I have tried to get more info about the ING Freedom Plan, but all the searches taking me to new Freedom Plan. If you have more details about the plan, please post here.
ING Freedom Plan has two options -
1- ING Prime Equity
2- ING Preserver
The ING Preserver performed better.

ULIP plans are not for return. So if the above plan is giving you 20% that too after deducting charges is really good.
For surrender charges please read the term and conditions of the policy documents.