0001193125-08-162764 Sample Contracts

Exhibit (g)(1)(i)
Custody Agreement • July 31st, 2008 • ING Separate Portfolios Trust

Pursuant to the terms and conditions of the Custody Agreement, Foreign Custody Manager Agreement, Fund Accounting Agreement, Custody & Fund Accounting Fee Schedule and Global Securities Fee Schedule, each dated January 6, 2003, and the Cash Reserve Agreement dated March 31, 2003 (the “Agreements”), we hereby notify you of the addition of ING Van Kampen Global Tactical Asset Allocation Portfolio, a newly established series of ING Investors Trust, ING Corporate Leaders 100 Fund, a new series of ING Series Fund, Inc., ING Russell™ Global Large Cap Index 85% Portfolio, and ING Global Equity Option Portfolio, each a newly established series of ING Variable Portfolios, Inc. (collectively, the “Portfolios”) to be included on the Amended Exhibit A to the Agreements as shown. This Amended Exhibit A supersedes the previous Amended Exhibit A dated April 28, 2008.

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Exhibit (h)(2)(i)
Agency Agreement • July 31st, 2008 • ING Separate Portfolios Trust
Exhibit (g)(3)(i)
Custody Agreement • July 31st, 2008 • ING Separate Portfolios Trust

Pursuant to the terms and conditions of the Custody Agreement, Foreign Custody Manager Agreement, Fund Accounting Agreement, Custody & Fund Accounting Fee Schedule and Global Securities Fee Schedule, each dated January 6, 2003, and the Cash Reserve Agreement dated March 31, 2003 (the “Agreements”), we hereby notify you of the addition of ING Van Kampen Global Tactical Asset Allocation Portfolio, a newly established series of ING Investors Trust, ING Corporate Leaders 100 Fund, a new series of ING Series Fund, Inc., ING Russell™ Global Large Cap Index 85% Portfolio, and ING Global Equity Option Portfolio, each a newly established series of ING Variable Portfolios, Inc. (collectively, the “Portfolios”) to be included on the Amended Exhibit A to the Agreements as shown. This Amended Exhibit A supersedes the previous Amended Exhibit A dated April 28, 2008.

INVESTMENT MANAGEMENT AGREEMENT
Investment Management Agreement • July 31st, 2008 • ING Separate Portfolios Trust • Delaware

Agreement dated May 16, 2007, between ING Separate Portfolios Trust (the “Trust”), a Delaware statutory trust, and ING Investment Management Co. (the “Manager”), a Connecticut corporation (the “Agreement”).

UNDERWRITING AGREEMENT ING SEPARATE PORTFOLIOS TRUST Scottsdale, Arizona 85258
Underwriting Agreement • July 31st, 2008 • ING Separate Portfolios Trust • Arizona

ING SEPARATE PORTFOLIOS TRUST is a Delaware statutory trust operating as an open-end management investment company (hereinafter referred to as the “Trust”). The Trust is registered as such under the Investment Company Act of 1940, as amended (the “1940 Act”), and its shares are registered under the Securities Act of 1933, as amended (the “1933 Act”). The Trust, on behalf of each of the series listed on Schedule A hereto, which may be amended from time to time by ING Funds Distributor, LLC (each a “Fund,” collectively the “Funds”), desires to offer and sell the authorized but unissued shares of the Funds to the public in accordance with applicable federal and state securities laws.

EXPENSE LIMITATION AGREEMENT ING Separate Portfolios Trust
Expense Limitation Agreement • July 31st, 2008 • ING Separate Portfolios Trust

This EXPENSE LIMITATION AGREEMENT (this “Agreement”), effective this 16th day of May, 2007, is made by and between ING Investment Management Co. (the “Investment Manager”) and ING Separate Portfolios Trust (the “Registrant”). The Registrant is a series fund investment company, and is entering into this Agreement on behalf of, and this Agreement shall apply to, each series of the Registrant set forth on Schedule A hereto (each a “Fund,” collectively the “Funds”), as such schedule may be amended from time to time to add or delete series.

ADMINISTRATION AGREEMENT
Administration Agreement • July 31st, 2008 • ING Separate Portfolios Trust • Delaware

THIS AGREEMENT made this 16th day of May, 2007, between ING SEPARATE PORTFOLIOS TRUST (the “Trust”), a Delaware statutory trust, and ING Funds Services, LLC (the “Administrator”), a limited liability company organization under the laws of Delaware.

Exhibit (g)(2)(i)
Custody Agreement • July 31st, 2008 • ING Separate Portfolios Trust

Pursuant to the terms and conditions of the Custody Agreement, Foreign Custody Manager Agreement, Fund Accounting Agreement, Custody & Fund Accounting Fee Schedule and Global Securities Fee Schedule, each dated January 6, 2003, and the Cash Reserve Agreement dated March 31, 2003 (the “Agreements”), we hereby notify you of the addition of ING Van Kampen Global Tactical Asset Allocation Portfolio, a newly established series of ING Investors Trust, ING Corporate Leaders 100 Fund, a new series of ING Series Fund, Inc., ING Russell™ Global Large Cap Index 85% Portfolio, and ING Global Equity Option Portfolio, each a newly established series of ING Variable Portfolios, Inc. (collectively, the “Portfolios”) to be included on the Amended Exhibit A to the Agreements as shown. This Amended Exhibit A supersedes the previous Amended Exhibit A dated April 28, 2008.

INITIAL CAPITAL AGREEMENT
Initial Capital Agreement • July 31st, 2008 • ING Separate Portfolios Trust
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