 |
|
|
|
@ |
|
|
Thermo Fisher Scientific, Inc. |
|
|
|
|
|
|
|
|
|
|
166,679 |
|
|
700 |
|
|
|
|
|
|
Tiffany & Co. |
|
|
|
|
|
|
|
|
|
|
43,085 |
|
|
4,500 |
|
|
|
|
|
|
Time Warner Cable, Inc. |
|
|
|
|
|
|
|
|
|
|
324,810 |
|
|
7,900 |
|
|
|
|
|
|
Time Warner, Inc. |
|
|
|
|
|
|
|
|
|
|
301,780 |
|
|
5,500 |
|
|
|
@ |
|
|
Titanium Metals Corp. |
|
|
|
|
|
|
|
|
|
|
104,445 |
|
|
5,700 |
|
|
|
|
|
|
TJX Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
284,259 |
|
|
2,500 |
|
|
|
|
|
|
Torchmark Corp. |
|
|
|
|
|
|
|
|
|
|
163,125 |
|
|
7,200 |
|
|
|
|
|
|
Total System Services, Inc. |
|
|
|
|
|
|
|
|
|
|
127,800 |
|
|
4,776 |
|
|
|
|
|
|
Travelers Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
286,226 |
|
|
8,000 |
|
|
|
|
|
|
Tyson Foods, Inc. |
|
|
|
|
|
|
|
|
|
|
149,040 |
|
|
7,300 |
|
|
|
|
|
|
Union Pacific Corp. |
|
|
|
|
|
|
|
|
|
|
696,493 |
|
|
6,160 |
|
|
|
|
|
|
United Parcel Service, Inc. Class B |
|
|
|
|
|
|
|
|
|
|
454,608 |
|
|
13,233 |
|
|
|
|
|
|
United Technologies Corp. |
|
|
|
|
|
|
|
|
|
|
1,105,485 |
|
|
9,795 |
|
|
|
|
|
|
UnitedHealth Group, Inc. |
|
|
|
|
|
|
|
|
|
|
417,071 |
|
|
3,098 |
|
|
|
|
|
|
UnumProvident Corp. |
|
|
|
|
|
|
|
|
|
|
82,190 |
|
|
3,300 |
|
|
|
@ |
|
|
Urban Outfitters, Inc. |
|
|
|
|
|
|
|
|
|
|
126,654 |
|
|
19,320 |
|
|
|
|
|
|
US Bancorp. |
|
|
|
|
|
|
|
|
|
|
535,744 |
|
29
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
4,900 |
|
|
|
|
|
|
Valero Energy Corp. |
|
|
|
|
|
|
|
|
|
|
138,082 |
|
|
1,700 |
|
|
|
@ |
|
|
Varian Medical Systems, Inc. |
|
|
|
|
|
|
|
|
|
|
117,776 |
|
|
1,300 |
|
|
|
@ |
|
|
VeriSign, Inc. |
|
|
|
|
|
|
|
|
|
|
45,877 |
|
|
40,855 |
|
|
|
S |
|
|
Verizon Communications, Inc. |
|
|
|
|
|
|
|
|
|
|
1,508,367 |
|
|
1,133 |
|
|
|
|
|
|
VF Corp. |
|
|
|
|
|
|
|
|
|
|
108,394 |
|
|
2,743 |
|
|
|
|
|
|
Viacom Class B |
|
|
|
|
|
|
|
|
|
|
122,502 |
|
|
4,200 |
|
|
|
|
|
|
Visa, Inc. |
|
|
|
|
|
|
|
|
|
|
306,810 |
|
|
1,700 |
|
|
|
|
|
|
Vulcan Materials Co. |
|
|
|
|
|
|
|
|
|
|
77,945 |
|
|
9,700 |
|
|
|
|
|
|
Walgreen Co. |
|
|
|
|
|
|
|
|
|
|
420,398 |
|
|
23,067 |
|
|
|
|
|
|
Wal-Mart Stores, Inc. |
|
|
|
|
|
|
|
|
|
|
1,199,023 |
|
|
15,300 |
|
|
|
|
|
|
Walt Disney Co. |
|
|
|
|
|
|
|
|
|
|
669,222 |
|
|
1,755 |
|
|
|
|
|
|
Waste Management, Inc. |
|
|
|
|
|
|
|
|
|
|
65,040 |
|
|
2,267 |
|
|
|
@ |
|
|
Waters Corp. |
|
|
|
|
|
|
|
|
|
|
188,274 |
|
|
3,200 |
|
|
|
@ |
|
|
Watson Pharmaceuticals, Inc. |
|
|
|
|
|
|
|
|
|
|
179,168 |
|
|
3,100 |
|
|
|
@ |
|
|
WellPoint, Inc. |
|
|
|
|
|
|
|
|
|
|
206,057 |
|
|
57,971 |
|
|
|
|
|
|
Wells Fargo & Co. |
|
|
|
|
|
|
|
|
|
|
1,870,144 |
|
|
1,200 |
|
|
|
@ |
|
|
Western Digital Corp. |
|
|
|
|
|
|
|
|
|
|
36,696 |
|
|
4,500 |
|
|
|
|
|
|
Western Union Co. |
|
|
|
|
|
|
|
|
|
|
98,955 |
|
|
2,500 |
|
|
|
|
|
|
Whirlpool Corp. |
|
|
|
|
|
|
|
|
|
|
206,250 |
|
|
1,500 |
|
|
|
|
|
|
Whole Foods Market, Inc. |
|
|
|
|
|
|
|
|
|
|
87,840 |
|
|
5,400 |
|
|
|
|
|
|
Williams Cos., Inc. |
|
|
|
|
|
|
|
|
|
|
163,944 |
|
|
2,030 |
|
|
|
S |
|
|
Windstream Corp. |
|
|
|
|
|
|
|
|
|
|
25,456 |
|
|
1,648 |
|
|
|
|
|
|
Wisconsin Energy Corp. |
|
|
|
|
|
|
|
|
|
|
97,562 |
|
|
500 |
|
|
|
|
|
|
WW Grainger, Inc. |
|
|
|
|
|
|
|
|
|
|
66,605 |
|
|
1,400 |
|
|
|
|
|
|
Wyndham Worldwide Corp. |
|
|
|
|
|
|
|
|
|
|
43,792 |
|
|
162 |
|
|
|
|
|
|
Wynn Resorts Ltd. |
|
|
|
|
|
|
|
|
|
|
19,915 |
|
|
12,100 |
|
|
|
|
|
|
Xcel Energy, Inc. |
|
|
|
|
|
|
|
|
|
|
289,674 |
|
|
7,300 |
|
|
|
S |
|
|
Xerox Corp. |
|
|
|
|
|
|
|
|
|
|
78,475 |
|
|
1,000 |
|
|
|
|
|
|
Xilinx, Inc. |
|
|
|
|
|
|
|
|
|
|
33,250 |
|
|
19,000 |
|
|
|
@ |
|
|
Yahoo!, Inc. |
|
|
|
|
|
|
|
|
|
|
311,600 |
|
|
4,300 |
|
|
|
|
|
|
Yum! Brands, Inc. |
|
|
|
|
|
|
|
|
|
|
216,419 |
|
|
4,300 |
|
|
|
@ |
|
|
Zimmer Holdings, Inc. |
|
|
|
|
|
|
|
|
|
|
268,062 |
|
|
700 |
|
|
|
|
|
|
Zions Bancorp. |
|
|
|
|
|
|
|
|
|
|
16,352 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
142,186,393 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Common Stock
( Cost $223,781,253 ) |
|
|
|
|
|
|
|
|
|
|
248,230,041 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
REAL ESTATE INVESTMENT TRUSTS: |
|
|
1.4 |
% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Australia: |
|
|
|
|
|
|
0.2 |
% |
|
|
|
|
|
68,654 |
|
|
|
|
|
|
CFS Retail Property Trust |
|
|
|
|
|
|
|
|
|
|
131,891 |
|
|
4,274 |
|
|
|
|
|
|
Dexus Property Group |
|
|
|
|
|
|
|
|
|
|
3,739 |
|
|
5,767 |
|
|
|
|
|
|
Goodman Group |
|
|
|
|
|
|
|
|
|
|
4,133 |
|
|
1,612 |
|
|
|
|
|
|
GPT Group |
|
|
|
|
|
|
|
|
|
|
5,120 |
|
|
3,230 |
|
|
|
|
|
|
Mirvac Group |
|
|
|
|
|
|
|
|
|
|
4,296 |
|
|
2,170 |
|
|
|
|
|
|
Stockland |
|
|
|
|
|
|
|
|
|
|
8,444 |
|
|
28,011 |
|
|
|
|
|
|
Westfield Group |
|
|
|
|
|
|
|
|
|
|
279,275 |
|
|
11,908 |
|
|
|
|
|
|
Westfield Retail Trust |
|
|
|
|
|
|
|
|
|
|
32,372 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
469,270 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
France: |
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
12 |
|
|
|
|
|
|
Klepierre |
|
|
|
|
|
|
|
|
|
|
469 |
|
|
280 |
|
|
|
|
|
|
Unibail |
|
|
|
|
|
|
|
|
|
|
56,341 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
56,810 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Hong Kong: |
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
44,500 |
|
|
|
|
|
|
Link Real Estate Investment Trust |
|
|
|
|
|
|
|
|
|
|
137,457 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
137,457 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Japan: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
33 |
|
|
|
|
|
|
Japan Prime Realty Investment Corp. |
|
|
|
|
|
|
|
|
|
|
91,980 |
|
|
60 |
|
|
|
|
|
|
Japan Retail Fund Investment Corp. |
|
|
|
|
|
|
|
|
|
|
103,271 |
|
|
7 |
|
|
|
|
|
|
Nomura Real Estate Office Fund, Inc. |
|
|
|
|
|
|
|
|
|
|
47,545 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
242,796 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Singapore: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
73,550 |
|
|
|
|
|
|
Ascendas Real Estate Investment Trust |
|
|
|
|
|
|
|
|
|
|
116,159 |
|
|
62,000 |
|
|
|
|
|
|
CapitaMall Trust |
|
|
|
|
|
|
|
|
|
|
88,532 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
204,691 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
United Kingdom: |
|
|
|
|
|
|
0.1 |
% |
|
|
|
|
|
16,825 |
|
|
|
|
|
|
British Land Co. PLC |
|
|
|
|
|
|
|
|
|
|
159,629 |
|
|
362 |
|
|
|
|
|
|
Capital Shopping Centres Group PLC |
|
|
|
|
|
|
|
|
|
|
2,327 |
|
|
431 |
|
|
|
|
|
|
Hammerson PLC |
|
|
|
|
|
|
|
|
|
|
3,266 |
|
|
6,571 |
|
|
|
|
|
|
Land Securities Group PLC |
|
|
|
|
|
|
|
|
|
|
81,895 |
|
|
421 |
|
|
|
|
|
|
Segro PLC |
|
|
|
|
|
|
|
|
|
|
2,204 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
249,321 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
United States: |
|
|
|
|
|
|
0.9 |
% |
|
|
|
|
|
4,700 |
|
|
|
|
|
|
Apartment Investment & Management Co. |
|
|
|
|
|
|
|
|
|
|
120,555 |
|
|
1,598 |
|
|
|
|
|
|
AvalonBay Communities, Inc. |
|
|
|
|
|
|
|
|
|
|
193,406 |
|
|
841 |
|
|
|
|
|
|
Boston Properties, Inc. |
|
|
|
|
|
|
|
|
|
|
80,669 |
|
|
5,300 |
|
|
|
|
|
|
Equity Residential |
|
|
|
|
|
|
|
|
|
|
292,083 |
|
|
5,166 |
|
|
|
|
|
|
HCP, Inc. |
|
|
|
|
|
|
|
|
|
|
196,308 |
|
|
1,457 |
|
|
|
|
|
|
Health Care Real Estate Investment Trust, Inc. |
|
|
|
|
|
|
|
|
|
|
76,085 |
|
|
10,900 |
|
|
|
|
|
|
Host Hotels & Resorts, Inc. |
|
|
|
|
|
|
|
|
|
|
200,560 |
|
30
PORTFOLIO OF INVESTMENTS
ING Global Advantage and Premium Opportunity Fund
as
of February 28, 2011
(continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Shares |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Value |
|
|
|
9,300 |
|
|
|
|
|
|
Kimco Realty Corp. |
|
|
|
|
|
|
|
|
|
|
180,234 |
|
|
11,324 |
|
|
|
|
|
|
Prologis |
|
|
|
|
|
|
|
|
|
|
184,128 |
|
|
2,600 |
|
|
|
|
|
|
Public Storage, Inc. |
|
|
|
|
|
|
|
|
|
|
291,850 |
|
|
1,362 |
|
|
|
|
|
|
Simon Property Group, Inc. |
|
|
|
|
|
|
|
|
|
|
149,874 |
|
|
3,737 |
|
|
|
|
|
|
Ventas, Inc. |
|
|
|
|
|
|
|
|
|
|
207,105 |
|
|
547 |
|
|
|
|
|
|
Vornado Realty Trust |
|
|
|
|
|
|
|
|
|
|
51,052 |
|
|
2,900 |
|
|
|
|
|
|
Weyerhaeuser Co. |
|
|
|
|
|
|
|
|
|
|
70,789 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
2,294,698 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Real Estate Investment Trusts
( Cost $3,166,770 ) |
|
|
|
|
|
|
|
|
|
|
3,655,043 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
PREFERRED STOCK: |
|
|
0.4 |
% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Germany: |
|
|
|
|
|
|
0.4 |
% |
|
|
|
|
|
44 |
|
|
|
|
|
|
Porsche AG |
|
|
|
|
|
|
|
|
|
|
3,505 |
|
|
10,411 |
|
|
|
|
|
|
ProSieben SAT.1 Media AG |
|
|
|
|
|
|
|
|
|
|
338,314 |
|
|
1,301 |
|
|
|
|
|
|
RWE AG |
|
|
|
|
|
|
|
|
|
|
83,872 |
|
|
2,952 |
|
|
|
|
|
|
Volkswagen AG |
|
|
|
|
|
|
|
|
|
|
502,004 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Preferred Stock
( Cost $916,465 ) |
|
|
|
|
|
|
|
|
|
|
927,695 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
RIGHTS: |
|
|
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Hong Kong: |
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
2,700 |
|
|
|
|
|
|
Wharf Holdings Ltd. |
|
|
|
|
|
|
|
|
|
|
5,044 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
5,044 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Sweden: |
|
|
|
|
|
|
0.0 |
% |
|
|
|
|
|
279 |
|
|
|
|
|
|
TeliaSonera AB |
|
|
|
|
|
|
|
|
|
|
14 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
14 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Rights
( Cost $- ) |
|
|
|
|
|
|
|
|
|
|
5,058 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Long-Term Investments
( Cost $227,864,488 ) |
|
|
|
|
|
|
|
|
|
|
252,817,837 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
SHORT-TERM INVESTMENTS: |
|
|
1.0 |
% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Mutual Funds: |
|
|
|
|
|
|
1.0 |
% |
|
|
|
|
|
2,383,000 |
|
|
|
|
|
|
Blackrock Liquidity Funds TempFund
Portfolio Class I |
|
|
|
|
|
|
|
|
|
|
2,383,000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Short-Term Investments
( Cost $2,383,000 ) |
|
|
|
|
|
|
|
|
|
|
2,383,000 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Investments in Securities
( Cost $230,247,488 ) * |
|
|
101.5 |
% |
|
|
|
|
|
$ |
255,200,837 |
|
|
|
|
|
|
|
|
|
Other Assets and Liabilities Net |
|
|
(1.5 |
) |
|
|
|
|
|
|
(3,655,360 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Net Assets |
|
|
100.0 |
% |
|
|
|
|
|
$ |
251,545,477 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
@ |
|
|
Non-income producing security |
|
|
|
|
ADR |
|
American Depositary Receipt |
|
|
|
|
S |
|
|
All or a portion of this security has been identified by the Fund to cover future
collateral requirements for applicable futures, options, swaps, foreign currency
contracts and/or when-issued or delayed-delivery securities. |
|
|
|
|
|
|
|
|
|
* |
|
|
Cost for federal income tax purposes is $233,155,845. |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Net unrealized appreciation consists of: |
|
|
|
|
|
|
|
|
|
Gross Unrealized Appreciation |
|
$ |
28,234,761 |
|
|
|
|
|
Gross Unrealized Depreciation |
|
|
(6,189,769 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
|
Net Unrealized Appreciation |
|
$ |
22,044,992 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Percentage of |
Industry |
|
Net Assets |
|
Consumer Discretionary |
|
|
9.9 |
% |
Consumer Staples |
|
|
9.5 |
|
Energy |
|
|
12.2 |
|
Financials |
|
|
19.6 |
|
Health Care |
|
|
9.8 |
|
Industrials |
|
|
12.4 |
|
Information Technology |
|
|
11.8 |
|
Materials |
|
|
6.0 |
|
Telecommunication Services |
|
|
4.6 |
|
Utilities |
|
|
4.7 |
|
Short-Term Investments |
|
|
1.0 |
|
Other Assets and Liabilities Net |
|
|
(1.5 |
) |
|
|
|
|
|
Net Assets |
|
|
100.0 |
% |
|
|
|
|
|
See Accompanying Notes to Financial Statements
Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed End Management Investment companies.
31
PROXY VOTING PROCEDURES AND GUIDELINES
Effective Date: July 10, 2003
Revision Date: March 3, 2011
I. INTRODUCTION
The following are the Proxy Voting Procedures and Guidelines (the Procedures and Guidelines) of
the ING Funds set forth on Exhibit 1 attached hereto and each portfolio or series thereof, except
for any Sub-Adviser-Voted Series identified on Exhibit 1 and further described in Section III
below (each non-Sub-Adviser-Voted Series hereinafter referred to as a Fund and collectively, the
Funds). The purpose of these Procedures and Guidelines is to set forth the process by which each
Fund subject to these Procedures and Guidelines will vote proxies related to the equity assets in
its investment portfolio (the portfolio securities). The term proxies as used herein shall
include votes in connection with annual and special meetings of equity stockholders but not those
regarding bankruptcy matters and/or related plans of reorganization. The Procedures and Guidelines
have been approved by the Funds Boards of Trustees/Directors1 (each a Board and
collectively, the Boards), including a majority of the independent Trustees/Directors2
of the Board. These Procedures and Guidelines may be amended only by the Board. The Board shall
review these Procedures and Guidelines at its discretion, and make any revisions thereto as deemed
appropriate by the Board.
II. COMPLIANCE COMMITTEE
The Boards hereby delegate to the Compliance Committee of each Board (each a Committee and
collectively, the Committees) the authority and responsibility to oversee the implementation of
these Procedures and Guidelines, and where applicable, to make determinations on behalf of the
Board with respect to the voting of proxies on behalf of each Fund. Furthermore, the Boards hereby
delegate to each Committee the authority to review and approve material changes to proxy voting
procedures of any Funds investment adviser (the Adviser). The Proxy Voting Procedures of the
Adviser (the Adviser Procedures) are attached hereto as Exhibit 2. Any determination regarding
the voting of proxies of each Fund
|
|
|
1 |
|
Reference in these Procedures to one or more
Funds shall, as applicable, mean those Funds that are under the jurisdiction of
the particular Board or Compliance Committee at issue. No provision in these
Procedures is intended to impose any duty upon the particular Board or
Compliance Committee with respect to any other Fund. |
|
2 |
|
The independent Trustees/Directors are those
Board members who are not interested persons of the Funds within the meaning
of Section 2(a)(19) of the Investment Company Act of 1940. |
Effective Date: 07/10/03
Revision Date: 03/03/11
that is made by a Committee, or any member thereof, as permitted herein, shall be deemed to be a
good faith determination regarding the voting of proxies by the full Board. Each Committee may
rely on the Adviser through the Agent, Proxy Coordinator and/or Proxy Group (as such terms are
defined for purposes of the Adviser Procedures) to deal in the first instance with the application
of these Procedures and Guidelines. Each Committee shall conduct itself in accordance with its
charter.
III. DELEGATION OF VOTING AUTHORITY
Except as otherwise provided for herein, the Board hereby delegates to the Adviser to each Fund the
authority and responsibility to vote all proxies with respect to all portfolio securities of the
Fund in accordance with then current proxy voting procedures and guidelines that have been approved
by the Board. The Board may revoke such delegation with respect to any proxy or proposal, and
assume the responsibility of voting any Fund proxy or proxies as it deems appropriate.
Non-material amendments to the Procedures and Guidelines may be approved for immediate
implementation by the President or Chief Financial Officer of a Fund, subject to ratification at
the next regularly scheduled meeting of the Compliance Committee.
A Board may elect to delegate the voting of proxies to the Sub-Adviser of a portfolio or series of
the ING Funds. In so doing, the Board shall also approve the Sub-Advisers proxy policies for
implementation on behalf of such portfolio or series (a Sub-Adviser-Voted Series).
Sub-Adviser-Voted Series shall not be covered under these Procedures and Guidelines but rather
shall be covered by such Sub-Advisers proxy policies, provided that the Board, including a
majority of the independent Trustees/Directors1, has approved them on behalf of such
Sub-Adviser-Voted Series, and ratifies any subsequent changes at the next regularly scheduled
meeting of the Compliance Committee and the Board.
When a Fund participates in the lending of its securities and the securities are on loan at record
date, proxies related to such securities will not be forwarded to the Adviser by the Funds
custodian and therefore will not be voted. However, the Adviser shall use best efforts to recall
or restrict specific securities from loan for the purpose of facilitating a material vote as
described in the Adviser Procedures.
Funds that are funds-of-funds will echo vote their interests in underlying mutual funds, which
may include ING Funds (or portfolios or series thereof) other than those set forth on Exhibit 1
attached hereto. This means that, if the fund-of-funds must vote on a proposal with respect to an
underlying investment company, the fund-of-funds will vote its interest in that underlying fund in
the same proportion all other shareholders in the investment company voted their interests.
A fund that is a feeder fund in a master-feeder structure does not echo vote. Rather, it passes
votes requested by the underlying master fund to its shareholders. This means that, if the feeder
|
|
|
1 |
|
The independent Trustees/Directors are those
Board members who are not interested persons of the Funds within the meaning
of Section 2(a)(19) of the Investment Company Act of 1940. |
2
fund is solicited by the master fund, it will request instructions from its own shareholders,
either directly or, in the case of an insurance-dedicated Fund, through an insurance product or
retirement plan, as to the manner in which to vote its interest in an underlying master fund.
When a Fund is a feeder in a master-feeder structure, proxies for the portfolio securities owned by
the master fund will be voted pursuant to the master funds proxy voting policies and procedures.
As such, and except as otherwise noted herein with respect to vote reporting requirements, feeder
Funds shall not be subject to these Procedures and Guidelines.
IV. APPROVAL AND REVIEW OF PROCEDURES
Each Funds Adviser has adopted proxy voting procedures in connection with the voting of portfolio
securities for the Funds as attached hereto in Exhibit 2. The Board hereby approves such
procedures. All material changes to the Adviser Procedures must be approved by the Board or the
Compliance Committee prior to implementation; however, the President or Chief Financial Officer of
a Fund may make such non-material changes as they deem appropriate, subject to ratification by the
Board or the Compliance Committee at its next regularly scheduled meeting.
V. VOTING PROCEDURES AND GUIDELINES
The Guidelines that are set forth in Exhibit 3 hereto specify the manner in which the Funds
generally will vote with respect to the proposals discussed therein.
Unless otherwise noted, the defined terms used hereafter shall have the same meaning as defined in
the Adviser Procedures
A. Routine Matters
The Agent shall be instructed to submit a vote in accordance with the Guidelines where such
Guidelines provide a clear policy (e.g., For, Against, Withhold or Abstain) on a
proposal. However, the Agent shall be directed to refer any proxy proposal to the Proxy
Coordinator for instructions as if it were a matter requiring case-by-case consideration
under circumstances where the application of the Guidelines is unclear, it appears to
involve unusual or controversial issues, or an Investment Professional (as such term is
defined for purposes of the Adviser Procedures) recommends a vote contrary to the
Guidelines.
B. Matters Requiring Case-by-Case Consideration
The Agent shall be directed to refer proxy proposals accompanied by its written analysis and
voting recommendation to the Proxy Coordinator where the Guidelines have noted
case-by-case consideration.
3
Upon receipt of a referral from the Agent, the Proxy Coordinator may solicit additional
research from the Agent, Investment Professional(s), as well as from any other source or
service.
Except in cases in which the Proxy Group has previously provided the Proxy Coordinator with
standing instructions to vote in accordance with the Agents recommendation, the Proxy
Coordinator will forward the Agents analysis and recommendation and/or any research
obtained from the Investment Professional(s), the Agent or any other source to the Proxy
Group. The Proxy Group may consult with the Agent and/or Investment Professional(s), as it
deems necessary.
The Proxy Coordinator shall use best efforts to convene the Proxy Group with respect to all
matters requiring its consideration. In the event quorum requirements cannot be timely met
in connection with a voting deadline, it shall be the policy of the Funds to vote in
accordance with the Agents recommendation, unless the Agents recommendation is deemed to
be conflicted as provided for under the Adviser Procedures, in which case no action shall be
taken on such matter (i.e., a Non-Vote).
|
1. |
|
Within-Guidelines Votes: Votes in Accordance with a Funds
Guidelines and/or, where applicable, Agent Recommendation |
In the event the Proxy Group, and where applicable, any Investment Professional
participating in the voting process, recommend a vote Within Guidelines, the Proxy
Group will instruct the Agent, through the Proxy Coordinator, to vote in this
manner. Except as provided for herein, no Conflicts Report (as such term is defined
for purposes of the Adviser Procedures) is required in connection with
Within-Guidelines Votes.
|
2. |
|
Non-Votes: Votes in Which No Action is Taken |
The Proxy Group may recommend that a Fund refrain from voting under circumstances
including, but not limited to, the following: (1) if the economic effect on
shareholders interests or the value of the portfolio holding is indeterminable or
insignificant, e.g., proxies in connection with fractional shares, securities no
longer held in the portfolio of an ING Fund or proxies being considered on behalf of
a Fund that is no longer in existence; or (2) if the cost of voting a proxy
outweighs the benefits, e.g., certain international proxies, particularly in cases
in which share blocking practices may impose trading restrictions on the relevant
portfolio security. In such instances, the Proxy Group may instruct the Agent,
through the Proxy Coordinator, not to vote such proxy. The Proxy Group may provide
the Proxy Coordinator with standing instructions on parameters that would dictate a
Non-Vote without the Proxy Groups review of a specific proxy.
4
Reasonable efforts shall be made to secure and vote all other proxies for the Funds,
but, particularly in markets in which shareholders rights are limited, Non-Votes
may also occur in connection with a Funds related inability to timely
access ballots or other proxy information in connection with its portfolio
securities.
Non-Votes may also result in certain cases in which the Agents recommendation has
been deemed to be conflicted, as described in V.B. above and V.B.4. below.
|
3. |
|
Out-of-Guidelines Votes: Votes Contrary to Procedures and
Guidelines, or Agent Recommendation, where applicable, Where No Recommendation
is Provided by Agent, or Where Agents Recommendation is Conflicted |
If the Proxy Group recommends that a Fund vote contrary to the Guidelines, or the
recommendation of the Agent, where applicable, if the Agent has made no
recommendation on a matter and the Procedures and Guidelines are silent, or the
Agents recommendation on a matter is deemed to be conflicted as provided for under
the Adviser Procedures, the Proxy Coordinator will then request that all members of
the Proxy Group, including any members who abstained from voting on the matter or
were not in attendance at the meeting at which the relevant proxy is being
considered, and each Investment Professional participating in the voting process
complete a Conflicts Report (as such term is defined for purposes of the Adviser
Procedures). As provided for in the Adviser Procedures, the Proxy Coordinator shall
be responsible for identifying to Counsel potential conflicts of interest with
respect to the Agent.
If Counsel determines that a conflict of interest appears to exist with respect to
the Agent, any member of the Proxy Group or the participating Investment
Professional(s), the Proxy Coordinator will then contact the Compliance Committee(s)
and forward to such Committee(s) all information relevant to their review, including
the following materials or a summary thereof: the applicable Procedures and
Guidelines, the recommendation of the Agent, where applicable, the recommendation of
the Investment Professional(s), where applicable, any resources used by the Proxy
Group in arriving at its recommendation, the Conflicts Report and any other written
materials establishing whether a conflict of interest exists, and findings of
Counsel (as such term is defined for purposes of the Adviser Procedures). Upon
Counsels finding that a conflict of interest exists with respect to one or more
members of the Proxy Group or the Advisers generally, the remaining members of the
Proxy Group shall not be required to complete a Conflicts Report in connection with
the proxy.
If Counsel determines that there does not appear to be a conflict of interest with
respect to the Agent, any member of the Proxy Group or the participating Investment
Professional(s), the Proxy Coordinator will instruct the Agent to vote the proxy as
recommended by the Proxy Group.
5
|
4. |
|
Referrals to a Funds Compliance Committee |
A Funds Compliance Committee may consider all recommendations, analysis, research
and Conflicts Reports provided to it by the Agent, Proxy Group and/or Investment
Professional(s), and any other written materials used to establish whether a
conflict of interest exists, in determining how to vote the proxies referred to the
Committee. The Committee will instruct the Agent through the Proxy Coordinator how
to vote such referred proposals.
The Proxy Coordinator shall use best efforts to timely refer matters to a Funds
Committee for its consideration. In the event any such matter cannot be timely
referred to or considered by the Committee, it shall be the policy of the Funds to
vote in accordance with the Agents recommendation, unless the Agents
recommendation is conflicted on a matter, in which case no action shall be taken on
such matter (i.e., a Non-Vote).
The Proxy Coordinator will maintain a record of all proxy questions that have been
referred to a Funds Committee, as well as all applicable recommendations, analysis,
research and Conflicts Reports.
VI. CONFLICTS OF INTEREST
In all cases in which a vote has not been clearly determined in advance by the Procedures and
Guidelines or for which the Proxy Group recommends an Out-of-Guidelines Vote, and Counsel has
determined that a conflict of interest appears to exist with respect to the Agent, any member of
the Proxy Group, or any Investment Professional participating in the voting process, the proposal
shall be referred to the Funds Committee for determination so that the Adviser shall have no
opportunity to vote a Funds proxy in a situation in which it or the Agent may be deemed to have a
conflict of interest. In the event a member of a Funds Committee believes he/she has a conflict
of interest that would preclude him/her from making a voting determination in the best interests of
the beneficial owners of the applicable Fund, such Committee member shall so advise the Proxy
Coordinator and recuse himself/herself with respect to determinations regarding the relevant proxy.
VII. REPORTING AND RECORD RETENTION
Annually in August, each Fund will post its proxy voting record, or a link thereto, for the prior
one-year period ending on June 30th on the ING Funds website. The proxy voting record
for each Fund will also be available on Form N-PX in the EDGAR database on the SECs website. For
any Fund that is a feeder in a master/feeder structure, no proxy voting record related to the
portfolio securities owned by the master fund will be posted on the ING Funds website or included
in the Funds Form N-PX; however, a cross-reference to the master funds proxy voting record as
filed in the SECs EDGAR database will be included in the Funds Form N-PX and posted on the ING
Funds website. If any feeder fund was solicited for vote by its underlying
6
master fund during the
reporting period, a record of the votes cast by means of the pass-through process described in
Section III above will be included on the ING Funds website and in the Funds Form N-PX.
7
EXHIBIT 1
to the
ING Funds
Proxy Voting Procedures
ING ASIA PACIFIC HIGH DIVIDEND EQUITY INCOME FUND
ING EMERGING MARKETS HIGH DIVIDEND EQUITY FUND
ING EMERGING MARKETS LOCAL BOND FUND
ING EQUITY TRUST
ING FUNDS TRUST
ING GLOBAL ADVANTAGE AND PREMIUM OPPORTUNITY FUND
ING GLOBAL EQUITY DIVIDEND AND PREMIUM OPPORTUNITY FUND
ING INFRASTRUCTURE, INDUSTRIALS AND MATERIALS FUND
ING INTERNATIONAL HIGH DIVIDEND EQUITY INCOME FUND
ING INVESTORS TRUST1
ING MAYFLOWER TRUST
ING MUTUAL FUNDS
ING PARTNERS, INC.
ING PRIME RATE TRUST
ING RISK MANAGED NATURAL RESOURCES FUND
ING SENIOR INCOME FUND
ING SEPARATE PORTFOLIOS TRUST
ING VARIABLE INSURANCE TRUST
ING VARIABLE PRODUCTS TRUST
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1 |
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Sub-Adviser-Voted Series: ING Franklin Mutual
Shares Portfolio |
EXHIBIT 2
to the
ING Funds
Proxy Voting Procedures
ING INVESTMENTS, LLC,
ING INVESTMENT MANAGEMENT CO.
AND
DIRECTED SERVICES LLC
I. INTRODUCTION
ING Investments, LLC, ING Investment Management Co. and Directed Services LLC (each an Adviser
and collectively, the Advisers) are the investment advisers for the registered investment
companies and each series or portfolio thereof (each a Fund and collectively, the Funds)
comprising the ING family of funds. As such, the Advisers have been delegated the authority to
vote proxies with respect to securities for certain Funds over which they have day-to-day portfolio
management responsibility.
The Advisers will abide by the proxy voting guidelines adopted by a Funds respective Board of
Directors or Trustees (each a Board and collectively, the Boards) with regard to the voting of
proxies unless otherwise provided in the proxy voting procedures adopted by a Funds Board.
In voting proxies, the Advisers are guided by general fiduciary principles. Each must act
prudently, solely in the interest of the beneficial owners of the Funds it manages. The Advisers
will not subordinate the interest of beneficial owners to unrelated objectives. Each Adviser will
vote proxies in the manner that it believes will do the most to maximize shareholder value.
The following are the Proxy Voting Procedures of ING Investments, LLC, ING Investment Management
Co. and Directed Services LLC (the Adviser Procedures) with respect to the voting of proxies on
behalf of their client Funds as approved by the respective Board of each Fund.
Unless otherwise noted, best efforts shall be used to vote proxies in all instances.
II. ROLES AND RESPONSIBILITIES
A. Proxy Coordinator
The Proxy Coordinator identified in Appendix 1 will assist in the coordination of the voting
of each Funds proxies in accordance with the ING Funds Proxy Voting Procedures and
Guidelines (the Procedures or Guidelines and collectively the Procedures and
Guidelines). The Proxy Coordinator is authorized to direct the Agent to vote a Funds
proxy in accordance with the Procedures and Guidelines unless the Proxy Coordinator receives
a recommendation from an Investment Professional (as described below) to vote contrary to
the Guidelines. In such event, and in connection with proxy proposals requiring
case-by-case consideration (except in cases in which the Proxy Group has previously provided
the Proxy Coordinator with standing instructions to vote in accordance with the Agents
recommendation), the Proxy Coordinator will call a meeting of the Proxy Group (as described
below).
Responsibilities assigned herein to the Proxy Coordinator, or activities in support thereof,
may be performed by such members of the Proxy Group or employees of the Advisers affiliates
as are deemed appropriate by the Proxy Group.
Unless specified otherwise, information provided to the Proxy Coordinator in connection with
duties of the parties described herein shall be deemed delivered to the Advisers.
B. Agent
An independent proxy voting service (the Agent), as approved by the Board of each Fund,
shall be engaged to assist in the voting of Fund proxies for publicly traded securities
through the provision of vote analysis, implementation, recordkeeping and disclosure
services. The Agent is Institutional Shareholder Services Inc., a subsidiary of MSCI Inc.
The Agent is responsible for coordinating with the Funds custodians to ensure that all
proxy materials received by the custodians relating to the portfolio securities are
processed in a timely fashion. To the extent applicable, the Agent is required to vote
and/or refer all proxies in accordance with these Adviser Procedures. The Agent will retain
a record of all proxy votes handled by the Agent. Such record must reflect all the
information required to be disclosed in a Funds Form N-PX pursuant to Rule 30b1-4 under the
Investment Company Act. In addition, the Agent is responsible for maintaining copies of all
proxy statements received by issuers and to promptly provide such materials to the Adviser
upon request.
The Agent shall be instructed to vote all proxies in accordance with a Funds Guidelines,
except as otherwise instructed through the Proxy Coordinator by the Advisers Proxy Group or
a Funds Compliance Committee (Committee).
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The Agent shall be instructed to obtain all proxies from the Funds custodians and to review
each proxy proposal against the Guidelines. The Agent also shall be requested to call the
Proxy Coordinators attention to specific proxy proposals that although governed by the
Guidelines appear to involve unusual or controversial issues.
Subject to the oversight of the Advisers, the Agent shall establish and maintain adequate
internal controls and policies in connection with the provision of proxy voting services
voting to the Advisers, including methods to reasonably ensure that its analysis and
recommendations are not influenced by conflict of interest, and shall disclose such controls
and policies to the Advisers when and as provided for herein. Unless otherwise specified,
references herein to recommendations of the Agent shall refer to those in which no conflict
of interest has been identified.
C. Proxy Group
The Adviser shall establish a Proxy Group (the Group or Proxy Group) which shall assist
in the review of the Agents recommendations when a proxy voting issue is referred to the
Group through the Proxy Coordinator. The members of the Proxy Group, which may include
employees of the Advisers affiliates, are identified in Appendix 1, as may be amended from
time at the Advisers discretion.
A minimum of four (4) members of the Proxy Group (or three (3) if one member of the quorum
is either the Funds Chief Investment Risk Officer or Chief Financial Officer) shall
constitute a quorum for purposes of taking action at any meeting of the Group. The vote of
a simple majority of the members present and voting shall determine any matter submitted to
a vote. Tie votes shall be broken by securing the vote of members not present at the
meeting; provided, however, that the Proxy Coordinator shall ensure compliance with all
applicable voting and conflict of interest procedures and shall use best efforts to secure
votes from all or as many absent members as may reasonably be accomplished. A member of the
Proxy Group may abstain from voting on any given matter, provided that quorum is not lost
for purposes of taking action and that the abstaining member still participates in any
conflict of interest processes required in connection with the matter. The Proxy Group may
meet in person or by telephone. The Proxy Group also may take action via electronic mail in
lieu of a meeting, provided that each Group member has received a copy of any relevant
electronic mail transmissions circulated by each other participating Group member prior to
voting and provided that the Proxy Coordinator follows the directions of a majority of a
quorum (as defined above) responding via electronic mail. For all votes taken in person or
by telephone or teleconference, the vote shall be taken outside the presence of any person
other than the members of the Proxy Group and such other persons whose attendance may be
deemed appropriate by the Proxy Group from time to time in furtherance of its duties or the
day-to-day administration of the Funds. In its discretion, the Proxy Group may provide the
Proxy Coordinator with standing instructions to perform responsibilities assigned herein to
the Proxy Group, or activities in support thereof, on its behalf, provided that such
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instructions do not contravene any requirements of these Adviser Procedures or a Funds
Procedures and Guidelines.
A meeting of the Proxy Group will be held whenever (1) the Proxy Coordinator receives a
recommendation from an Investment Professional to vote a Funds proxy contrary to the
Guidelines, or the recommendation of the Agent, where applicable, (2) the Agent has made no
recommendation with respect to a vote on a proposal, or (3) a matter requires case-by-case
consideration, including those in which the Agents recommendation is deemed to be
conflicted as provided for under these Adviser Procedures, provided that, if the Proxy Group
has previously provided the Proxy Coordinator with standing instructions to vote in
accordance with the Agents recommendation and no issue of conflict must be considered, the
Proxy Coordinator may implement the instructions without calling a meeting of the Proxy
Group.
For each proposal referred to the Proxy Group, it will review (1) the relevant Procedures
and Guidelines, (2) the recommendation of the Agent, if any, (3) the recommendation of the
Investment Professional(s), if any, and (4) any other resources that any member of the Proxy
Group deems appropriate to aid in a determination of a recommendation.
If the Proxy Group recommends that a Fund vote in accordance with the Procedures and
Guidelines, or the recommendation of the Agent, where applicable, it shall instruct the
Proxy Coordinator to so advise the Agent.
If the Proxy Group recommends that a Fund vote contrary to the Guidelines, or the
recommendation of the Agent, where applicable, or if the Agents recommendation on a matter
is deemed to be conflicted, it shall follow the procedures for such voting as established by
a Funds Board.
The Proxy Coordinator shall use best efforts to convene the Proxy Group with respect to all
matters requiring its consideration. In the event quorum requirements cannot be timely met
in connection with a voting deadline, the Proxy Coordinator shall follow the procedures for
such voting as established by a Funds Board.
D. Investment Professionals
The Funds Advisers, sub-advisers and/or portfolio managers (each referred to herein as an
Investment Professional and collectively, Investment Professionals) may submit, or be
asked to submit, a recommendation to the Proxy Group regarding the voting of proxies related
to the portfolio securities over which they have day-to-day portfolio management
responsibility. The Investment Professionals may accompany their recommendation with any
other research materials that they deem appropriate or with a request that the vote be
deemed material in the context of the portfolio(s) they manage, such that lending activity
on behalf of such portfolio(s) with respect to the relevant security should be reviewed by
the Proxy Group and considered for recall and/or
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restriction. Input from the relevant sub-advisers and/or portfolio managers shall be given
primary consideration in the Proxy Groups determination of whether a given proxy vote is to
be deemed material and the associated security accordingly restricted from lending. The
determination that a vote is material in the context of a Funds portfolio shall not mean
that such vote is considered material across all Funds voting that meeting. In order to
recall or restrict shares timely for material voting purposes, the Proxy Group shall use
best efforts to consider, and when deemed appropriate, to act upon, such requests timely,
and requests to review lending activity in connection with a potentially material vote may
be initiated by any relevant Investment Professional and submitted for the Proxy Groups
consideration at any time.
III. VOTING PROCEDURES
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A. |
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In all cases, the Adviser shall follow the voting procedures as set forth in
the Procedures and Guidelines of the Fund on whose behalf the Adviser is exercising
delegated authority to vote. |
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B. |
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Routine Matters |
The Agent shall be instructed to submit a vote in accordance with the Guidelines where such
Guidelines provide a clear policy (e.g., For, Against, Withhold or Abstain) on a
proposal. However, the Agent shall be directed to refer any proxy proposal to the Proxy
Coordinator for instructions as if it were a matter requiring case-by-case consideration
under circumstances where the application of the Guidelines is unclear, it appears to
involve unusual or controversial issues, or an Investment Professional recommends a vote
contrary to the Guidelines.
C. Matters Requiring Case-by-Case Consideration
The Agent shall be directed to refer proxy proposals accompanied by its written analysis and
voting recommendation to the Proxy Coordinator where the Guidelines have noted
case-by-case consideration.
Upon receipt of a referral from the Agent, the Proxy Coordinator may solicit additional
research from the Agent, Investment Professional(s), as well as from any other source or
service.
Except in cases in which the Proxy Group has previously provided the Proxy Coordinator with
standing instructions to vote in accordance with the Agents recommendation, the Proxy
Coordinator will forward the Agents analysis and recommendation and/or any research
obtained from the Investment Professional(s), the Agent or any other source to the Proxy
Group. The Proxy Group may consult with the Agent and/or Investment Professional(s), as it
deems necessary.
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1. |
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Within-Guidelines Votes: Votes in Accordance with a Funds
Guidelines and/or, where applicable, Agent Recommendation |
In the event the Proxy Group, and where applicable, any Investment Professional
participating in the voting process, recommend a vote Within Guidelines, the Proxy
Group will instruct the Agent, through the Proxy Coordinator, to vote in this
manner. Except as provided for herein, no Conflicts Report (as such term is defined
herein) is required in connection with Within-Guidelines Votes.
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2. |
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Non-Votes: Votes in Which No Action is Taken |
The Proxy Group may recommend that a Fund refrain from voting under circumstances
including, but not limited to, the following: (1) if the economic effect on
shareholders interests or the value of the portfolio holding is indeterminable or
insignificant, e.g., proxies in connection with fractional shares, securities no
longer held in the portfolio of an ING Fund or proxies being considered on behalf of
a Fund that is no longer in existence; or (2) if the cost of voting a proxy
outweighs the benefits, e.g., certain international proxies, particularly in cases
in which share blocking practices may impose trading restrictions on the relevant
portfolio security. In such instances, the Proxy Group may instruct the Agent,
through the Proxy Coordinator, not to vote such proxy. The Proxy Group may provide
the Proxy Coordinator with standing instructions on parameters that would dictate a
Non-Vote without the Proxy Groups review of a specific proxy.
Reasonable efforts shall be made to secure and vote all other proxies for the Funds,
but, particularly in markets in which shareholders rights are limited, Non-Votes
may also occur in connection with a Funds related inability to timely access
ballots or other proxy information in connection with its portfolio securities.
Non-Votes may also result in certain cases in which the Agents recommendation has
been deemed to be conflicted, as provided for in the Funds Procedures.
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3. |
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Out-of-Guidelines Votes: Votes Contrary to Procedures and
Guidelines, or Agent Recommendation, where applicable, Where No Recommendation
is Provided by Agent, or Where Agents Recommendation is Conflicted |
If the Proxy Group recommends that a Fund vote contrary to the Guidelines, or the
recommendation of the Agent, where applicable, if the Agent has made no
recommendation on a matter and the Procedures and Guidelines are silent, or the
Agents recommendation on a matter is deemed to be conflicted as provided for under
these Adviser Procedures, the Proxy Coordinator will then implement the procedures
for handling such votes as adopted by the Funds Board.
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4. |
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The Proxy Coordinator will maintain a record of all proxy
questions that have been referred to a Funds Compliance Committee, as well as
all applicable recommendations, analysis, research and Conflicts Reports. |
IV. ASSESSMENT OF THE AGENT AND CONFLICTS OF INTEREST
In furtherance of the Advisers fiduciary duty to the Funds and their beneficial owners, the
Advisers shall establish the following:
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A. |
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Assessment of the Agent |
The Advisers shall establish that the Agent (1) is independent from the Advisers,
(2) has resources that indicate it can competently provide analysis of proxy issues
and (3) can make recommendations in an impartial manner and in the best interests of
the Funds and their beneficial owners. The Advisers shall utilize, and the Agent
shall comply with, such methods for establishing the foregoing as the Advisers may
deem reasonably appropriate and shall do so not less than annually as well as prior
to engaging the services of any new proxy service. The Agent shall also notify the
Advisers in writing within fifteen (15) calendar days of any material change to
information previously provided to an Adviser in connection with establishing the
Agents independence, competence or impartiality.
Information provided in connection with assessment of the Agent shall be forwarded
to a member of the mutual funds practice group of ING Investment Management
(Counsel) for review. Counsel shall review such information and advise the Proxy
Coordinator as to whether a material concern exists and if so, determine the most
appropriate course of action to eliminate such concern.
The Advisers shall establish and maintain procedures to identify and address
conflicts that may arise from time to time concerning the Agent. Upon the Advisers
request, which shall be not less than annually, and within fifteen (15) calendar
days of any material change to such information previously provided to an Adviser,
the Agent shall provide the Advisers with such information as the Advisers deem
reasonable and appropriate for use in determining material relationships of the
Agent that may pose a conflict of interest with respect to the Agents proxy
analysis or recommendations. The Proxy Coordinator shall forward all such
information to Counsel for review. Counsel shall review such information and
provide the Proxy Coordinator with a brief statement regarding whether or not a
material conflict of interest is present. Matters as to which a material conflict
of interest is deemed to be present shall be handled as provided in the Funds
Procedures and Guidelines.
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In connection with their participation in the voting process for portfolio
securities, each member of the Proxy Group, and each Investment Professional
participating in the voting process, must act solely in the best interests of the
beneficial owners of the applicable Fund. The members of the Proxy Group may not
subordinate the interests of the Funds beneficial owners to unrelated objectives,
including taking steps to reasonably insulate the voting process from any conflict
of interest that may exist in connection with the Agents services or utilization
thereof.
For all matters for which the Proxy Group recommends an Out-of-Guidelines Vote, or
for which a recommendation contrary to that of the Agent or the Guidelines has been
received from an Investment Professional and is to be utilized, the Proxy
Coordinator will implement the procedures for handling such votes as adopted by the
Funds Board, including completion of such Conflicts Reports as may be required
under the Funds Procedures. Completed Conflicts Reports should be provided to the
Proxy Coordinator within two (2) business days and may be submitted to the Proxy
Coordinator verbally, provided the Proxy Coordinator documents the Conflicts Report
in writing. Such Conflicts Report should describe any known conflicts of either a
business or personal nature, and set forth any contacts with respect to the referral
item with non-investment personnel in its organization or with outside parties
(except for routine communications from proxy solicitors). The Conflicts Report
should also include written confirmation that any recommendation from an Investment
Professional provided in connection with an Out-of-Guidelines Vote or under
circumstances where a conflict of interest exists was made solely on the investment
merits and without regard to any other consideration.
The Proxy Coordinator shall forward all Conflicts Reports to Counsel for review.
Counsel shall review each report and provide the Proxy Coordinator with a brief
statement regarding whether or not a material conflict of interest is present.
Matters as to which a material conflict of interest is deemed to be present shall be
handled as provided in the Funds Procedures and Guidelines.
V. REPORTING AND RECORD RETENTION
The Adviser shall maintain the records required by Rule 204-2(c)(2), as may be amended from time to
time, including the following: (1) A copy of each proxy statement received regarding a Funds
portfolio securities. Such proxy statements received from issuers are available either in the
SECs EDGAR database or are kept by the Agent and are available upon request. (2) A record of each
vote cast on behalf of a Fund. (3) A copy of any document created by the Adviser that was material
to making a decision how to vote a proxy, or that memorializes the basis for that decision. (4) A
copy of written requests for Fund proxy voting information and any written response thereto or to
any oral request for information on how the Adviser voted proxies on
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behalf of a Fund. All proxy voting materials and supporting documentation will be retained for a
minimum of six (6) years, the first two years in the Advisers office.
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APPENDIX 1
to the
Advisers Proxy Voting Procedures
Proxy Group for registered investment company clients of ING Investments, LLC, ING Investment
Management Co. and Directed Services LLC:
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Name |
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Title or Affiliation |
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Stanley D. Vyner
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Chief Investment Risk Officer and Executive
Vice President, ING Investments, LLC |
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Todd Modic
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Senior Vice President, ING Funds Services, LLC
and ING Investments, LLC; and Chief Financial
Officer of the ING Funds |
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Maria Anderson
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Vice President of Fund Compliance, ING Funds
Services, LLC |
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Karla J. Bos
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Proxy Coordinator for the ING Funds and
Assistant Vice President Proxy Voting, ING
Funds Services, LLC |
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Julius A. Drelick III, CFA
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Vice President, Platform Product Management and
Project Management, ING Funds Services, LLC |
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Harley Eisner
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Vice President of Financial Analysis, ING Funds
Services, LLC |
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Theresa K. Kelety, Esq.
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Vice President and Senior Counsel, ING Funds |
Effective as of January 1, 2010
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EXHIBIT 3
to the
ING Funds
Proxy Voting Procedures
PROXY VOTING GUIDELINES OF THE ING FUNDS
I. INTRODUCTION
The following is a statement of the Proxy Voting Guidelines (Guidelines) that have been adopted
by the respective Boards of Directors or Trustees of each Fund. Unless otherwise provided for
herein, any defined term used herein shall have the meaning assigned to it in the Funds and
Advisers Proxy Voting Procedures (the Procedures).
Proxies must be voted in the best interest of the Fund(s). The Guidelines summarize the Funds
positions on various issues of concern to investors, and give a general indication of how Fund
portfolio securities will be voted on proposals dealing with particular issues. The Guidelines are
not exhaustive and do not include all potential voting issues.
The Advisers, in exercising their delegated authority, will abide by the Guidelines as outlined
below with regard to the voting of proxies except as otherwise provided in the Procedures. In
voting proxies, the Advisers are guided by general fiduciary principles. Each must act prudently,
solely in the interest of the beneficial owners of the Funds it manages. The Advisers will not
subordinate the interest of beneficial owners to unrelated objectives. Each Adviser will vote
proxies in the manner that it believes will do the most to maximize shareholder value.
II. GUIDELINES
The following Guidelines are grouped according to the types of proposals generally presented to
shareholders of U.S. issuers: Board of Directors, Proxy Contests, Auditors, Proxy Contest
Defenses, Tender Offer Defenses, Miscellaneous, Capital Structure, Executive and Director
Compensation, State of Incorporation, Mergers and Corporate Restructurings, Mutual Fund Proxies,
and Social and Environmental Issues. An additional section addresses proposals most frequently
found in global proxies.
General Policies
These Guidelines apply to securities of publicly traded companies and to those of privately held
companies if publicly available disclosure permits such application. All matters for which such
disclosure is not available shall be considered CASE-BY-CASE.
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It shall generally be the policy of the Funds to take no action on a proxy for which no Fund holds
a position or otherwise maintains an economic interest in the relevant security at the time the
vote is to be cast.
In all cases receiving CASE-BY-CASE consideration, including cases not specifically provided for
under these Guidelines, unless otherwise provided for under these Guidelines, it shall generally be
the policy of the Funds to vote in accordance with the recommendation provided by the Funds Agent,
Institutional Shareholder Services Inc., a subsidiary of MSCI Inc.
Unless otherwise provided for herein, it shall generally be the policy of the Funds to vote in
accordance with the Agents recommendation when such recommendation aligns with the recommendation
of the relevant issuers management or management has made no recommendation. However, this policy
shall not apply to CASE-BY-CASE proposals for which a contrary recommendation from the Investment
Professional for the relevant Fund has been received and is to be utilized, provided that
incorporation of any such recommendation shall be subject to the conflict of interest review
process required under the Procedures.
Recommendations from the Investment Professionals, while not required under the Procedures, are
likely to be considered with respect to proxies for private equity securities and/or proposals
related to merger transactions/corporate restructurings, proxy contests, or unusual or
controversial issues. Such input shall be given primary consideration with respect to CASE-BY-CASE
proposals being considered on behalf of the relevant Fund.
Except as otherwise provided for herein, it shall generally be the policy of the Funds not to
support proposals that would impose a negative impact on existing rights of the Funds to the extent
that any positive impact would not be deemed sufficient to outweigh removal or diminution of such
rights.
The foregoing policies may be overridden in any case as provided for in the Procedures. Similarly,
the Procedures provide that proposals whose Guidelines prescribe a firm voting position may instead
be considered on a CASE-BY-CASE basis when unusual or controversial circumstances so dictate.
Interpretation and application of these Guidelines is not intended to supersede any law,
regulation, binding agreement or other legal requirement to which an issuer may be or become
subject. No proposal shall be supported whose implementation would contravene such requirements.
1. The Board of Directors
Voting on Director Nominees in Uncontested Elections
Unless otherwise provided for herein, the Agents standards with respect to determining director
independence shall apply. These standards generally provide that, to be considered completely
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independent, a director shall have no material connection to the company other than the board seat.
Agreement with the Agents independence standards shall not dictate that a Funds vote shall be
cast according to the Agents corresponding recommendation. Votes on director nominees not subject
to specific policies described herein should be made on a CASE-BY-CASE basis.
Where applicable and except as otherwise provided for herein, it shall generally be the policy of
the Funds to lodge disagreement with an issuers policies or practices by withholding support from
a proposal for the relevant policy or practice rather than the director nominee(s) to which the
Agent assigns a correlation. Support shall be withheld from nominees deemed responsible for
governance shortfalls, but if they are not standing for election (e.g., the board is classified),
support shall generally not be withheld from others in their stead. When a determination is made
to withhold support due to concerns other than those related to an individual directors
independence or actions, responsibility may be attributed to the entire board, a committee, or an
individual (such as the CEO or committee chair), taking into consideration whether the desired
effect is to send a message or to remove the director from service.
Where applicable and except as otherwise provided for herein, generally vote FOR nominees in
connection with issues raised by the Agent if the nominee did not serve on the board or relevant
committee during the majority of the time period relevant to the concerns cited by the Agent.
WITHHOLD support from a nominee who, during both of the most recent two years, attended less than
75 percent of the board and committee meetings without a valid reason for the absences. WITHHOLD
support if two-year attendance cannot be ascertained from available disclosure. DO NOT WITHHOLD
support in connection with attendance issues for nominees who have served on the board for less
than the two most recent years.
Unless a company has implemented a policy that should reasonably prevent abusive use of its poison
pill, WITHHOLD support from nominees responsible for implementing excessive anti-takeover measures,
including failure to remove restrictive poison pill features or to ensure a pills expiration or
timely submission to shareholders for vote. Rather than follow the Agents practice of withholding
support from all incumbent nominees, responsibility will generally be assigned to the board chair
or, if not standing for election, the lead director. If neither is standing for election, WITHHOLD
support from all continuing directors.
Consider on a CASE-BY-CASE basis any nominee whom the Agent cites as having failed to implement a
majority-approved shareholder proposal. Vote FOR if the shareholder proposal has been reasonably
addressed. Proposals seeking shareholder ratification of a poison pill may be deemed reasonably
addressed if the company has implemented a policy that should reasonably prevent abusive use of the
pill. WITHHOLD support if the shareholder proposal at issue is supported under these Guidelines
and the board has not disclosed its reasoning for not implementing the proposal.
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If the board has not acted upon negative votes (WITHHOLD or AGAINST, as applicable based on the
issuers election standard) representing a majority of the votes cast at the previous annual
meeting, consider board nominees on a CASE-BY-CASE basis. Generally, vote FOR nominees when:
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(1) |
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The issue relevant to the majority negative vote has been adequately addressed or
cured, which may include disclosure of the boards rationale; or |
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(2) |
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The Funds Guidelines or voting record do not support the relevant issue causing the
majority negative vote. |
If the above provisions have not been satisfied, generally WITHHOLD support from the chair of the
nominating committee, or if not standing for election, consider CASE-BY-CASE.
WITHHOLD support from inside directors or affiliated outside directors who sit on the audit
committee.
Vote FOR inside directors or affiliated outside directors who sit on the nominating or compensation
committee, provided that such committee meets the applicable independence requirements of the
relevant listing exchange.
Vote FOR inside directors or affiliated outside directors if the full board serves as the
compensation or nominating committee OR has not created one or both committees, provided that the
issuer is in compliance with all provisions of the listing exchange in connection with performance
of relevant functions (e.g., performance of relevant functions by a majority of independent
directors in lieu of the formation of a separate committee).
Compensation Practices:
It shall generally be the policy of the Funds that matters of compensation are best determined by
an independent board and compensation committee. Votes on director nominees in connection with
compensation practices should be considered on a CASE-BY-CASE basis, and generally:
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(1) |
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Say on pay. If shareholders have been provided with an advisory vote on
executive compensation (say on pay), and practices not supported under these Guidelines
have been identified, it shall generally be the policy of the Funds to align with the Agent
when a vote AGAINST the say on pay proposal has been recommended in lieu of withholding
support from certain nominees for compensation concerns. Issuers receiving negative
recommendations on both director nominees and say on pay regarding issues not otherwise
supported by these Guidelines will be considered on a CASE-BY-CASE basis. |
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(2) |
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Tenure. Where applicable and except as otherwise provided for herein, vote FOR
nominees who did not serve on the compensation committee, or board, as applicable based on
the Agents analysis, during the majority of the time period relevant to the concerns cited
by the Agent. |
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(3) |
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Pay for performance. Consider nominees receiving an adverse recommendation
from the Agent CASE-BY-CASE when the Agent has identified a pay practice (or combination of
practices) not otherwise supported under these Guidelines that appears to have created a
misalignment between CEO pay and performance with regard to |
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shareholder value. Generally vote FOR nominees if the company has provided a reasonable
rationale regarding pay and performance, or has demonstrated that they are reasonably
correlated, or when the increased compensation relates solely to a practice or practices
(such as an increase in option awards or base salary) not deemed inherently problematic by
the Agent. Generally WITHHOLD support from nominees for structuring equity compensation
such that pay is unreasonably insulated from performance conditions. |
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(4) |
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Pay disparity. Generally DO NOT WITHHOLD support from director nominees solely
due to internal pay disparity as assessed by the Agent, but consider pay magnitude concerns
on a CASE-BY-CASE basis. |
|
|
(5) |
|
Change in control provisions. If the Agent recommends withholding support from
nominees in connection with overly liberal change in control provisions, including those
lacking a double trigger, vote FOR such nominees if mitigating provisions or board actions
(e.g., clawbacks) are present, but generally WITHHOLD support if they are not. If the
Agent recommends withholding support from nominees in connection with potential change in
control payments or tax-gross-ups on change in control payments, vote FOR the nominees if
the amount appears reasonable and no material governance concerns exist. Generally
WITHHOLD support if the amount is so significant (individually or collectively) as to
potentially influence an executives decision to enter into a transaction or to effectively
act as a poison pill. |
|
|
(6) |
|
Repricing. If the Agent recommends withholding support from nominees in
connection with their failure to seek a shareholder vote on plans to reprice, replace, buy
back or exchange options, generally WITHHOLD support from such nominees, except that
cancellation of options would not be considered an exchange unless the cancelled options
were regranted or expressly returned to the plan reserve for reissuance. |
|
|
(7) |
|
Tax benefits. If the Agent recommends withholding support from nominees that
have approved compensation that is ineligible for tax benefits to the company (e.g., under
Section 162(m) of OBRA), vote FOR such nominees if the company has provided an adequate
rationale or the plan itself is being put to shareholder vote at the same meeting. If the
plan is up for vote, the provisions under Section 8., OBRA-Related Compensation Proposals,
shall apply. |
|
|
(8) |
|
Director perquisites. If the Agent recommends withholding support from
nominees in connection with director compensation in the form of perquisites, generally
vote FOR the nominees if the cost is reasonable in the context of the directors total
compensation and the perquisites themselves appear reasonable given their purpose, the
directors duties and the companys line of business. |
|
|
(9) |
|
Incentive plans. Generally WITHHOLD support from nominees in connection with
long-term incentive plans, or total executive compensation packages, inadequately aligned
with shareholders because they are overly cash-based/lack an appropriate equity component,
except that such cases will be considered CASE-BY-CASE in connection with executives
already holding significant equity positions. Generally consider nominees on a
CASE-BY-CASE basis in connection with short-term incentive plans over which the nominee has
exercised discretion to exclude extraordinary items, |
23
|
|
|
and WITHHOLD support if treatment of such items has been inconsistent (e.g., exclusion of
losses but not gains). |
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(10) |
|
Options backdating. If the Agent has raised issues of options backdating,
consider members of the compensation committee, or board, as applicable, as well as company
executives nominated as directors, on a CASE-BY-CASE basis. |
|
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(11) |
|
Independence from management. Generally WITHHOLD support from nominees cited
by the Agent for permitting named executives to have excessive input into setting their own
compensation. |
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(12) |
|
Multiple concerns. If the Agent recommends withholding support from nominees
in connection with other compensation practices such as tax gross-ups, perquisites,
retention or recruitment provisions (including contract length or renewal provisions),
guaranteed awards, pensions/SERPs, severance or termination arrangements, vote FOR such
nominees if the issuer has provided adequate rationale and/or disclosure, factoring in any
overall adjustments or reductions to the compensation package at issue. Generally DO NOT
WITHHOLD support solely due to any single such practice if the total compensation appears
reasonable, but consider on a CASE-BY-CASE basis compensation packages representing a
combination of such provisions and deemed by the Agent to be excessive. |
|
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(13) |
|
Commitments. Generally, vote FOR nominees receiving an adverse recommendation
from the Agent due to problematic pay practices if the issuer makes a public commitment
(e.g., via a Form 8-K filing) to rectify the practice on a going-forward basis. |
|
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(14) |
|
Other. If the Agent has raised other considerations regarding poor
compensation practices, consider nominees on a CASE-BY-CASE basis. |
Accounting Practices:
|
(1) |
|
Generally, vote FOR independent outside director nominees serving on the audit
committee. |
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(2) |
|
Where applicable and except as otherwise provided for herein, generally vote FOR
nominees serving on the audit committee, or the companys CEO or CFO if nominated as
directors, who did not serve on that committee or have responsibility over the relevant
financial function, as applicable, during the majority of the time period relevant to the
concerns cited by the Agent. |
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(3) |
|
If the Agent has raised concerns regarding poor accounting practices, consider the
companys CEO and CFO, if nominated as directors, and nominees serving on the audit
committee on a CASE-BY-CASE basis. Generally vote FOR nominees if the company has taken
adequate steps to remediate the concerns cited, which would typically include removing or
replacing the responsible executives, and if the concerns are not re-occurring and/or the
company has not yet had a full year to remediate the concerns since the time they were
identified. |
|
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(4) |
|
If total non-audit fees exceed the total of audit fees, audit-related fees and tax
compliance and preparation fees, the provisions under Section 3., Auditor Ratification,
shall apply. |
24
Board Independence:
It shall generally be the policy of the Funds that a board should be majority independent and
therefore to consider inside director or affiliated outside director nominees when the full board
is not majority independent on a CASE-BY-CASE basis. Generally:
|
(1) |
|
WITHHOLD support from the fewest directors whose removal would achieve majority
independence across the remaining board, except that support may be withheld from
additional nominees whose relative level of independence cannot be differentiated. |
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(2) |
|
WITHHOLD support from all non-independent nominees, including the founder, chairman or
CEO, if the number required to achieve majority independence is equal to or greater than
the number of non-independent nominees. |
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(3) |
|
Except as provided above, vote FOR non-independent nominees in the role of CEO, and
when appropriate, founder or chairman, and determine support for other non-independent
nominees based on the qualifications and contributions of the nominee as well as the Funds
voting precedent for assessing relative independence to management, e.g., insiders holding
senior executive positions are deemed less independent than affiliated outsiders with a
transactional or advisory relationship to the company, and affiliated outsiders with a
material transactional or advisory relationship are deemed less independent than those with
lesser relationships. |
|
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(4) |
|
Non-voting directors (e.g., director emeritus or advisory director) shall be excluded
from calculations with respect to majority board independence. |
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|
(5) |
|
When conditions contributing to a lack of majority independence remain substantially
similar to those in the previous year, it shall generally be the policy of the Funds to
vote on nominees in a manner consistent with votes cast by the Fund(s) in the previous
year. |
Generally vote FOR nominees without regard to over-boarding issues raised by the Agent unless
other concerns requiring CASE-BY-CASE consideration have been raised.
Generally, when the Agent recommends withholding support due to assessment that a nominee acted in
bad faith or against shareholder interests in connection with a major transaction, such as a merger
or acquisition, or if the Agent recommends withholding support due to other material failures or
egregious actions, consider on a CASE-BY-CASE basis, factoring in the merits of the nominees
performance and rationale and disclosure provided. If the Agent cites concerns regarding actions
in connection with a candidates service on another board, vote FOR the nominee if the issuer has
provided adequate rationale regarding the boards process for determining the appropriateness of
the nominee to serve on the board under consideration.
Performance Test for Directors
Consider nominees failing the Agents performance test, which includes market-based and operating
performance measures, on a CASE-BY-CASE basis. Input from the Investment Professional(s) for a
given Fund shall be given primary consideration with respect to such proposals.
Support will generally be WITHHELD from nominees receiving a negative recommendation from the Agent
due to sustained poor stock performance (measured by one- and three-year total
25
shareholder returns) combined with multiple takeover defenses/entrenchment devices if the issuer:
|
(1) |
|
Is a controlled company or has a non-shareholder-approved poison pill in place, without
provisions to redeem or seek approval in a reasonable period of time; and |
|
|
(2) |
|
Maintains a dual class capital structure, imposes a supermajority vote requirement or
has authority to issue blank check preferred stock. |
Nominees receiving a negative recommendation from the Agent due to sustained poor stock performance
combined with other takeover defenses/entrenchment devices will be considered on a CASE-BY-CASE
basis.
Proposals Regarding Board Composition or Board Service
Generally, except as otherwise provided for herein, vote AGAINST shareholder proposals to impose
new board structures or policies, including those requiring that the positions of chairman and CEO
be held separately, but vote FOR proposals in connection with a binding agreement or other legal
requirement to which an issuer has or reasonably may expect to become subject, and consider such
proposals on a CASE-BY-CASE basis if the board is not majority independent or corporate governance
concerns have been identified. Generally, except as otherwise provided for herein, vote FOR
management proposals to adopt or amend board structures or policies, except consider such proposals
on a CASE-BY-CASE basis if the board is not majority independent, corporate governance concerns
have been identified, or the proposal may result in a material reduction in shareholders
rights.
Generally, vote AGAINST shareholder proposals:
|
|
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Asking that more than a simple majority of directors be independent. |
|
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|
|
Asking that the independence of the compensation and/or nominating committees
be greater than that required by the listing exchange. |
|
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|
Limiting the number of public company boards on which a director may serve. |
|
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|
Seeking to redefine director independence or directors specific roles (e.g.,
responsibilities of the lead director). |
|
|
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|
Requesting creation of additional board committees or offices, except as
otherwise provided for herein. |
|
|
|
|
Limiting the tenure of outside directors or impose a mandatory retirement age
for outside directors (unless the proposal seeks to relax existing standards), but
generally vote FOR management proposals in this regard. |
Generally, vote FOR shareholder proposals that seek creation of an audit, compensation or
nominating committee of the board, unless the committee in question is already in existence or the
issuer has availed itself of an applicable exemption of the listing exchange (e.g., performance of
relevant functions by a majority of independent directors in lieu of the formation of a separate
committee).
Stock Ownership Requirements
Generally, vote AGAINST shareholder proposals requiring directors to own a minimum amount of
company stock in order to qualify as a director or to remain on the board.
26
Director and Officer Indemnification and Liability Protection
Proposals on director and officer indemnification and liability protection should be evaluated on a
CASE-BY-CASE basis, using Delaware law as the standard. Vote AGAINST proposals to limit or
eliminate entirely directors and officers liability for monetary damages for violating the duty
of care. Vote AGAINST indemnification proposals that would expand coverage beyond just legal
expenses to acts, such as negligence, that are more serious violations of fiduciary obligation than
mere carelessness. Vote FOR only those proposals providing such expanded coverage in cases when a
directors or officers legal defense was unsuccessful if:
|
(1) |
|
The director was found to have acted in good faith and in a manner that he reasonably
believed was in the best interests of the company; and |
|
|
(2) |
|
Only if the directors legal expenses would be covered. |
2. Proxy Contests
These proposals should generally be analyzed on a CASE-BY-CASE basis. Input from the Investment
Professional(s) for a given Fund shall be given primary consideration with respect to proposals in
connection with proxy contests being considered on behalf of that Fund.
Voting for Director Nominees in Contested Elections
Votes in a contested election of directors must be evaluated on a CASE-BY-CASE basis.
Reimburse Proxy Solicitation Expenses
Voting to reimburse proxy solicitation expenses should be analyzed on a CASE-BY-CASE basis,
generally voting FOR if associated nominees are also supported.
3. Auditors
Ratifying Auditors
Generally, except in cases of poor accounting practices or high non-audit fees, vote FOR management
proposals to ratify auditors. Consider management proposals to ratify auditors on a CASE-BY-CASE
basis if the Agent cites poor accounting practices. If fees for non-audit services exceed 50
percent of total auditor fees as described below, consider on a CASE-BY-CASE basis, voting AGAINST
management proposals to ratify auditors only if concerns exist that remuneration for the non-audit
work is so lucrative as to taint the auditors independence. For purposes of this review, fees
deemed to be reasonable, generally non-recurring exceptions to the non-audit fee category (e.g.,
those related to an IPO) shall be excluded. Generally vote FOR shareholder proposals asking the
issuer to present its auditor annually for ratification.
Auditor Independence
Generally, consider shareholder proposals asking companies to prohibit their auditors from engaging
in non-audit services (or capping the level of non-audit services) on a CASE-BY-CASE basis.
27
Audit Firm Rotation
Generally, vote AGAINST shareholder proposals asking for mandatory audit firm rotation.
4. Proxy Contest Defenses
Presentation of management and shareholder proposals on the same matter on the same agenda shall
not require a Fund to vote FOR one and AGAINST the other.
Board Structure: Staggered vs. Annual Elections
Generally, vote AGAINST proposals to classify the board or otherwise restrict shareholders ability
to vote upon directors and FOR proposals to repeal classified boards and to elect all directors
annually.
Shareholder Ability to Remove Directors
Generally, vote AGAINST proposals that provide that directors may be removed only for cause.
Generally, vote FOR proposals to restore shareholder ability to
remove directors with or without
cause.
Generally, vote AGAINST proposals that provide that only continuing directors may elect
replacements to fill board vacancies.
Generally, vote FOR proposals that permit shareholders to elect directors to fill board vacancies.
Cumulative Voting
If the company is controlled or maintains a classified board of directors, generally, vote AGAINST
management proposals to eliminate cumulative voting, except that such proposals may be supported
irrespective of classification in furtherance of an issuers plan to adopt a majority voting
standard, and vote FOR shareholder proposals to restore or permit cumulative voting.
Time-Phased Voting
Generally, vote AGAINST proposals to implement, and FOR proposals to eliminate, time-phased or
other forms of voting that do not promote a one share, one vote standard.
Shareholder Ability to Call Special Meetings
Generally, vote FOR management or shareholder proposals that provide shareholders with the ability
to call special meetings.
Shareholder Ability to Act by Written Consent
Generally, vote AGAINST shareholder proposals seeking the right to act by written consent if the
issuer:
|
(1) |
|
Permits shareholders to call special meetings; |
|
|
(2) |
|
Does not impose supermajority vote requirements; and |
|
|
(3) |
|
Has otherwise demonstrated its accountability to shareholders (e.g., the company has
reasonably addressed majority-supported shareholder proposals). |
28
Consider management proposals to eliminate the right to act by written consent on a CASE-BY-CASE
basis, generally voting FOR if the above conditions are present.
Generally, vote FOR shareholder proposals seeking the right to act by written consent if the above
conditions are not present.
Shareholder Ability to Alter the Size of the Board
Generally, vote FOR proposals that seek to fix the size of the board or designate a range for its
size.
Generally, vote AGAINST proposals that give management the ability to alter the size of the board
outside of a specified range without shareholder approval.
5. Tender Offer Defenses
Poison Pills
Generally, vote FOR shareholder proposals that ask a company to submit its poison pill for
shareholder ratification, or to redeem its pill in lieu thereof, unless (1) shareholders have
approved adoption of the plan, (2) a policy has already been implemented by the company that should
reasonably prevent abusive use of the pill, or (3) the board had determined that it was in the best
interest of shareholders to adopt a pill without delay, provided that such plan would be put to
shareholder vote within twelve months of adoption or expire, and if not approved by a majority of
the votes cast, would immediately terminate.
Review on a CASE-BY-CASE basis shareholder proposals to redeem a companys poison pill.
Review on a CASE-BY-CASE basis management proposals to approve or ratify a poison pill or any plan
or charter amendment (e.g., investment restrictions) that can reasonably be construed as an
anti-takeover measure, with voting decisions generally based on the Agents approach to evaluating
such proposals, considering factors such as rationale, trigger level and sunset provisions. Votes
will generally be cast in a manner that seeks to preserve shareholder value and the right to
consider a valid offer, voting AGAINST management proposals in connection with poison pills or
anti-takeover activities that do not meet the Agents standards.
Fair Price Provisions
Vote proposals to adopt fair price provisions on a CASE-BY-CASE basis.
Generally, vote AGAINST fair price provisions with shareholder vote requirements greater than a
majority of disinterested shares.
Greenmail
Generally, vote FOR proposals to adopt anti-greenmail charter or bylaw amendments or otherwise
restrict a companys ability to make greenmail payments.
Review on a CASE-BY-CASE basis anti-greenmail proposals when they are bundled with other charter or
bylaw amendments.
Pale Greenmail
Review on a CASE-BY-CASE basis restructuring plans that involve the payment of pale greenmail.
29
Unequal Voting Rights
Generally, vote AGAINST dual-class exchange offers and dual-class recapitalizations.
Supermajority Shareholder Vote Requirement
Generally,
vote AGAINST proposals to require a supermajority shareholder vote.
Generally, vote FOR management or shareholder proposals to lower
supermajority shareholder vote
requirements, unless, for companies with shareholder(s) with
significant ownership levels, the
Agent recommends retention of existing supermajority requirements in
order to protect minority
shareholder interests.
White Squire Placements
Generally, vote FOR shareholder proposals to require approval of blank check preferred stock issues
for other than general corporate purposes.
6. Miscellaneous
Amendments to Corporate Documents
Except to align with legislative or regulatory changes or when support is recommended by the Agent
or Investment Professional (including, for example, as a condition to a major transaction such as a
merger), generally, vote AGAINST proposals seeking to remove shareholder approval requirements or
otherwise remove or diminish shareholder rights, e.g., by (1) adding restrictive provisions, (2)
removing provisions or moving them to portions of the charter not requiring shareholder approval,
or (3) in corporate structures such as holding companies, removing provisions in an active
subsidiarys charter that provide voting rights to parent company shareholders. This policy would
also generally apply to proposals seeking approval of corporate agreements or amendments to such
agreements that the Agent recommends AGAINST because a similar reduction in shareholder rights is
requested.
Generally, vote AGAINST proposals for charter amendments that support board entrenchment or may be
used as an anti-takeover device (or to further anti-takeover conditions), particularly if the
proposal is bundled or the board is classified.
Generally, vote FOR proposals seeking charter or bylaw amendments to remove anti-takeover
provisions.
Consider proposals seeking charter or bylaw amendments not addressed under these Guidelines on a
CASE-BY-CASE basis.
Confidential Voting
Generally, vote FOR shareholder proposals that request companies to adopt confidential voting, use
independent tabulators, and use independent inspectors of election as long as the proposals include
clauses for proxy contests as follows:
|
|
|
In the case of a contested election, management should be permitted to request
that the dissident group honor its confidential voting policy. |
|
|
|
|
If the dissidents agree, the policy remains in place. |
|
|
|
|
If the dissidents do not agree, the confidential voting policy is waived. |
30
Generally, vote FOR management proposals to adopt confidential voting.
Proxy Access
Consider on a CASE-BY-CASE basis shareholder proposals seeking access to managements proxy
material in order to nominate their own candidates to the board.
Majority Voting Standard
Except as otherwise provided for herein, it shall generally be the policy of the Funds to extend
discretion to issuers to determine when it may be appropriate to adopt a majority voting
standard. Generally, vote FOR management proposals, provided the proposal contains a
plurality carve-out for contested elections, but AGAINST shareholder proposals unless also
supported by management, seeking election of directors by the affirmative vote of the majority of
votes cast in connection with a meeting of shareholders, including amendments to corporate
documents or other actions in furtherance of a majority standard, and provided such standard does
not conflict with state law in which the company is incorporated. For issuers with a history of
significant corporate governance concerns, consider such proposals on a CASE-BY-CASE basis.
Bundled Proposals
Except as otherwise provided for herein, review on a CASE-BY-CASE basis bundled or conditioned
proxy proposals, generally voting AGAINST bundled proposals containing one or more items not
supported under these Guidelines if the Agent or an Investment Professional deems the negative
impact, on balance, to outweigh any positive impact.
Shareholder Advisory Committees
Review on a CASE-BY-CASE basis proposals to establish a shareholder advisory committee.
Reimburse Shareholder for Expenses Incurred
Voting to reimburse expenses incurred in connection with shareholder proposals should be analyzed
on a CASE-BY-CASE basis.
Other Business
In connection with proxies of U.S. issuers, generally vote FOR management proposals for Other
Business, except in connection with a proxy contest in which a Fund is not voting in support of
management.
Quorum Requirements
Review on a CASE-BY-CASE basis proposals to lower quorum requirements for shareholder meetings
below a majority of the shares outstanding.
Advance Notice for Shareholder Proposals
Generally, vote FOR management proposals related to advance notice period requirements, provided
that the period requested is in accordance with applicable law and no material governance concerns
have been identified in connection with the issuer.
31
Multiple Proposals
Multiple proposals of a similar nature presented as options to the course of action favored by
management may all be voted FOR, provided that support for a single proposal is not operationally
required, no one proposal is deemed superior in the interest of the Fund(s), and each proposal
would otherwise be supported under these Guidelines.
7. Capital Structure
Common Stock Authorization
Review proposals to increase the number of shares of common stock authorized for issuance on a
CASE-BY-CASE basis. Except where otherwise indicated, the Agents proprietary approach of
determining appropriate thresholds and, for requests above such allowable threshold, applying a
company-specific, qualitative review (e.g., considering rationale and prudent historical usage),
will generally be utilized in evaluating such proposals.
Generally vote FOR:
|
|
|
Proposals to authorize capital increases within the Agents allowable
thresholds or those in excess but meeting Agents qualitative standards, but consider on a
CASE-BY-CASE basis those requests failing the Agents review for proposals in connection
with which a contrary recommendation from the Investment Professional(s) has been received
and is to be utilized (e.g., in support of a merger or acquisition proposal). |
|
|
|
|
Proposals to authorize capital increases within the Agents allowable
thresholds or those in excess but meeting Agents qualitative standards, unless the company
states that the stock may be used as a takeover defense. In those cases, consider on a
CASE-BY-CASE basis if a contrary recommendation from the Investment Professional(s) has
been received and is to be utilized. |
|
|
|
|
Proposals to authorize capital increases exceeding the Agents thresholds when
a companys shares are in danger of being delisted or if a companys ability to continue to
operate as a going concern is uncertain. |
Generally, vote AGAINST:
|
|
|
Proposals to increase the number of authorized shares of a class of stock if
the issuance which the increase is intended to service is not supported under these
Guidelines. |
|
|
|
|
Nonspecific proposals authorizing excessive discretion to a board. |
Consider management proposals to make changes to the capital structure not otherwise addressed
under these Guidelines CASE-BY-CASE, generally voting with the Agents recommendation unless a
contrary recommendation has been received from the Investment Professional for the relevant Fund
and is to be utilized.
Dual Class Capital Structures
Generally, vote AGAINST proposals to increase the number of authorized shares of the class of stock
that has superior voting rights in companies that have dual class capital structures, but consider
CASE-BY-CASE if (1) bundled with favorable proposal(s), (2) approval of such
32
proposal(s) is a condition of such favorable proposal(s), or (3) part of a recapitalization for
which support is recommended by the Agent or an Investment Professional.
Generally, vote AGAINST management proposals to create or perpetuate dual class capital structures
with unequal voting rights, and vote FOR shareholder proposals to eliminate them, when the relevant
Fund owns the class with inferior voting rights, but generally vote FOR management proposals and
AGAINST shareholder proposals when the relevant Fund owns the class with superior voting rights.
Consider CASE-BY-CASE if bundled with favorable proposal(s), (2) approval of such proposal(s) is a
condition of such favorable proposal(s), or (3) part of a recapitalization for which support is
recommended by the Agent or an Investment Professional.
Consider management proposals to eliminate or make changes to dual class capital structures
CASE-BY-CASE, generally voting with the Agents recommendation unless a contrary recommendation has
been received from the Investment Professional for the relevant Fund and is to be utilized.
Stock Distributions: Splits and Dividends
Generally, vote FOR management proposals to increase common share authorization for a stock split,
provided that the increase in authorized shares falls within the Agents allowable thresholds, but
consider on a CASE-BY-CASE basis those proposals exceeding the Agents threshold for proposals in
connection with which a contrary recommendation from the Investment Professional(s) has been
received and is to be utilized.
Reverse Stock Splits
Consider on a CASE-BY-CASE basis management proposals to implement a reverse stock split. In the
event the split constitutes a capital increase effectively exceeding the Agents allowable
threshold because the request does not proportionately reduce the number of shares authorized,
consider managements rationale and/or disclosure, generally voting FOR, but generally not
supporting additional requests for capital increases on the same agenda.
Preferred Stock
Review proposals to increase the number of shares of preferred stock authorized for issuance on a
CASE-BY-CASE basis, and except where otherwise indicated, generally utilize the Agents approach
for evaluating such proposals. This approach incorporates both qualitative and quantitative
measures, including a review of past performance (e.g., board governance, shareholder returns and
historical share usage) and the current request (e.g., rationale, whether shares are blank check
and declawed, and dilutive impact as determined through the Agents proprietary model for assessing
appropriate thresholds).
Generally, vote AGAINST proposals authorizing the issuance of preferred stock or creation of new
classes of preferred stock with unspecified voting, conversion, dividend distribution, and other
rights (blank check preferred stock), but vote FOR if the Agent or an Investment Professional so
recommends because the issuance is required to effect a merger or acquisition proposal.
Generally, vote FOR proposals to issue or create blank check preferred stock in cases when the
company expressly states that the stock will not be used as a takeover defense. Generally vote
33
AGAINST in cases where the company expressly states that, or fails to disclose whether, the stock
may be used as a takeover defense, but vote FOR if the Agent or an Investment Professional so
recommends because the issuance is required to address special circumstances such as a merger or
acquisition.
Generally, vote FOR proposals to authorize or issue preferred stock in cases where the company
specifies the voting, dividend, conversion, and other rights of such stock and the terms of the
preferred stock appear reasonable.
Vote CASE-BY-CASE on proposals to increase the number of blank check preferred shares after
analyzing the number of preferred shares available for issue given a companys industry and
performance in terms of shareholder returns.
Shareholder Proposals Regarding Blank Check Preferred Stock
Generally, vote FOR shareholder proposals to have blank check preferred stock placements, other
than those shares issued for the purpose of raising capital or making acquisitions in the normal
course of business, submitted for shareholder ratification.
Adjustments to Par Value of Common Stock
Generally, vote FOR management proposals to reduce the par value of common stock.
Preemptive Rights
Review on a CASE-BY-CASE basis shareholder proposals that seek preemptive rights or management
proposals that seek to eliminate them. In evaluating proposals on preemptive rights, consider the
size of a company and the characteristics of its shareholder base.
Debt Restructurings
Review on a CASE-BY-CASE basis proposals to increase common and/or preferred shares and to issue
shares as part of a debt restructuring plan.
Share Repurchase Programs
Generally, vote FOR management proposals to institute open-market share repurchase plans in which
all shareholders may participate on equal terms, but vote AGAINST plans with terms favoring
selected parties.
Generally, vote FOR management proposals to cancel repurchased shares.
Generally, vote AGAINST proposals for share repurchase methods
lacking adequate risk mitigation or
exceeding appropriate volume or duration parameters for the market.
Consider shareholder proposals seeking share repurchase programs on a CASE-BY-CASE basis, with
input from the Investment Professional(s) for a given Fund to be given primary consideration.
Tracking Stock
Votes on the creation of tracking stock are determined on a CASE-BY-CASE basis.
34
8. Executive and Director Compensation
Except as otherwise provided for herein, votes with respect to compensation and employee benefit
plans should be determined on a CASE-BY-CASE basis, with voting decisions generally based on the
Agents approach to evaluating such plans, which includes determination of costs and comparison to
an allowable cap.
|
|
|
Generally, vote in accordance with the Agents recommendations FOR
equity-based plans with costs within such cap and AGAINST those with costs in excess of it,
except that plans above the cap may be supported if so recommended by the Agent or
Investment Professional as a condition to a major transaction such as a merger. |
|
|
|
|
Generally, vote AGAINST plans if the Agent suggests cost or dilution
assessment may not be possible due to the method of disclosing shares allocated to the
plan(s), except that such concerns arising in connection with evergreen provisions shall be
considered CASE-BY-CASE, voted FOR if the company has provided a reasonable rationale
and/or adequate disclosure regarding the plan as a whole. |
|
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|
|
Generally, vote FOR plans with costs within the cap if the primary
considerations raised by the Agent pertain to burn rate thresholds set by the Agent or
matters that would not result in a negative vote under these Guidelines on a management say
on pay proposal or the relevant board or committee member(s). |
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Generally, vote AGAINST plans administered by potential grant recipients. |
|
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|
Generally, vote AGAINST proposals to eliminate existing shareholder approval
requirements for material plan changes, unless the company has provided a reasonable
rationale and/or adequate disclosure regarding the requested changes. |
|
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|
Generally vote AGAINST long-term incentive plans that are inadequately aligned
with shareholders because they lack an appropriate equity component, except that such cases
will be considered CASE-BY-CASE in connection with executives already holding significant
equity positions. |
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|
|
Generally, vote AGAINST plans that contain an overly liberal change in control
definition (e.g., does not result in actual change in control). |
|
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|
Consider plans CASE-BY-CASE if the Agent raises other considerations not
otherwise provided for herein. |
Restricted Stock or Stock Option Plans
Consider proposals for restricted stock or stock option plans, or the issuance of shares in
connection with such plans, on a CASE-BY-CASE basis, considering factors such as level of
disclosure and adequacy of vesting or performance requirements. Plans that do not meet the Agents
criteria in this regard may be supported, but vote AGAINST if no disclosure is provided regarding
either vesting or performance requirements.
Management Proposals Seeking Approval to Reprice Options
Review on a CASE-BY-CASE basis management proposals seeking approval to reprice, replace or
exchange options, considering factors such as rationale, historic trading patterns, value-for-value
exchange, vesting periods and replacement option terms. Generally, vote FOR proposals that meet
the Agents criteria for acceptable repricing, replacement or exchange transactions,
35
except that considerations raised by the Agent regarding burn rate or executive participation shall
not be grounds for withholding support.
Vote AGAINST compensation plans that (1) permit or may permit (e.g., history of repricing and no
express prohibition against future repricing) repricing of stock options, or any form or
alternative to repricing, without shareholder approval, (2) include provisions that permit
repricing, replacement or exchange transactions that do not meet the Agents criteria (except
regarding burn rate or executive participation as noted above), or (3) give the board sole
discretion to approve option repricing, replacement or exchange programs.
Director Compensation
Votes on stock-based plans for directors are made on a CASE-BY-CASE basis, with voting decisions
generally based on the Agents quantitative approach described above as well as a review of
qualitative features of the plan when costs exceed the Agents threshold. DO NOT VOTE AGAINST
plans for which burn rate is the sole consideration raised by the Agent.
Employee Stock Purchase Plans
Votes on employee stock purchase plans, and capital issuances in support of such plans, should be
made on a CASE-BY-CASE basis, with voting decisions generally based on the Agents approach to
evaluating such plans, except that negative recommendations by the Agent due to evergreen
provisions will be reviewed CASE-BY-CASE, voted FOR if the company has provided a reasonable
rationale and/or adequate disclosure regarding the plan as a whole.
OBRA-Related Compensation Proposals
Votes on plans intended to qualify for favorable tax treatment under the provisions of Section
162(m) of OBRA should be evaluated irrespective of the Agents assessment of board independence,
provided that the board meets the independence requirements of the relevant listing exchange and no
potential recipient under the plan(s) sits on the committee that exercises discretion over the
related compensation awards. Unless the issuer has provided a compelling rationale, generally vote
with the Agents recommendations AGAINST plans that deliver excessive compensation that fails to
qualify for favorable tax treatment.
Amendments that Place a Cap on Annual Grants or Amend Administrative Features
Generally, vote FOR plans that simply amend shareholder-approved plans to include administrative
features or place a cap on the annual grants any one participant may receive to comply with the
provisions of Section 162(m) of OBRA.
Amendments to Add Performance-Based Goals
Generally, vote FOR amendments to add performance goals to existing compensation plans to comply
with the provisions of Section 162(m) of OBRA.
Amendments to Increase Shares and Retain Tax Deductions Under OBRA
Votes on amendments to existing plans to increase shares reserved and to qualify the plan for
favorable tax treatment under the provisions of Section 162(m) should be evaluated on a
36
CASE-BY-CASE basis, generally voting FOR such plans that do not raise any negative concerns
under these Guidelines.
Approval of Cash or Cash-and-Stock Bonus Plans
Generally, vote FOR cash or cash-and-stock bonus plans to exempt the compensation from taxes
under the provisions of Section 162(m) of OBRA, with primary consideration given to managements
assessment that such plan meets the requirements for exemption of performance-based
compensation.
Shareholder Proposals Regarding Executive and Director Pay
Regarding the remuneration of individuals other than senior executives and directors, generally,
vote AGAINST shareholder proposals that seek to expand or restrict disclosure or require
shareholder approval beyond regulatory requirements and market practice. Vote AGAINST shareholder
proposals that seek disclosure of executive or director compensation if providing it would be out
of step with market practice and disruptive to the business.
Unless evidence exists of abuse in historical compensation practices, and except as otherwise
provided for herein, generally vote AGAINST shareholder proposals that seek to impose new
compensation structures or policies.
Severance and Termination Payments
Generally, vote FOR shareholder proposals to have parachute arrangements submitted for shareholder
ratification (with parachutes defined as compensation arrangements related to termination that
specify change in control events) and provided that the proposal does not include unduly
restrictive or arbitrary provisions such as advance approval requirements.
Generally, vote FOR shareholder proposals seeking double triggers on change in control awards.
Generally vote FOR shareholder proposals to submit executive
severance agreements for shareholder
ratification, if such proposals specify change in control events,
Supplemental Executive Retirement
Plans, or deferred executive compensation plans, or if ratification
is required by the listing
exchange.
Review on a CASE-BY-CASE basis all proposals to approve, ratify or cancel executive severance or
termination arrangements, including those related to executive recruitment or retention. Generally
vote FOR such compensation arrangements if:
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(1) |
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The primary considerations raised by the Agent would not result in a negative vote
under these Guidelines on a management say on pay proposal or the relevant board or
committee member(s); |
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(2) |
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The issuer has provided adequate rationale and/or disclosure; or |
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(3) |
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Support is recommended by the Agent or Investment Professional (e.g., as a condition to
a major transaction such as a merger). |
However, vote in accordance with the Agents recommendations AGAINST new or materially amended
plans, contracts or payments that include single trigger change in control provisions or do not
require an actual change in control in order to be triggered, except that plans, contracts or
payments with single triggers may be supported if mitigating provisions or board actions (e.g.,
clawbacks) are present.
37
Employee Stock Ownership Plans (ESOPs)
Generally, vote FOR proposals that request shareholder approval in order to implement an ESOP or to
increase authorized shares for existing ESOPs, except in cases when the number of shares allocated
to the ESOP is excessive (i.e., generally greater than five percent of outstanding shares).
401(k) Employee Benefit Plans
Generally, vote FOR proposals to implement a 401(k) savings plan for employees.
Holding Periods
Generally, vote AGAINST proposals requiring mandatory periods for officers and directors to hold
company stock.
Advisory Votes on Executive Compensation (Say on Pay)
Generally, management proposals seeking ratification of the companys compensation program will be
voted FOR unless the program includes practices or features not supported under these Guidelines
and the proposal receives a negative recommendation from the Agent. Unless otherwise provided for
herein, proposals not receiving the Agents support due to concerns regarding severance/termination
payments, incentive structures or vesting or performance criteria not otherwise supported by these
Guidelines will be considered on a CASE-BY-CASE basis, factoring in whether the issuer has made
improvements to its overall compensation program and generally voting FOR if the company has
provided a reasonable rationale and/or adequate disclosure regarding the matter(s) under
consideration. For say on pay proposals not supported by the Agent and referencing incentive plan
concerns:
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(1) |
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Long-term incentive plans: Proposals will be voted AGAINST if they cite
long-term incentive plans that are inadequately aligned with shareholders because they are
cash-based or lack an appropriate equity component, except that such cases will be
considered CASE-BY-CASE in connection with executives already holding significant equity
positions. |
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(2) |
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Short-term incentive plans: Proposals will be considered on a CASE-BY-CASE
basis if they cite short-term incentive plans over which the board has exercised discretion
to exclude extraordinary items, and voted AGAINST if treatment of such items has been
inconsistent (e.g., exclusion of losses but not gains). |
Generally, vote AGAINST proposals when named executives have material input into setting their own
compensation.
Generally, vote AGAINST proposals presented by issuers subject to Troubled Asset Relief Program
(TARP) provisions if there is inadequate discussion of the process for ensuring that incentive
compensation does not encourage excessive risk-taking.
Frequency of Advisory Votes on Executive Compensation
Generally, support proposals seeking an annual say on pay and oppose those seeking a less frequent
say on pay.
38
9. State of Incorporation
Voting on State Takeover Statutes
Review on a CASE-BY-CASE basis proposals to opt in or out of state takeover statutes (including
control share acquisition statutes, control share cash-out statutes, freezeout provisions, fair
price provisions, stakeholder laws, poison pill endorsements, severance pay and labor contract
provisions, anti-greenmail provisions, and disgorgement provisions).
Voting on Reincorporation Proposals
Proposals to change a companys state of incorporation should be examined on a CASE-BY-CASE basis,
generally supporting management proposals not assessed as a potential takeover defense, but if so
assessed, weighing managements rationale for the change. Generally, vote FOR management
reincorporation proposals upon which another key proposal, such as a merger transaction, is
contingent if the other key proposal is also supported. Generally, vote AGAINST shareholder
reincorporation proposals not also supported by the company.
10. Mergers and Corporate Restructurings
Input from the Investment Professional(s) for a given Fund shall be given primary consideration
with respect to proposals regarding business combinations, particularly those between otherwise
unaffiliated parties, or other corporate restructurings being considered on behalf of that Fund.
Generally, vote FOR a proposal not typically supported under these Guidelines if a key proposal,
such as a merger transaction, is contingent upon its support and a vote FOR is accordingly
recommended by the Agent or an Investment Professional.
Mergers and Acquisitions
Votes on mergers and acquisitions should be considered on a CASE-BY-CASE basis.
Corporate Restructuring
Votes on corporate restructuring proposals, including demergers, minority squeezeouts, leveraged
buyouts, spinoffs, liquidations, dispositions, divestitures and asset sales, should be considered
on a CASE-BY-CASE basis, with voting decisions generally based on the Agents approach to
evaluating such proposals.
Adjournment
Generally, vote FOR proposals to adjourn a meeting to provide additional time for vote solicitation
when the primary proposal is also voted FOR.
Appraisal Rights
Generally, vote FOR proposals to restore, or provide shareholders with, rights of appraisal.
Changing Corporate Name
Generally, vote FOR changing the corporate name.
39
11. Mutual Fund Proxies
Approving New Classes or Series of Shares
Generally, vote FOR the establishment of new classes or series of shares.
Authorizing the Board to Hire and Terminate Subadvisors Without Shareholder Approval
Generally, vote FOR these proposals.
Master-Feeder Structure
Generally, vote FOR the establishment of a master-feeder structure.
Establish Director Ownership Requirement
Generally, vote AGAINST shareholder proposals for the establishment of a director ownership
requirement.
The matters below should be examined on a CASE-BY-CASE basis:
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Election of Directors |
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Converting Closed-end Fund to Open-end Fund |
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Proxy Contests |
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Investment Advisory Agreements |
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Preferred Stock Proposals |
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1940 Act Policies |
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Changing a Fundamental Restriction to a Nonfundamental Restriction |
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Change Fundamental Investment Objective to Nonfundamental |
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Name Rule Proposals |
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Disposition of Assets/Termination/Liquidation |
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Changes to the Charter Document |
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Changing the Domicile of a Fund |
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Change in Funds Subclassification |
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Distribution Agreements |
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Mergers |
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Reimburse Shareholder for Expenses Incurred |
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Terminate the Investment Advisor |
12. Social and Environmental Issues
Boards of directors and company management are responsible for guiding the corporation in
connection with matters that are most often the subject of shareholder proposals on social and
environmental issues: ensuring that the companies they oversee comply with applicable legal,
regulatory and ethical standards, effectively managing risk, and assessing and addressing matters
that may have a financial impact on shareholder value. The Funds will generally vote in accordance
with the boards recommendation on such proposals unless it appears both that the stewardship noted
above has fallen short and the issue is material to the company. The former
40
may be evidenced by the companys failure to align its actions and disclosure with market practice
and that of its peers, or the companys having been subject to significant controversies,
litigation, fines or penalties in connection with the relevant issue. Such instances will be
considered CASE-BY-CASE. The Funds will generally vote AGAINST shareholder proposals seeking to
dictate corporate conduct, impose excessive costs or restrictions, duplicate policies already
substantially in place, or release information that would not help a shareholder evaluate an
investment in the corporation as an economic matter.
13. Global Proxies
Companies incorporated outside the U.S. shall generally be subject to the foregoing U.S. Guidelines
if they are listed on a U.S. exchange and treated as a U.S. domestic issuer by the Securities and
Exchange Commission. Where applicable and not provided for otherwise herein, certain U.S.
Guidelines may also be applied to companies incorporated outside the U.S., e.g., companies with a
significant base of U.S. operations and employees. However, the following provide for differing
regulatory and legal requirements, market practices and political and economic systems existing in
various global markets.
Unless otherwise provided for herein, it shall generally be the policy of the Funds to vote AGAINST
global proxy proposals when the Agent recommends voting AGAINST such proposal because relevant
disclosure by the issuer, or the time provided for consideration of such disclosure, is inadequate.
For purposes of these global Guidelines, AGAINST shall mean withholding of support for a
proposal, resulting in submission of a vote of AGAINST or ABSTAIN, as appropriate for the given
market and level of concern raised by the Agent regarding the issue or lack of disclosure or time
provided.
In connection with practices described herein that are associated with a firm AGAINST vote, it
shall generally be the policy of the Funds to consider them on a CASE-BY-CASE basis if the Agent
recommends their support (1) as the issuer or market transitions to better practices (e.g., having
committed to new regulations or governance codes) or (2) as the more favorable choice when
shareholders must choose between alternate proposals.
Routine Management Proposals
Generally, vote FOR the following and other similar routine management proposals:
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the opening of the shareholder meeting |
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that the meeting has been convened under local regulatory requirements |
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the presence of quorum |
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the agenda for the shareholder meeting |
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the election of the chair of the meeting |
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the appointment of shareholders to co-sign the minutes of the meeting |
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regulatory filings (e.g., to effect approved share issuances) |
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the designation of inspector or shareholder representative(s) of minutes of
meeting |
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the designation of two shareholders to approve and sign minutes of meeting |
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the allowance of questions |
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the publication of minutes |
41
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the closing of the shareholder meeting |
Consider proposals seeking authority to call shareholder meetings on less than 21 days notice on a
CASE-BY-CASE basis, with voting decisions generally based on the Agents approach to consider
whether the issuer has provided clear disclosure of its compliance with any hurdle conditions for
the authority imposed by applicable law and has historically limited it use of such authority to
time-sensitive matters.
Discharge of Management/Supervisory Board Members
Generally, vote FOR management proposals seeking the discharge of management and supervisory board
members, unless the Agent recommends AGAINST due to concern about the past actions of the companys
auditors or directors or legal action is being taken against the board by other shareholders,
including when the proposal is bundled. Generally do not withhold support from such proposals in
connection with remuneration practices otherwise supported under these Guidelines or as a means of
expressing disapproval of broader practices of the issuer or its board.
Director Elections
Unless otherwise provided for herein, the Agents standards with respect to determining director
independence shall apply. These standards generally provide that, to be considered completely
independent, a director shall have no material connection to the company other than the board seat.
Agreement with the Agents independence standards shall not dictate that a Funds vote shall be
cast according to the Agents corresponding recommendation. Further, unless otherwise provided for
herein, the application of Guidelines in connection with such standards shall apply only when the
nominees level of independence can be ascertained based on available disclosure. These policies
generally apply to director nominees in uncontested elections; votes in contested elections, and
votes on director nominees not subject to policies described herein, should be made on a
CASE-BY-CASE basis, with primary consideration in contested elections given to input from the
Investment Professional(s) for a given Fund.
For issuers domiciled in Canada, Finland, France, Ireland, the Netherlands, Sweden or tax haven
markets, generally vote AGAINST non-independent directors when the full board serves as the audit
committee, or the company does not have an audit committee.
For issuers in all markets, including those in tax haven markets and those in Japan that have
adopted the U.S.-style board-with-committees structure, vote AGAINST non-independent nominees to
the audit committee, or, if the slate of nominees is bundled, vote AGAINST the slate. If the slate
is bundled and audit committee membership is unclear or proposed as a separate agenda item, vote
FOR if the Agent otherwise recommends support. For Canadian issuers, the Funds U.S. Guidelines
with respect to audit committees shall apply; in addition, nominees (or slates of nominees) will be
voted AGAINST if they do not comply with regulatory requirements to disclose audit fees broken down
by category.
42
Negative recommendations from the Agent on slate ballots of nominees at Canadian issuers will be
considered on a CASE-BY-CASE basis if the board is classified or the Agent cites other concerns not
otherwise supported by these Guidelines, generally voting AGAINST when concerns relate to dual
class capital structures or other anti-takeover/entrenchment devices.
Generally, vote FOR non-independent directors when the full board serves as the compensation or
nominating committee, or the company does not have a compensation or nominating committee, if the
board meets the applicable independence requirements of the relevant listing exchange. Vote FOR
non-independent directors who sit on the compensation or nominating committees if such committee
meets the applicable independence requirements of the relevant listing exchange.
Generally follow the Agents recommendations to vote AGAINST individuals nominated as
outside/non-executive directors who do not meet the Agents standard for independence, unless the
slate of nominees is bundled, in which case the proposal(s) to elect board members shall be
considered on a CASE-BY-CASE basis.
For issuers in tax haven markets, generally withhold support (AGAINST or ABSTAIN, as appropriate)
from bundled slates of nominees if the board is non-majority independent. For issuers in Canada
and other global markets, generally follow the Agents standards for withholding support from
bundled slates or non-independent directors (typically excluding the CEO), as applicable, if the
board does not meet the Agents independence standards or the boards independence cannot be
ascertained due to inadequate disclosure.
For issuers in Japan, generally follow the Agents recommendations in furtherance of greater board
independence and minority shareholder protections, including:
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At listed subsidiary companies with controlling shareholders, if the board
after the shareholder meeting does not include at least two directors deemed independent
under the Agents standards, generally vote AGAINST reelection of top executives. |
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At companies with a three-committee structure, generally vote AGAINST outside
director nominees not deemed independent under the Agents standards; however, generally
vote FOR affiliated outsiders if the board after the shareholder meeting is majority
independent. |
Generally, withhold support (AGAINST or ABSTAIN, as appropriate) from nominees or slates of
nominees presented in a manner not aligned with market practice and/or legislation, including:
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Bundled slates of nominees (e.g., France, Hong Kong or Spain); |
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Simultaneous reappointment of retiring directors (e.g., South Africa); |
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In markets with term lengths capped by legislation or market practice,
nominees whose terms exceed the caps or are not disclosed (except that bundled slates with
such lack of disclosure shall be considered on a CASE-BY-CASE basis); or |
43
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Nominees whose names are not disclosed in advance of the meeting (e.g.,
Austria, Philippines, Hong Kong or South Africa) or far enough in advance relative to
voting deadlines (e.g., Italy) to make an informed voting decision. |
Such criteria will not generally provide grounds for withholding support in countries in which they
may be identified as best practice but such legislation or market practice is not yet applicable,
unless specific governance shortfalls identified by the Agent (e.g., director terms longer than
four years) indicate diminished accountability to shareholders and so dictate that less latitude
should be extended to the issuer.
Generally vote FOR nominees without regard to recommendations that the position of chairman should
be separate from that of CEO or otherwise required to be independent, unless other concerns
requiring CASE-BY-CASE consideration have been raised. The latter would include former CEOs
proposed as board chairmen in markets such as the United Kingdom for which best practice and the
Agent recommend against such practice.
When cumulative or net voting applies, generally vote with the Agents recommendation to support
nominees asserted by the issuer to be independent, even if independence disclosure or criteria fall
short of Agents standards.
Consider nominees for whom the Agent has raised concerns regarding scandals or internal controls on
a CASE-BY-CASE basis, generally withholding support (AGAINST or ABSTAIN, as appropriate) from
nominees or slates of nominees when:
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The scandal or shortfall in controls took place at the company, or an
affiliate, for which the nominee is being considered; |
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Culpability can be attributed to the nominee (e.g., nominee manages or audits
relevant function); and |
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The nominee has been directly implicated, with resulting arrest and criminal
charge or regulatory sanction. |
Consider non-independent nominees on a CASE-BY-CASE basis when the Agent has raised concerns
regarding diminished shareholder value as evidenced by a significant drop in share price, generally
voting with Agents recommendation AGAINST such nominees when few, if any, outside directors are
present on the board and:
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The founding family has retained undue influence over the company despite a
history of scandal or problematic controls; |
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The nominees have engaged in protectionist activities such as introduction of
a poison pill or preferential and/or dilutive share issuances; or |
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Evidence exists regarding compliance or accounting shortfalls. |
If the Agent recommends withholding support due to other material failures or egregious actions,
the Funds U.S. Guidelines with respect to such issues shall apply.
Consider nominees serving on the remuneration committee on a CASE-BY-CASE basis if the Agent
recommends withholding support from nominees in connection with remuneration
44
practices not otherwise supported by these Guidelines, including cases in which the issuer has not
followed market practice by submitting a resolution on executive compensation.
For issuers in markets in which nominees attendance records are adequately disclosed, the Funds
U.S. Guidelines with respect to director attendance shall apply. The same two-year attendance
policy shall be applied regarding attendance by directors and statutory auditors of Japanese
companies if year-over-year data can be tracked by nominee. For issuers in Canada, generally vote
AGAINST a slate of nominees if one or more nominees fail the attendance Guideline, unless the Agent
cites compelling reasons for supporting the slate (e.g., the issuers commitment to replace slate
elections with individual elections within a year).
Consider self-nominated director candidates on a CASE-BY-CASE basis, with voting decisions
generally based on the Agents approach to evaluating such candidates, except that (1) an
unqualified candidate will generally not be supported simply to effect a protest vote and (2)
cases of multiple self-nominated candidates may be considered as a proxy contest if similar issues
are raised (e.g., potential change in control).
Generally vote FOR nominees without regard to over-boarding issues raised by the Agent unless
other concerns requiring CASE-BY-CASE consideration have been raised.
In cases where a director holds more than one board seat and corresponding votes, manifested as one
seat as a physical person plus an additional seat as a representative of a legal entity, generally
vote with the Agents recommendation to withhold support (AGAINST or ABSTAIN, as appropriate) from
the legal entity and vote on the physical person.
Generally, vote with the Agents recommendation to withhold support (AGAINST or ABSTAIN, as
appropriate) from nominees for whom support has become moot since the time the individual was
nominated (e.g., due to death, disqualification or determination not to accept appointment).
Generally, vote with the Agents recommendation when more candidates are presented than available
seats and no other provisions under these Guidelines apply.
Board Structure
Generally, vote FOR proposals to fix board size, but also support proposals seeking a board range
if the range is reasonable in the context of market practice and anti-takeover considerations.
Proposed article amendments in this regard shall be considered on a CASE-BY-CASE basis, with voting
decisions generally based on the Agents approach to evaluating such proposals.
Director and Officer Indemnification and Liability Protection
Generally, vote in accordance with the Agents standards for indemnification and liability
protection for officers and directors, voting AGAINST overly broad provisions.
45
Independent Statutory Auditors
With respect to Japanese companies that have not adopted the three-committee structure, vote
AGAINST any nominee to the position of independent statutory auditor whom the Agent considers
affiliated, e.g., if the nominee has worked a significant portion of his career for the company,
its main bank or one of its top shareholders. Where shareholders must vote on multiple nominees in
a single resolution, vote AGAINST all nominees. When multiple slates of statutory auditors are
presented, generally vote with the Agents recommendation, typically to support nominees deemed to
be more independent and/or aligned with interests of minority shareholders.
Generally, vote AGAINST incumbent nominees at companies implicated in scandals or exhibiting poor
internal controls.
Key Committees
Generally, except where market practice otherwise dictates, vote AGAINST proposals that permit
non-board members to serve on the audit, compensation or nominating committee, provided that
bundled slates may be supported if no slate nominee serves on the relevant committee(s). If not
otherwise addressed under these Guidelines, consider other negative recommendations from the Agent
regarding committee members on a CASE-BY-CASE basis.
Director and Statutory Auditor Remuneration
Consider director compensation plans on a CASE-BY-CASE basis, with voting decisions generally based
on the Agents approach to evaluating such proposals, while also factoring in the merits of the
rationale and disclosure provided.
Generally, vote FOR proposals to approve the remuneration of directors and auditors as long as the
amount is not excessive (e.g., significant increases should be supported by adequate rationale and
disclosure), there is no evidence of abuse, the recipients overall compensation appears
reasonable, and the board and/or responsible committee meets exchange or market standards for
independence.
For European issuers, vote AGAINST non-executive director remuneration if:
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The advance general meeting documents do not specify fees paid to
non-executive directors; |
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The company seeks to excessively increase the fees relative to market or
sector practices without providing a reasonable rationale for the increase; or |
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It provides for granting of stock options or similarly structured equity-based
compensation. |
For Toronto Stock Exchange (TSX) issuers, the Agents limits with respect to equity awards to
non-employee directors shall apply.
Bonus Payments
With respect to Japanese companies, generally follow the Agents guidelines on retirement and
annual bonus payments, which include voting FOR retirement bonus proposals if all payments are for
directors or auditors who have served as executives of the company and AGAINST such proposals if
any payments are for outsiders, except when deemed appropriate by the Agent, provided that no
payments shall be supported unless the individual or aggregate amounts are
46
disclosed. In all markets, if issues have been raised regarding a scandal or internal controls,
generally vote AGAINST bonus proposals for retiring directors or continuing directors or auditors
when culpability can be attributed to the nominee (e.g., if a Fund is also voting AGAINST the
nominee under criteria herein regarding issues of scandal or internal controls), unless bundled
with bonuses for a majority of directors or auditors a Fund is voting FOR.
Stock Option Plans for Independent Internal Statutory Auditors
With respect to Japanese companies, follow the Agents guidelines with respect to proposals
regarding option grants to independent internal statutory auditors or other outside parties,
generally voting AGAINST such plans.
Amendment Procedures for Equity Compensation Plans and ESPPs
For TSX issuers, votes with respect to amendment procedures for security-based compensation
arrangements and employee share purchase plans shall generally be cast in a manner designed to
preserve shareholder approval rights, with voting decisions generally based on the Agents
recommendation.
Compensation Plans and Shares Reserved for Equity Compensation Plans
Unless otherwise provided for herein, votes with respect to equity compensation plans (e.g.,
option, warrant, restricted stock or employee share purchase plans or participation in company
offerings such as IPOs or private placements) or awards thereunder, the issuance of shares in
connection with such plans, or related management proposals (e.g., article amendments), should be
determined on a CASE-BY-CASE basis, with voting decisions generally based on the Agents approach
to evaluating such proposals, considering quantitative or qualitative factors as appropriate for
the market and utilizing the Agents methodology, including classification of a companys stage of
development as growth or mature and the corresponding determination as to reasonability of the
share requests.
Generally, vote AGAINST proposals that:
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Exceed Agents recommended dilution limits, including cases in which the Agent
suggests dilution cannot be fully assessed (e.g., due to inadequate disclosure); |
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Provide deep or near-term discounts (or the equivalent, such as dividend
equivalents on unexercised options) to executives or directors, unless discounts to
executives are deemed by the Agent to be adequately mitigated by other requirements such as
long-term vesting or performance requirements (e.g., Japan) or broad-based employee
participation otherwise meeting the Agents standards (e.g., France); |
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Are administered with discretion by potential grant recipients, unless such
discretion is deemed acceptable due to market practice or other mitigating provisions; |
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Provide for retirement benefits or equity incentive awards to outside
directors if not in line with market practice (e.g., Australia, Belgium, The Netherlands); |
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Permit financial assistance in the form of non-recourse (or essentially
non-recourse) loans in connection with executives participation; |
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For matching share plans, do not meet the Agents standards, considering
holding period, discounts, dilution, participation, purchase price and performance
criteria; |
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Provide for vesting upon change in control if deemed to evidence a conflict of
interest or anti-takeover device or if the change in control definition is too liberal
(e.g., does not result in actual change in control); |
|
|
|
|
Provide no disclosure regarding vesting or performance criteria (provided that
proposals providing disclosure in one or both areas, without regard to Agents criteria for
such disclosure, shall be supported provided they otherwise satisfy these Guidelines); |
|
|
|
|
Permit post-employment vesting or exercise if deemed inappropriate by the
Agent; |
|
|
|
|
Allow plan administrators to make material amendments without shareholder
approval unless adequate prior disclosure has been provided, with such voting decisions
generally based on the Agents approach to evaluating such plans; |
|
|
|
|
Provide for contract or notice periods or severance/termination payments that
exceed market practice, e.g., relative to multiples of annual compensation; or |
|
|
|
|
Provide for retesting in connection with achievement of performance hurdles
unless the Agents analysis indicates that (1) performance targets are adequately increased
in proportion to the additional time available, (2) the retesting is de minimis as a
percentage of overall compensation or is acceptable relative to market practice, or (3) the
issuer has committed to cease retesting within a reasonable period of time. |
Generally, vote FOR such plans/awards or the related issuance of shares that (1) do not suffer from
the defects noted above or (2) otherwise meet the Agents tests if the considerations raised by the
Agent pertain primarily to performance hurdles, discretionary bonuses, recruitment awards,
retention incentives, non-compete payments or vesting upon change in control (other than addressed
above), if:
|
(1) |
|
The company has provided adequate disclosure and/or a reasonable rationale regarding
the relevant plan/award, practice or participation; |
|
|
(2) |
|
The recipients overall compensation appears reasonable; |
|
|
(3) |
|
Potential payments or awards are not so significant (individually or collectively) as
to potentially influence an executives decision-making (e.g., to enter into a transaction
that will result in a change of control payment) or to effectively act as a poison pill;
and |
|
|
(4) |
|
The board and/or responsible committee meets exchange or market standards for
independence. |
Unless otherwise provided for herein, market practice of the primary country in which a company
does business or competes for talent, or in which an employee is serving, as applicable, shall
supersede that of the issuers domicile.
Consider proposals in connection with such plans or the related issuance of shares in other
instances on a CASE-BY-CASE basis.
Remuneration Reports (Advisory Votes on Executive Compensation)
Generally, withhold support (AGAINST or ABSTAIN as appropriate for specific market and level of
concerns identified) from remuneration reports/advisory votes on compensation that include
compensation plans that:
|
(1) |
|
Permit practices or features not supported under these Guidelines, including financial
assistance under the conditions described above; |
48
|
(2) |
|
Permit retesting excessive relative to market practice (irrespective of the Agents
support for the report as a whole); |
|
|
(3) |
|
Cite long-term incentive plans deemed to be inadequately based on equity awards (e.g.,
cash-based plans or plans lacking an appropriate equity component); |
|
|
(4) |
|
Cite equity award valuation methods triggering a negative recommendation from the
Agent; |
|
|
(5) |
|
Include components, metrics or rationales that have not been disclosed in line with
market practice (although retrospective disclosure may be considered adequate); |
|
|
(6) |
|
For issuers in Australia, permit open market purchase of shares in support of equity
grants in lieu of seeking shareholder approval, but only if the issuer has a history of
significant negative votes when formally seeking approval for such grants; or |
|
|
(7) |
|
Include provisions for retirement benefits or equity incentive awards to outside
directors if not in line with market practice, except that reports will generally be voted
FOR if contractual components are reasonably aligned with market practices on a
going-forward basis (e.g., existing obligations related to retirement benefits or terms
contrary to evolving standards would not preclude support for the report). |
Reports receiving the Agents support and not triggering the concerns cited above will generally be
voted FOR. Unless otherwise provided for herein, reports not receiving the Agents support due to
concerns regarding severance/termination payments, leaver status, incentive structures and
vesting or performance criteria not otherwise supported by these Guidelines shall be considered on
a CASE-BY-CASE basis, generally voted FOR if:
|
(1) |
|
The company has provided a reasonable rationale and/or adequate disclosure regarding
the matter(s) under consideration; |
|
|
(2) |
|
The recipients overall compensation appears reasonable; and |
|
|
(3) |
|
The board and/or responsible committee meets exchange or market standards for
independence. |
Reports with typically unsupported features may be voted FOR when the Agent recommends their
initial support as the issuer or market transitions to better practices (e.g., having committed to
new regulations or governance codes).
Shareholder Proposals Regarding Executive and Director Pay
The Funds U.S. Guidelines with respect to such shareholder proposals shall apply.
General Share Issuances
Unless otherwise provided for herein, voting decisions shall generally be based on the Agents
practice to determine support for general issuance requests (with or without preemptive rights), or
related requests to repurchase and reissue shares, based on their amount relative to currently
issued capital, appropriate volume and duration parameters, and market-specific considerations
(e.g., priority right protections in France, reasonable levels of dilution and discount in Hong
Kong). Requests to reissue repurchased shares will not be supported unless a related general
issuance request is also supported.
Consider specific issuance requests on a CASE-BY-CASE basis based on the proposed use and the
companys rationale.
49
Generally, vote AGAINST proposals to issue shares (with or without preemptive rights), convertible
bonds or warrants, to grant rights to acquire shares, or to amend the corporate charter relative to
such issuances or grants when concerns have been identified by the Agent with respect to inadequate
disclosure, inadequate restrictions on discounts, failure to meet the Agents standards for general
issuance requests, or authority to refresh share issuance amounts without prior shareholder
approval.
Generally, vote AGAINST nonspecific proposals authorizing excessive discretion to a board.
Increases in Authorized Capital
Unless otherwise provided for herein, voting decisions should generally be based on the Agents
approach, as follows. Generally:
|
|
|
Vote FOR nonspecific proposals, including bundled proposals, to increase
authorized capital up to 100 percent over the current authorization unless the increase
would leave the company with less than 30 percent of its new authorization outstanding. |
|
|
|
|
Vote FOR specific proposals to increase authorized capital, unless: |
|
§ |
|
The specific purpose of the increase (such as a share-based acquisition or
merger) does not meet these Guidelines for the purpose being proposed; or |
|
|
§ |
|
The increase would leave the company with less than 30 percent of its new
authorization outstanding after adjusting for all proposed issuances. |
|
|
|
Vote AGAINST proposals to adopt unlimited capital authorizations. |
|
|
|
|
The Agents market-specific exceptions to the above parameters shall be
applied. |
Preferred Stock
Unless otherwise provided for herein, voting decisions should generally be based on the Agents
approach, including:
|
|
|
Vote FOR the creation of a new class of preferred stock or issuances of
preferred stock up to 50 percent of issued capital unless the terms of the preferred stock
would adversely affect the rights of existing shareholders. |
|
|
|
|
Vote FOR the creation/issuance of convertible preferred stock as long as the
maximum number of common shares that could be issued upon conversion meets the Agents
guidelines on equity issuance requests. |
|
|
|
|
Vote AGAINST the creation of (1) a new class of preference shares that would
carry superior voting rights to the common shares or (2) blank check preferred stock unless
the board states that the authorization will not be used to thwart a takeover bid. |
Poison Pills/Protective Preference Shares
Generally, vote AGAINST management proposals in connection with poison pills or anti-takeover
activities (e.g., disclosure requirements or issuances, transfers or repurchases) that do not meet
the Agents standards. Generally vote in accordance with Agents recommendation to withhold
support from a nominee in connection with poison pill or anti-takeover considerations when
responsibility for the actions can be reasonably attributed to the nominee. Generally DO NOT VOTE
AGAINST director remuneration in connection with poison pill considerations raised by the Agent.
50
Waiver on Tender-Bid Requirement
Generally, consider proposals on a CASE-BY-CASE basis seeking a waiver for a major shareholder from
the requirement to make a buyout offer to minority shareholders, voting FOR when little concern of
a creeping takeover exists and the company has provided a reasonable rationale for the request.
Approval of Financial Statements and Director and Auditor Reports
Generally, vote FOR management proposals seeking approval of financial accounts and reports, unless
there is concern about the companys financial accounts and reporting, which, in the case of
related party transactions, would include concerns raised by the Agent regarding consulting
agreements with non-executive directors but not severance/termination payments exceeding the
Agents standards for multiples of annual compensation, provided the recipients overall
compensation appears reasonable and the board and/or responsible committee meets exchange or market
standards for independence. Unless otherwise provided for herein, reports not receiving the
Agents support due to other concerns regarding severance/termination payments not otherwise
supported by these Guidelines shall be considered on a CASE-BY-CASE basis, factoring in the merits
of the rationale or disclosure provided and generally voted FOR if the overall compensation package
and/or program at issue appears reasonable. Generally, vote AGAINST board-issued reports receiving
a negative recommendation from the Agent due to concerns regarding independence of the board or the
presence of non-independent directors on the audit committee. However, generally do not withhold
support from such proposals in connection with remuneration practices otherwise supported under
these Guidelines or as a means of expressing disapproval of broader practices of the issuer or its
board.
Remuneration of Auditors
Generally, vote FOR proposals to authorize the board to determine the remuneration of auditors,
unless there is evidence of excessive compensation relative to the size and nature of the company.
Indemnification of Auditors
Generally, vote AGAINST proposals to indemnify auditors.
Ratification of Auditors and Approval of Auditors Fees
For Canadian issuers, the Funds U.S. Guidelines with respect to auditors and auditor fees shall
apply.
For other markets, generally, follow the Agents standards for proposals seeking auditor
ratification or approval of auditors fees, which generally indicate a vote FOR such proposals if
the level of disclosure and independence meet the Agents standards. However, if fees for
non-audit services (excluding significant, one-time events) exceed 50 percent of total auditor
fees, consider on a CASE-BY-CASE basis, and vote FOR ratification of auditors or approval of
auditors fees if it appears that remuneration for the non-audit work is not so lucrative as to
taint the auditors independence.
In other cases, generally vote FOR such proposals unless there are material concerns raised by the
Agent about the auditors practices or independence.
51
Audit Commission
Consider nominees to the audit commission on a CASE-BY-CASE basis, with voting decisions generally
based on the Agents approach to evaluating such candidates.
Allocation of Income and Dividends
With respect to Japanese companies, consider management proposals concerning allocation of income
and the distribution of dividends, including adjustments to reserves to make capital available for
such purposes, on a CASE-BY-CASE basis, generally voting with the Agents recommendations to
support such proposals unless:
|
§ |
|
The dividend payout ratio has been consistently below 30 percent without
adequate explanation; or |
|
|
§ |
|
The payout is excessive given the companys financial position. |
Generally vote FOR such proposals by issuers in other markets. In any markets, in the event
management offers multiple dividend proposals on the same agenda, primary consideration shall be
given to input from the relevant Investment Professional(s) and voted with the Agents
recommendation if no input is received.
Stock (Scrip) Dividend Alternatives
Generally, vote FOR most stock (scrip) dividend proposals, but vote AGAINST proposals that do not
allow for a cash option unless management demonstrates that the cash option is harmful to
shareholder value.
Debt Instruments
Generally, vote AGAINST proposals authorizing excessive discretion to a board to issue or set terms
for debt instruments (e.g., commercial paper).
Debt Issuance Requests
When evaluating a debt issuance request, the issuing companys present financial situation is
examined. The main factor for analysis is the companys current debt-to-equity ratio, or gearing
level. A high gearing level may incline markets and financial analysts to downgrade the companys
bond rating, increasing its investment risk factor in the process. A gearing level up to 100
percent is considered acceptable.
Generally, vote FOR debt issuances for companies when the gearing level is between zero and 100
percent. Review on a CASE-BY-CASE basis proposals where the issuance of debt will result in the
gearing level being greater than 100 percent, or for which inadequate disclosure precludes
calculation of the gearing level, comparing any such proposed debt issuance to industry and market
standards, and with voting decisions generally based on the Agents approach to evaluating such
requests.
52
Financing Plans
Generally, vote FOR the adoption of financing plans if they are in the best economic interests of
shareholders.
Related Party Transactions
Consider related party transactions on a CASE-BY-CASE basis. Generally, vote FOR approval of such
transactions unless the agreement requests a strategic move outside the companys charter or
contains unfavorable or high-risk terms (e.g., deposits without security interest or guaranty).
Approval of Donations
Generally, vote AGAINST such proposals unless adequate, prior disclosure of amounts is provided; if
so, single- or multi-year authorities may be supported.
Capitalization of Reserves
Generally, vote FOR proposals to capitalize the companys reserves for bonus issues of shares or to
increase the par value of shares.
Investment of Company Reserves
These proposals should generally be analyzed on a CASE-BY-CASE basis, with primary consideration
given to input from the Investment Professional(s) for a given Fund.
Article Amendments
Review on a CASE-BY-CASE basis all proposals seeking amendments to the articles of association.
Generally, vote FOR an article amendment if:
|
|
|
It is editorial in nature; |
|
|
|
|
Shareholder rights are protected; |
|
|
|
|
There is negligible or positive impact on shareholder value; |
|
|
|
|
Management provides adequate reasons for the amendments or the Agent otherwise
supports managements position; |
|
|
|
|
It seeks to discontinue and/or delist a form of the issuers securities when
the relevant Fund does not hold the affected security type; or |
|
|
|
|
The company is required to do so by law (if applicable). |
Generally, vote AGAINST an article amendment if:
|
|
|
It removes or lowers quorum requirements for board or shareholder meetings
below levels recommended by the Agent; |
|
|
|
|
It reduces relevant disclosure to shareholders; |
|
|
|
|
It seeks to align the articles with provisions of another proposal not
supported by these Guidelines; |
|
|
|
|
It is not supported under these Guidelines, is presented within a bundled
proposal, and the negative impact, on balance, outweighs any positive impact; or |
53
|
|
|
It imposes a negative impact on existing shareholder rights, including rights
of the Funds, or diminishes accountability to shareholders to the extent that any positive
impact would not be deemed to be sufficient to outweigh removal or diminution of such
rights. |
With respect to article amendments for Japanese companies:
|
|
|
Generally vote FOR management proposals to amend a companys articles to
expand its business lines. |
|
|
|
|
Generally vote FOR management proposals to amend a companys articles to
provide for an expansion or reduction in the size of the board, unless the
expansion/reduction is clearly disproportionate to the growth/decrease in the scale of the
business or raises anti-takeover concerns. |
|
|
|
|
If anti-takeover concerns exist, generally vote AGAINST management proposals,
including bundled proposals, to amend a companys articles to authorize the Board to vary
the annual meeting record date or to otherwise align them with provisions of a takeover
defense. |
|
|
|
|
Generally follow the Agents guidelines with respect to management proposals
regarding amendments to authorize share repurchases at the boards discretion, voting
AGAINST proposals unless there is little to no likelihood of a creeping takeover (major
shareholder owns nearly enough shares to reach a critical control threshold) or constraints
on liquidity (free float of shares is low), and where the company is trading at below book
value or is facing a real likelihood of substantial share sales; or where this amendment is
bundled with other amendments which are clearly in shareholders interest. |
Other Business
In connection with global proxies, vote in accordance with the Agents market-specific
recommendations on management proposals for Other Business, generally AGAINST.
54
ING Global Advantage &
Premium Opportunity Fund
Item 8. Fund Managers of Closed-End Management Investment Companies.
(a) (1) Fund Management. The following individuals share responsibility for the day-to-day
management of the Funds Fund:
Overall Strategy and Asset Allocation
Vincent Costa, CFA, Senior Vice President and Head of
Portfolio Management of Quantitative Equity, joined ING IM in April
2006 as Head of Portfolio Management of quantitative equity. Prior to joining ING IM he was with Merrill Lynch Investment Management, where he worked for 7 years in quantitative equity leadership positions, including managing director and head of their quantitative investments organization.
Domestic Option Strategy
Paul Zemsky. Mr. Zemsky is currently Head of Derivative Strategies for ING IM. Mr. Zemsky, along
with Ernie Tang, will be jointly and primarily responsible for the structure and implementation of
the Funds U.S. domestic index option strategy. As Head of Derivative Strategies, Mr. Zemsky
oversees derivative strategies for credit, interest rate, and equity products, and supports the
organization on a number of key areas, including product development and risk management for both
proprietary and third party businesses. This includes hedging and overlay strategies, as well as
focusing on new business development opportunities. A key function within his scope of
responsibility is developing macro hedging strategies for variable and equity index annuities sold
through various ING businesses. Mr. Zemsky joined ING IM in 2005 after 18 years at J.P. Morgan
Investment Management, where he held a number of key positions, including having responsibility for
the market timing and sector allocation for the firms fixed income business and handling option
trading in both the exchange-traded and over-the-counter markets. Most recently, Mr. Zemsky
co-founded CaliberOne Private Funds Management, a macro hedge fund. Mr. Zemsky holds a dual degree
in finance and electrical engineering from the Management and Technology Program at the University of Pennsylvania.
Jody I. Hrazanek. Ms. Hrazanek joined ING IM in October 2005. She has 12 years of investment
related experience. In her current role she is a derivatives trader with responsibility for ING
IMs third-party business as well as ING IMs insurance general account. She will be primarily
responsible for implementing the Funds collar strategy through its put option purchasing and call
option writing activities. Prior to joining ING IM, she was a convertible bond trader at Advent
Capital Management from 2003 to 2005. She had previously been a convertible bond and risk arbitrage
trader at Merrill Lynch Quantitative Advisors from 1999 to 2003 and Deutsche Bank Asset Management
from 1996 to 1999 as well as an analyst at Goldman Sachs from 1994 to 1996. Ms. Hrazanek graduated summa cum laude from Fairfield University with a Bachelor of Science
in mathematics and received a Master of Science in statistics and operations research from New York
University.
International Equity and Option Strategy
Frank van Etten. Mr. Van Etten is currently an Investment Manager of Structured Products and
joined IIM Europe in 2002. In this capacity he is responsible for managing a range of structured
products and the execution of transactions in the derivatives portfolios. Furthermore Mr. Van Etten
also carries out research in structured products development and option strategies and markets. Mr.
Van Etten obtained his Masters
degree in econometrics from Tilburg University in 2003, specializing in quantitative finance.
55
Frank
Van Etten. Mr. Van Etten
is currently an Investment Manager of Structured Products and began his career at ING, joining
the firm in 2002. Mr. Van
Etten will be primarily responsible for implementation of the Funds international index option strategy.
In this capacity he is responsible for managing a range of structured products
and the execution of transactions in the derivatives Funds. Furthermore Mr. Van Etten also carries out research
in structured products development and option strategies and markets. Mr. Van Etten
obtained his Masters degree in econometrics from Tilburg University
in 2003, specializing in quantitative finance.
Pranay
Gupta, CFA
As Chief Investment Officer for ING Investment Management Asia
Pacific, Pranay is responsible for overseeing US$85bn in institutional,
retail and insurance assets. Pranay joined ING in 2009 from
the Pearl Group, U.K. where he was Deputy Chief Investment
Officer and a Member of the Board from 2006-2009. At Pearl,
Pranay was responsible for the overall framework for strategy and asset allocation and investment risk analytics
for the $55bn portfolio, and also managed the $3bn Systematic
Strategies Fund a multi strategy hedge fund of funds. From 2002 to
2006, Pranay was the Head of Global Quantitative Strategies at ABP Investments, Netherlands,
managing a $24bn quantitative multi-strategy fund. In his previous
positions as Chief Investment Strategist for Asia for Societe Generale and Head of Quantitative
Research for JP Morgan Chase Investment Management, New York, Pranay
researched quantitative investment processes, and managed investment teams in Asia,
Japan, Europe and the US. Pranay holds a
Bachelors degree in Mechanical Engineering specializing in Computer Aided Design, an
MBA in Finance, and is a CFA charter holder. Pranay
has nineteen years of experience in investment management, having worked in the
financial industry in Europe, UK, US and Asia.. Pranay holds
a Bachelors degree in Mechanical Engineering specializing in Computer Aided Design, an
MBA in Finance, and is a CFA charter holder. Pranay has
nineteen years of experience in investment management, having worked in the
financial industry in Europe, UK, US and Asia.
(a) (2) (i-iii) Other Accounts Managed
The
following table shows the number of accounts and total assets in the accounts managed by
the Fund managers of the Sub-Adviser as of February 28, 2011,
unless otherwise noted:
|
|
|
|
|
|
|
|
|
ING
Global |
|
|
|
Mutual Funds |
|
Trusts, Sep Accts and Stable Value |
|
|
Advantage and Premium |
|
|
|
Registered Investment Companies |
|
Other Pooled Investment Vehicles and Alternative |
|
Other Accounts, IIM Managed |
Opportunity
|
|
Portfolio |
|
Number of Accts / Total Assets |
|
Number of Accts / Total Assets (rounded to nearest |
|
Number of Accts / Total Assets |
Fund (IGA) |
|
Manager |
|
(rounded to nearest million) |
|
million) |
|
(rounded to nearest million) |
IIM Portion
|
|
Paul Zemsky
|
|
41/$18,799
|
|
12/$960
|
|
0/$0 |
|
|
Jody I. Hrazanek
|
|
2/$499
|
|
0/$0
|
|
0/$0 |
|
|
Vincent Costa
|
|
30/$14,050
|
|
10/$2,040
|
|
0/$0 |
|
|
Pranay Gupta
|
|
9/$2,800
|
|
17/$2,660
|
|
0/$0 |
|
|
Frank van Etten
|
|
2/$160
|
|
0/$0
|
|
0/$0 |
56
(a) (2) (iv) Conflicts of Interest
A portfolio manager may be subject to potential conflicts of interest because the
portfolio manager is responsible for other accounts in addition to a Fund. These other accounts
may include, among others, other mutual funds, separately managed advisory accounts, commingled
trust accounts, insurance separate accounts, wrap fee programs and hedge funds. Potential
conflicts may arise out of the implementation of differing investment strategies for the portfolio
managers various accounts, the allocation of investment opportunities among those accounts or
differences in the advisory fees paid by the portfolio managers accounts.
A potential conflict of interest may arise as a result of the portfolio managers
responsibility for multiple accounts with similar investment guidelines. Under these
circumstances, a potential investment may be suitable for more than one of the portfolio managers
accounts, but the quantity of the investment available for purchase is less than the aggregate
amount the accounts would ideally devote to the opportunity. Similar conflicts may arise when
multiple accounts seek to dispose of the same investment.
A portfolio manager may also manage accounts whose objectives and policies differ from that of
the Fund. These differences may be such that under certain circumstances, trading activity
appropriate for one account managed by the portfolio manager may not be appropriate for the Fund.
For example, if an account were to sell a significant position in a security, which could cause the
market price of that security to decrease, while the Fund maintained its position in that security.
A potential conflict may arise when a portfolio manager is responsible for accounts that have
different advisory fees the difference in the fees may create an incentive for the portfolio
manager to favor one account over another, for example, in terms of access to particularly
appealing investment opportunities. This conflict may be heightened where an account is subject to
a performance-based fee.
As part of its compliance program, ING IM has adopted policies and procedures reasonably designed
to address the potential conflicts of interest described above.
Finally, a potential conflict of interest may arise because the investment mandates for
certain other accounts, such as hedge funds, may allow extensive use of short sales, which, in
theory, could allow them to enter into short positions in securities where other accounts hold long
positions. ING IM has policies and procedures reasonably designed to limit and monitor short sales
by the other accounts to avoid harm to the Fund.
(a) (3) Compensation
For each of the portfolio managers (each a Portfolio Manager and collectively the Portfolio
Managers) of the Portfolios listed above, compensation consists of (a) fixed base
salary; (b) bonus which is based on ING IM performance, one and three year pre-tax
performance of the accounts the portfolio managers are primarily and jointly responsible for
relative to account benchmarks and peer universe performance, and revenue growth of the accounts
they are responsible for; and, in certain instances, (c) long-term equity awards tied to the
performance of the parent company, ING Groep.
The Portfolio Managers for the Portfolios listed above are also eligible to participate in an
annual cash incentive plan. The overall design of the annual incentive plan was developed to tie
pay to both performance and cash flows, structured in such a way as to drive performance and
57
promote retention of top talent. As with base salary compensation, individual target awards are
determined and set based on external market data and internal comparators. Investment performance
is measured on both relative and absolute performance in all areas. Relevant indices include the
MSCI World Index and the MSCI Europe Index. Relevant peer groups include Morningstar global equity
funds in the Netherlands and the rest of Europe. The measures for each team are outlined on a
scorecard that is reviewed on an annual basis. These scorecards measure investment performance
versus peer groups over one- and three-year periods and year-to-date net cash flow (changes in the
accounts net assets not attributable to changes in the value of the accounts investments) for all
accounts managed by each team. The results for overall ING IM scorecards are calculated on an
asset weighted performance basis of the individual team scorecards.
Investment professionals performance measures for bonus determinations are weighted by 25%
being attributable to the overall ING IM performance and 75% attributable to their specific team
results (60% investment performance and 15% net cash flow).
Based on job function, internal comparators and external market data, portfolio managers
participate in the ING Long-Term Incentive Plan. Plan awards are based on the current years
performance as defined by the ING IM component of the annual incentive plan. The awards vest in
three years and are paid in a combination of ING restricted stock, stock options and restricted
performance units.
Portfolio Managers whose base salary compensation exceeds a particular threshold may
participate in ING IMs deferred compensation plan. The plan provides an opportunity to invest
deferred amounts of compensation in mutual funds, ING IM stock or at an annual fixed interest rate.
Deferral elections are done on an annual basis and the amount of compensation deferred is
irrevocable.
(a) (4) Ownership of Securities
Ownership:
|
|
|
Portfolio Manager |
|
Dollar Range of Trust Shares Owned |
Paul Zemsky
|
|
Over $100,000 |
Jody I. Hrazanek
|
|
None |
Vincent Costa
|
|
None |
Pranay Gupta
|
|
None |
Frank van Etten
|
|
None |
58
Item 9. Purchases of Equity Securities by Closed-End Management Investment Company and
Affiliated Purchasers
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(a) |
|
(b) |
|
(c) |
|
(d)* |
|
|
TOTAL NUMBER |
|
AVERAGE |
|
TOTAL NUMBER OF SHARES |
|
MAXIMUM NUMBER (OR APPROXIMATE DOLLAR VALUE) |
|
|
OF SHARES (OR |
|
PRICE PAID |
|
(OR UNITS) PART OF PUBLICLY |
|
OF SHARES (OR UNITS) THAT MAY YET BE |
|
|
UNITS) |
|
PER SHARE (OR |
|
ANNOUNCED PLANS OR |
|
PURCHASED UNDER THE PLANS |
Period* |
|
PURCHASED |
|
UNIT) |
|
PROGRAMS |
|
OR PROGRAMS |
MARCH 1-31, 2009 |
|
|
153,044 |
|
|
$ |
9.30 |
|
|
|
1,106,116 |
|
|
|
1,669,956 |
|
APRIL 1-30, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
MAY 1-31, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
JUNE 1-30, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
JULY 1-31, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
AUGUST 1-31, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
SEPTEMBER 1-30, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
OCTOBER 1-31, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
NOVEMBER 1-30, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
DECEMBER 1-31, 2009 |
|
|
0 |
|
|
|
|
|
|
|
0 |
|
|
|
1,669,956 |
|
JANUARY 1-31, 2010** |
|
|
n/a |
|
|
|
n/a |
|
|
|
n/a |
|
|
|
n/a |
|
FEBRUARY 1-28, 2010** |
|
|
n/a |
|
|
|
n/a |
|
|
|
n/a |
|
|
|
n/a |
|
TOTAL |
|
|
153,044 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
* |
|
The Registrants repurchase program, which authorized the repurchase of 1,823,000 shares, was announced on December 5, 2008.
Any repurchases made by the registrant pursuant to the program were made through open-market transactions. |
|
** |
|
The repurchase program expired on December 31, 2009 |
Item 10. Submission of Matters to a Vote of Security Holders.
The Board has a Nominating Committee for the purpose of considering and presenting to the Board
candidates it proposes for nomination to fill Independent Trustee vacancies on the Board. The
Committee currently consists of all Independent Trustees of the Board (6 individuals). The
Nominating Committee operates pursuant to a Charter approved by the Board. The primary purpose of
the Nominating Committee is to consider and present to the Board the candidates it proposes for
nomination to fill vacancies on the Board. In evaluating candidates, the Nominating Committee may
consider a variety of factors, but it has not at this time set any specific minimum qualifications
that must be met. Specific qualifications of candidates for Board membership will be based on the
needs of the Board at the time of nomination.
The Nominating Committee is willing to consider nominations received from shareholders and shall
assess shareholder nominees in the same manner as it reviews its own nominees. A shareholder
nominee for director should be submitted in writing to the Funds Secretary. Any such shareholder
nomination should include at a minimum the following information as to each individual proposed for
nomination as trustee: such individuals written consent to be named in the proxy statement as a
nominee (if nominated) and to serve as a trustee (if elected), and all information relating to such
individual that is required to be disclosed in the solicitation of proxies for election of
trustees, or is otherwise required, in each case under applicable federal securities laws, rules
and regulations.
The Secretary shall submit all nominations received in a timely manner to the Nominating Committee.
To be timely, any such submission must be delivered to the Funds Secretary not earlier than the
90th day prior to such meeting and not later than the close of business on the later of
the 60th day prior to such meeting or the 10th day following the day on which
public announcement of the date of the meeting is first made, by either disclosure in a press
release or in a document publicly filed by the Fund with the Securities and Exchange Commission.
Item 11. Controls and Procedures.
(a) |
|
Based on our evaluation conducted within 90 days of the filing date, hereof, the design and
operation of the registrants disclosure controls and procedures are effective to ensure that
material information relating to the registrant is made known to the certifying officers by
others within the appropriate entities, particularly during the period in which Forms N-CSR
are being prepared, and the registrants disclosure controls and procedures allow timely
preparation and review of the information for the registrants Form N-CSR and the officer
certifications of such Form N-CSR. |
(b) |
|
There were no significant changes in the registrants internal controls that occurred during
the second fiscal quarter of the period covered by this report that has materially affected,
or is reasonably likely to materially affect, the registrants internal control over financial
reporting. |
Item 12. Exhibits.
(a)(1) |
|
Code of Ethics pursuant to Item 2 of Form N-CSR is filed and attached hereto as
EX-99.CODE ETH. |
|
(a)(2) |
|
A separate certification for each principal executive officer and principal financial
officer of the registrant as required by Rule 30a-2 under the Act (17 CFR 270.30a-2) is
attached hereto as EX-99.CERT. |
|
(b) |
|
The officer certifications required by Section 906 of the Sarbanes-Oxley Act of 2002
are attached hereto as EX-99.906CERT. |
|
(3) |
|
Not applicable. |
59
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act
of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned,
thereunto duly authorized.
(Registrant):
ING Global Advantage and Premium Opportunity Fund
|
|
|
|
|
By
|
|
/s/ Shaun P. Mathews
Shaun P. Mathews
|
|
|
|
|
President and Chief Executive Officer |
|
|
Date:
May 5, 2011
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act
of 1940, this report has been signed below by the following persons on behalf of the registrant
and in the capacities and on the dates indicated.
|
|
|
|
|
By
|
|
/s/ Shaun P. Mathews
Shaun P. Mathews
|
|
|
|
|
President and Chief Executive Officer |
|
|
|
|
|
|
|
Date: May 5, 2011 |
|
|
|
|
|
|
|
By
|
|
/s/ Todd Modic
|
|
|
|
|
Todd Modic |
|
|
|
|
Senior Vice President and Chief Financial Officer |
Date:
May 5, 2011
60