Davis Polk advised Morgan Stanley & Co. Incorporated, Citigroup Global Markets Inc., Merrill Lynch, Pierce, Fenner & Smith Incorporated, UBS Securities LLC, Wells Fargo Securities, LLC and Ameriprise Financial Services, Inc. as representatives of the several underwriters on the $385 million SEC-registered initial public offering of 19,250,000 shares of common stock of ING Emerging Markets High Dividend Equity Fund. The shares are listed on the New York Stock Exchange under the symbol “IHD.”

ING Emerging Markets High Dividend Equity Fund is a newly organized, diversified, closed-end management investment company advised by ING Investments, LLC, an indirect wholly owned subsidiary of ING Groep N.V. and sub-advised by ING Investment Management Advisors B.V., an indirect wholly owned subsidiary of ING Groep.

The Davis Polk corporate team included partner Joseph A. Hall and associates John K. Doulamis, Phoebe Nel and Bruce Rose-Innes. Partner Mary Conway and associate Kay Ng provided tax advice. Counsel Susan Betteridge Baker provided Investment Company Act advice. Counsel Marcie A. Goldstein provided FINRA advice. Katina D. Gallo was the legal assistant on the transaction. All members of the Davis Polk team are based in the New York office.