Strategic importance as a subsidiary of the ING Group. Very strong capitalization and stable earnings performance. Investment portfolio comprised of sound assets. Ratings and outlook on ING Life are capped by those on core insurance operating entities within the ING Group. Uncertainty over further business expansion in the small and midsize enterprise (SME) market due to intensifying competition. Japan-based ING Life Insurance Co. Ltd. is a key subsidiary of the ING Group, a global financial services conglomerate. Japan is considered one of the most important insurance markets for the group, particularly given the potential for asset-accumulation type business. ING Life has maintained and developed its competitive niche positions, mainly focusing on SME and high net worth (HNW) markets through the