0001145443-13-002045 Sample Contracts

SUB-ADVISORY AGREEMENT ING ASIA PACIFIC HIGH DIVIDEND EQUITY INCOME FUND

Sub-Advisory Agreement • October 29th, 2013 • ING Asia Pacific High Dividend Equity Income Fund • New York

• Contract Type
  Sub-Advisory Agreement
• Filed
  October 29th, 2013
• Company
  ING Asia Pacific High Dividend Equity Income Fund
• Jurisdiction
  New York

AGREEMENT dated May 6, 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”).

INVESTMENT MANAGEMENT AGREEMENT ING ASIA PACIFIC HIGH DIVIDEND EQUITY INCOME FUND

Investment Management Agreement • October 29th, 2013 • ING Asia Pacific High Dividend Equity Income Fund • New York

• Contract Type
  Investment Management Agreement
• Filed
  October 29th, 2013
• Company
  ING Asia Pacific High Dividend Equity Income Fund
• Jurisdiction
  New York

AGREEMENT dated May 7, 2013, between ING Asia Pacific High Dividend Equity Income Fund (the “Fund”), a Delaware statutory trust, and ING Investments, LLC (the “Adviser”), a limited liability company organized and existing under the laws of the State of Arizona (the “Agreement”).

ITEM 77Q1– Exhibits

Investment Management Agreement • October 29th, 2013 • ING Asia Pacific High Dividend Equity Income Fund

• Contract Type
  Investment Management Agreement
• Filed
  October 29th, 2013
• Company
  ING Asia Pacific High Dividend Equity Income Fund