Voya Investment Management (Uk) Limited

Allegations: MR. GRANOFF/ MS. JANIS IS A DIRECTOR OF ING POMONA PRIVATE EQUITY FUND (THE "FUND"), A CLOSED-END INVESTMENT FUND ORGANIZED AS A FUND-OF-FUNDS UNDER THE LAWS OF LUXEMBOURG. ON JUNE 10, 2013, THE LUXEMBOURG COMMISSION DE SURVEILLANCE DU SECTOR FINANCIER ("CSSF") ISSUED AN ORDER FINDING THAT THE ANNUAL FINANCIAL STATEMENTS FOR THE FUND FOR THE FISCAL YEAR ENDED DECEMBER 31, 2012 HAD NOT BEEN FILED WITH THE CSSF ON A TIMELY BASIS. THE ORDER IMPOSED AN ADMINISTRATIVE FINE OF 2,000 EUROS ON MR. GRANOFF/MS. JANIS. THERE HAVE BEEN NO ALLEGATIONS OF INDIVIDUAL WRONGDOING BY MR, GRANOFF/MS. JANIS OR ANY OTHER DIRECTOR OF THE FUND. Status: Final Sanction Detail: 2000 EUROS; PAID BY THE FUND Summary: THIS IS A FUND IN WIND DOWN MODE THAT IS OVER TEN YEARS OLD. MR. GRANOFF/MS. JANIS SERVES AS A DIRECTOR OF THE FUND. THE PREPARATION AND FILING OF THE FUND'S ANNUAL FINANCIAL REPORTS IS HANDLED BY THE FUND'S LUXEMBOURG-BASED MANAGER AND ADMINISTRATOR. MR. GRANOFF/MS. JANIS AND THE FUND'S OTHER DIRECTORS ARE NOT ENGAGED IN THE DAY TO DAY ADMINISTRATION OF THE FUND AND HAVE NO ROLE IN THE PREPARATION OF THE FUND'S ANNUAL REPORTS. THERE HAVE BEEN NO ALLEGATIONS OF INDIVIDUAL WRONGDOING BY MR. GRANOFF/MS. JANIS OR ANY OTHER DIRECTOR OF THE FUND. ALSO, AS A FUND-OF-FUNDS, THE FUND MUST RECEIVE FINANCIAL STATEMENTS FROM ITS UNDERLYING PORTFOLIO FUNDS IN ORDER TO COMPLETE ITS OWN FINANCIAL REPORT. THE FUND HAS NO CONTROL OVER THE TIMING OF THE RECEIPT OF THE UNDERLYING FINANCIAL STATEMENTS. ASIDE FROM PAYMENT OF THE ADMINISTRATIVE FINE OF 2,000 EUROS, THERE HAVE BEEN NO OTHER TERMS, CONDITIONS, RESTRICTIONS OR OTHER SANCTIONS IMPOSED ON MR. GRANOFF/MS. JANIS.