0001145443-13-001774 Sample Contracts

FORM OF INVESTMENT MANAGEMENT AGREEMENT ING VARIABLE FUNDS
Investment Management Agreement • August 29th, 2013 • Ing Variable Funds • New York

AGREEMENT dated May 7, 2013, between ING Variable Funds (the “Trust”), a Massachusetts business trust, and ING Investments, LLC (the “Adviser”), a limited liability company organized and existing under the laws of the State of Arizona (the “Agreement”).

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FORM OF SUB-ADVISORY AGREEMENT ING VARIABLE FUNDS
Sub-Advisory Agreement • August 29th, 2013 • Ing Variable Funds • New York

AGREEMENT dated May 7, 2013, between ING Investments, LLC, an Arizona limited liability company (the “Manager”), and ING Investment Management Co. LLC, a Delaware limited liability company (the “Sub-Adviser”).

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ITEM 77Q-1 – Exhibits
Investment Management Agreement • August 29th, 2013 • Ing Variable Funds
Sample 1
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