Code of Ethics

Effective October 18, 2022

Code of Ethics

A Message From Adena

Dear Colleagues,

The unique aspects of our business, brand and culture set Nasdaq apart from our
peers and strengthen the positive impact we have on our clients, shareholders, the
global capital markets and each other.

Our sense of purpose and ability to deliver innovative solutions to the global
marketplace is fortified by our commitment to integrity; it remains at the center of
all we do. The Nasdaq Code of Ethics provides values-based guidance, heightens
compliance risk awareness, strengthens decision-making, and drives sound business
performance—it ensures we are living our values.

You have heard me herald the virtues of operating a “collaborative command culture.”
In my view, this can only succeed in an environment where mutual respect and a focus
on ‘doing the right thing’ are paramount. Our Code of Ethics sets clear expectations for
how we can do this effectively together. Living by the Code not only protects Nasdaq,
it protects you.

At Nasdaq, our purpose is to champion inclusive growth and prosperity. We power

stronger economies, create more equitable opportunities and contribute to a more
sustainable world to help our communities, clients, employees and people of all
backgrounds reach their full potential. As such, our unwavering commitment to
integrity, as outlined in our Code of Ethics, will ensure our success and safeguard the
important role we play in the global economy.

Please make sure you read the Code and join me in making the commitment to uphold
it in all we do as Nasdaq employees.

Best Regards,

Adena

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Table of Contents
1. Putting Our Values into Practice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Code Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Purpose, Vision, Mission, & Values. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Our Obligations & Responsibilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Compliance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Resources, Advice, & Guidance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Governance & Oversight. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2. SpeakUp! Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
About SpeakUp!. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Reporting Obligations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Zero-Tolerance for Retaliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Reporting Channels. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Urgent Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
How the SpeakUp! Line Works . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
SPEAKUP! LINE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

3. Self-Regulatory Organization Responsibilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Regulatory Referrals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Responding to Regulators. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

4. Responsibilities as a Public Company. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Accurate Reporting & Public Disclosure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Financial Reporting Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

5. Diversity, Inclusion, & Belonging. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Our Individual Duties. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Our Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Equal Employment Opportunity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Policy Against Discrimination, Harassment, & Retaliation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

6. Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Duties of Loyalty . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Outside Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Improper Financial Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Related Person Transactions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Broker-Dealer Affiliate Employees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

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7. Personal Trading & Investments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Global Trading Policy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Covered Persons. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Covered Securities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Global Trading Policy Rules . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Digital Assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Supplemental Trading Policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Watch List. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Private Investments & Personal Financial Interests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

8. Gifts, Entertainment, & Anti-Corruption. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Gifts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Entertainment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Approvals and Reporting of Gifts and Entertainment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Anti-Corruption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

9. Trade Controls & Economic Sanctions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

International Travel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
Overview of Trade Control Compliance Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

10. Antitrust & Fair Competition. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

11. Anti-Money Laundering. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
12. Confidentiality & Information Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Confidential Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Nasdaq Information Technology Assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Reporting Potential Data Breaches. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

13. Use of Open Source Software. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

14. Personal Data & Privacy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
15. Ethical Supplier & Expense Management. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Ethics & Compliance Expectations for Suppliers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Compliance with Supplier Selection & Contracting Policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
Use of Corporate Credit Cards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
Reporting Concerns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

16. External Communications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Public Speaking, Teaching, & Writing Engagements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Social Media. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

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1.
Putting Our Values into Practice

Introduction
This Code of Ethics, in conjunction with our policies, procedures, standards and handbooks,
outlines our collective responsibilities in conducting our business in accordance with the highest
standards of business ethics and compliance.

While this Code addresses many topics, it cannot cover every possible situation. The most
important thing to remember is that if you are ever uncertain about what is the right thing to do
or need guidance related to your work at Nasdaq, you are encouraged to Speak Up! and contact
one of our Guidance and Reporting Channels.

This Code is effective October 18, 2022, and supersedes all prior versions of this Code. You are
advised to check the Ethics page on Nasdaq’s intranet for the current version of the Code as a
printed copy may not be up to date.

This Code and any policies or other documents referenced in it are not an implied or express
contract of employment.

Code Applicability
This Code applies to all directors, officers, and employees of Nasdaq and its subsidiaries, as well
as all consultants and contractors and others who work on behalf of Nasdaq (which are referred
to in the Code alternatively as “Associates,” “we” or “you” based on context).

Application to Certain Nasdaq Subsidiaries

Where authorized by the CEO, a Nasdaq subsidiary may be permitted to adopt its own code of
ethics and related policies to apply to its operations, provided that in no event shall its code and
policies contain requirements that are substantively less restrictive than those in this Code and
related policies. The subsidiary’s code and policies may exclude topics or requirements that are
not relevant to its operations.

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Purpose, Vision,
Mission, & Values
We power stronger economies,
create more equitable
opportunities, and contribute
to a more sustainable world to
help our communities, clients,
employees, and people of all
backgrounds reach their full
potential.
 Act Like An Owner
թ Take initiative and follow through
Purpose թ Be empowered to propose solutions
Champion inclusive growth and prosperity թ Set measurable goals, and measure results
թ Drive innovation by taking intelligent risks

Vision թ Maximize operational efficiency

Reimagining markets to realize the potential Play As A Team

of tomorrow թ Listen well and demonstrate humility
թ Trust colleagues, assume good intent

Mission թ Collaborate across boundaries

թ Seek out diverse thought & background
 rovide the premier platform and ecosystem
P
թ Demonstrate empathy for others
for global capital markets and beyond with
Demonstrate Mastery
unmatched technology, insights & markets
թ Ensure you’re a subject matter expert
expertise
թ Build your capabilities
թ Show courage & resourcefulness
Values թ Be accountable for commitments
Our commitment to ethical business is explicitly
Fuel Client Success
reflected in Our Value to Lead with Integrity but թ Define your clients—internal and/or external
all of our Values should be read collectively as թ Center decision making around their needs
supporting ethical business practices: թ Solve problems swiftly
թ Demonstrate resilience through obstacles
թ Deliver quality that exceeds expectations

Lead With Integrity

թ Demonstrate respect for everyone
թ Communicate transparently
թ Role model honesty & ethics

Drive Innovation
թ Bring forth ideas for meaningful change
թ Take intelligent risks; learn from failures
թ Show courage and resourcefulness
թ Lead with agility and resiliency

These Values reflect our commitment to always

doing the right thing as an organization and as
individual stewards of our enterprise. They serve as
a common bond to unify our activities in pursuit of
our Purpose, ensuring we build an enduring company
for our customers, shareholders, colleagues, and
communities. Values-based decision-making and
good judgment are the best means for ensuring that
we conduct business ethically and in compliance
with all applicable laws and regulations.

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Our Obligations & Reporting Obligations Ethics is foundational
Responsibilities As detailed in this Code, you are required to to our business.
report any suspicious activities and violations We reflect our
All Associates of this Code, policies, or the law related commitment
As a Nasdaq Associate, you must contribute to to Nasdaq’s business that you observe or to integrity in
reasonably suspect or that are reported to
Nasdaq's ethical culture by understanding and everything we do.
abiding by our Code and policies, modeling you by a colleague, customer, supplier, or third
party. Reports can be made through any of the
Managers have
our Values, reporting potential or observed
Guidance and Reporting Channels set forth in a special duty to
violations, and completing certification and
training requirements. the SpeakUp! section of this Code. model our values
and be champions of
Associates are expected seek guidance in
Comprehension & Compliance the ethical culture of
advance of taking action whenever application
Nasdaq Associates must understand and of this Code, a policy, or applicable law is
their teams.
comply with all applicable Nasdaq policies, unclear. Associates are expected to fully
standards, and Employee Handbooks. As cooperate with any internal, law enforcement,
an Associate, you are expected to maintain or regulatory investigation as appropriate
a working knowledge of this Code and all and in accordance with all applicable laws.
applicable policies and review updates when Questions or requests for guidance should be
they are issued. All current policies are posted directed to your management or the relevant
to the Policy Library on Nasdaq’s intranet. Guidance and Reporting Channels set forth in
the SpeakUp! section of this Code.
The Law & Local Regulations
Your obligations under this Code include Certification & Training
adherence to all applicable laws and You are required to certify your compliance
regulations including but not limited to, laws with the Code and Nasdaq policies annually
applicable to Nasdaq as a publicly-traded and complete all required Ethics and other
company, a self-regulatory organization (SRO) certifications and training by the established
or exchange operator and local laws and deadlines. New hires and non-employee
regulations applicable in the jurisdiction where Associates must certify in accordance with
you work. To the extent that an applicable Nasdaq hiring and contractor on-boarding
law conflicts with a provision in this Code or a procedures or the integration plan for acquired
referenced policy or document, the conflicting companies.
provision of the Code, policy, or document will
not apply.

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Manager Responsibilities Compliance
Nasdaq leaders must create an ethical
culture in which Associates understand our Consequences for Non-Compliance
commitment to integrity as foundational to Any Associate who violates a provision in this
our Purpose, Vision, Mission, and Values. They Code, an applicable Employee Handbook
must build an environment where Associates or policy, or engages in illegal or improper
feel comfortable raising issues or concerns behavior, will be subject to disciplinary action,
without fear of retaliation. Any allegations or up to and including termination of employment
reports of misconduct reported by Associates (or, in the case of non-employees, termination
must promptly be referred to the relevant of services or contract). Disciplinary action may
Guidance and Reporting Channels set forth in result in the reduction or elimination entirely
the SpeakUp! section of this Code. of any compensation awards, be factored into
performance appraisals, and/or be considered
Managers must encourage ethical conduct and
in promotion or work assignment decisions.
compliance with the law by:
Associates may be required to undertake
թ Modeling integrity and personally leading remedial or corrective actions to address
ethics and compliance efforts; non-compliance. In appropriate cases, Nasdaq
may refer a matter to a regulator or law
թ Considering ethics and compliance efforts,
enforcement.
including risk management and cyber and
information security, when evaluating and Waivers
rewarding Associates; and
From time to time, special circumstances may
թ Ensuring Associates understand that warrant a waiver from a provision of the Code.
business results are never more important The Global Ethics Team, in consultation with
than ethical conduct and compliance with the Associate’s Senior Vice President (SVP),
Nasdaq policies and the law. Executive Vice President (EVP) or President,
will consider written waiver requests and may
Nasdaq managers and leaders are expected to
grant a written, time-limited waiver. Any waiver
build and foster a climate to identify business
of a material departure from this Code for a
risks and ensure that processes to address
President, Executive Officer or Director may
risks are communicated and implemented;
be granted, depending on the topic, only by
provide education on Nasdaq policies and
the Audit & Risk Committee or the Nominating
applicable laws; ensure periodic risk reviews
& Governance Committee of the Board of
are conducted; and, working with the Office
Directors and must be disclosed, along with
of General Counsel and Global Ethics Team,
the reasons for the waiver, when and how
take prompt action to address identified ethical
required by applicable law and regulations.
issues.

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Resources, Advice, Global Co-Chief Compliance
& Guidance Officers
Nasdaq’s General Counsel - Europe and
Current company-wide policies are posted to
Deputy General Counsel for Litigation
the Policy Library on Nasdaq’s intranet. The
and Compliance are its Global Co-Chief
teams and individuals below have responsibility
Compliance Officers. They are responsible
for the management and oversight of the Code
for oversight of Nasdaq’s global compliance
of Ethics and Nasdaq compliance policies.
programs including policies and supporting
procedures and coordinating the activities of
The Global Ethics Team
Nasdaq’s Compliance Council.
The Global Ethics Team monitors compliance
with this Code, including through training,
oversight programs, compliance testing, and
Governance & Oversight
reviews. Its members are available to answer Nasdaq’s Compliance Council and Board Audit
your questions promptly and confidentially and Risk Committee provide governance
and provide training and educational and oversight of the ethics and compliance
sessions to employees throughout the year. programs. The Compliance Council is chaired
You can contact the Global Ethics Team at by the Chief Legal and Regulatory Officer and
[email protected]. has management oversight responsibility for
Nasdaq’s ethics and compliance programs and
Compliance Officers compliance-related risks. At the board level,
Certain regulated businesses within Nasdaq under its charter, the Audit and Risk Committee
have dedicated compliance officers who are has responsibility for oversight of the
responsible for overseeing compliance for the programs including this Code, related policies,
entities which they cover. Compliance Officers communication of the Code to Associates
oversee specialized policies that apply to and monitoring employee awareness of and
their respective entities. They also support compliance to the program.
the Global Ethics Team in applying the Code
of Ethics and company-wide policies to their
organizations.

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2.
SpeakUp! Zero-Tolerance for Retaliation

Program Nasdaq has zero toleration for retaliation against

individuals seeking guidance, reporting concerns,
cooperating in an investigation, or otherwise
using our SpeakUp! Program. Nasdaq provides all
About SpeakUp! legal protections afforded under applicable laws
Raising concerns about potential violations of this and regulations for individuals reporting alleged
Code or a policy is critical to protecting Nasdaq, misconduct or violations of law; this includes the
your colleagues, our customers, shareholders, and right of Associates to report violations of certain
stakeholders in our business – it is fundamental to laws directly to law enforcement or a designated
upholding our commitment to act with integrity. government authority. Any concerns about
retaliation should be raised with the Global Ethics
Team immediately. Any Associate who engages in
Reporting Obligations retaliation is subject to disciplinary action, up to and
including, termination of employment.
You are expected to timely seek guidance in
situations where application of the Code or a
policy is unclear. You must also promptly report
any observed or suspected violations of this
Code, a Nasdaq policy, or any laws or regulations
applicable to our business. This extends to acts by •You
 do not need all the facts to
any Associate, customer, supplier, or others that report a potential, suspected, or
violate the Code or policy, or constitute illegal,
observed violation.
inappropriate, or unethical behavior.

To make a report, you do not need all the facts or to •P

 reserve all documents in your
prove that a violation has occurred. Rather, you must possession.
only act in good faith, provide all relevant information
known to you, and not present information in a •D
 o not investigate the matter.
misleading manner. If you believe that a violation has
occurred, you must preserve all documents you have
related to the possible violation and provide them to
the individual investigating the matter.

In addition, if someone reports a suspected Code

or other violation to you, you must notify one of
the individuals or groups listed in the Reporting
Channels below. Unless you are specifically
authorized to do so by the Office of General Counsel
or the applicable compliance function, you must not
investigate the matter either prior to, or following,
making a report.

nasdaq.com 11
Reporting Channels
You can seek guidance from or make a report to any of the following resources under Nasdaq’s SpeakUp! Program:

Nasdaq Leadership
Nasdaq is committed to having an open culture where anyone who surfaces concerns is respected for
doing so. All managers and Location Leaders have been provided with guidance on how to address and
appropriately escalate issues where necessary.

Office of General Counsel

The Office of General Counsel maintains the SpeakUp! Program. You can contact anyone in the Office of
General Counsel with concerns you have.

Ethics & Compliance

The Global Ethics Team is an independent group with individuals located globally across Nasdaq who are
available to help resolve any ethics or compliance-related issues. Contact the Global Ethics Team directly by
emailing [email protected]. You can also contact any listed members of the Global Ethics &
Compliance Group directly.

People Team
People@Nasdaq have business partners & regional experts to help address employment and workplace
related issues.

Audit
Audit is an independent group with individuals available to consult on any ethics or compliance-related
issues.

SpeakUp! Portal
Operated by Red Flag Reporting, the SpeakUp! Line provides 24X7x365 live operators for calls and the
Secure Web Portal offers an online interface for intake and follow-up. The system allows the user to remain
anonymous (subject to local law) and matters are routed to the appropriate Nasdaq Team.

Urgent Issues
Associates are required to report urgent issues to the appropriate team listed below. These teams
provide immediate assistance related for the areas they support.

թ MarketWatch: Protects the integrity of our markets with real-time surveillance.

թ Information Security: Responds to threats or damage to information systems or data.

թ Global Security: Protects Nasdaq through the Facility Security Operations Center.

nasdaq.com 12
How the SpeakUp! Line Works
You may report a matter or seek guidance through Nasdaq’s SpeakUp! SPEAKUP! LINE
Line. The SpeakUp! Line is operated by Red Flag Reporting, a third party
company that operates this type of reporting system on behalf of global
Secure Web Portal
https://portal3.redflagreporting.com/
companies and organizations.
nasdaq-landing-page/
Reporting Anonymously
Phone
When you contact Red Flag Reporting through the secure web portal or by
U.S. & Canada (toll-free)
phone, you have the option to make an anonymous report (subject to any
866-352-1946
local legal restrictions). Your report will be provided to the Nasdaq officials
identified to receive the report as listed in the system and investigated like Sweden (toll-free)
any other matter reported to Nasdaq. The SpeakUp! Line allows Nasdaq to 020-889-294
communicate with anonymous reporters by relaying messages through the
Global (toll)
Red Flag Reporting.
+1-330-765-4281
If you make an anonymous report, you have the option to receive follow-up
information on your report and respond to questions from the investigation
team through the Red Flag Reporting system. Red Flag Reporting is strictly
prohibited from sharing the submitting individual’s personal information
with Nasdaq unless that person explicitly consents to sharing.

After Reporting
If you provide your contact information or permit contact when making a
report through the SpeakUp! Line, you will receive prompt acknowledgment
of your report (generally within one business day). You will subsequently
be provided information on the resolution of your report, subject to privacy
and legal requirements that may limit what can be provided.

Protections Under Applicable Laws and Regulations

Nasdaq is a subject to laws and regulations such as the Sarbanes Oxley
Act (SOX), the US Defend Trade Secrets Act, the EU Whistleblower
Directive (as implemented in the member states where Nasdaq operates),
and the UK Public Interest Disclosure Act. These laws and regulations
authorize Associates to report certain suspected violations of law
directly to designated regulatory or law enforcement entities (and, in
limited instances, make a public disclosure), regardless of whether the
Associate reported the potential violation internally through Nasdaq’s
Reporting Channels first. Nasdaq complies with such laws and regulations.
Nasdaq will not prohibit an Associate from making a permitted disclosure
authorized under such laws and regulations or retaliate against an
Associate for making such a report.

* Some jurisdictions in Europe may limit what matters are reported through a “hotline system.” When using the SpeakUp! Line portal, you will be asked to identify your Nasdaq location and
will be provided instructions based on local law as to whether a matter can be reported through the portal or should be identified through a different channel.

nasdaq.com 13
In particular, nothing in this Code, any policy, For Associates in the EU, this reporting
employee handbook or confidentiality/ includes, but is not limited to, reporting
intellectual property ownership agreement that to designated European Union regulators,
you signed as an Associate prohibits you from: “National Competent Authorities” or other
authorized recipients regarding suspected
թ Reporting possible violations of US federal
violations of laws and regulations related to
law or regulation to any US governmental
breaches of EU/EEA law subject to the EU
department or agency (including executive
Whistleblower Directive such as (a) financial
or legislative branch entities);
services, products and markets, and prevention
թ Making other disclosures that are protected of money laundering and terrorist financing, (b)
under the whistleblower provisions of US protection of privacy and personal data, and
federal law or regulation; security of network and information systems,
թ Disclosing a Nasdaq trade secret in (c) breaches affecting the financial interests
confidence to a US federal, state, or local of the EU and (d) breaches relating to the EU
government official, or to an attorney, for the internal market.
sole purpose of reporting or investigating a
As permitted by such laws and regulations,
suspected violation of the law;
you are not required to notify Nasdaq prior to
թ Reporting violations or suspected violations making such reports or exercising such rights.
of law or other reportable matters to
regulators, or other authorized recipients
as permitted under whistleblower or
similar laws and regulations in effect in the
location where the Associate works (and, if
applicable, as further detailed in the relevant
Employee Handbook for such country
or local policies adopted by the Nasdaq
subsidiary for which the Associate works).

nasdaq.com 14
3.
Self- Regardless of your
Accordingly, any regulatory referral
must be made through the SpeakUp!
role at Nasdaq, you
Regulatory Line identifying “Regulatory Referral”
as the type of report.
are required to report

Organization suspicious conduct

or potential rule
Responding to
Responsibilities Regulators
violations related to
the markets we own
As an employee or contractor of We respond promptly, accurately, and operate. Such
a United States Self-Regulatory and completely to legitimate reports should be
Organization (SRO) or an affiliate, regulatory requests for information. made through the
you have a heightened and proactive In responding to any such requests
Regulatory Reporting
responsibility to ensure regulatory requiring the disclosure of personal
System within the
integrity. One of your most important data, Nasdaq takes into account
roles is to assist Nasdaq in its its obligations under privacy laws SpeakUp! Portal.
responsibility to protect the investors including, where applicable, the EU
and public interest in the markets. General Data Protection Regulation
Nasdaq cooperates with regulators (GDPR) or contractual agreements
who oversee our business. implementing GDPR or other privacy
law-related requirements.
The Guidance on the Responsibilities
of U.S. Self-Regulatory Organizations The Office of General Counsel
and Nasdaq as a Self-Regulatory represents Nasdaq and its affiliates
Organization outlines your regulatory with respect to requests from
obligations arising out of Nasdaq’s regulators for documents or other
ownership of U.S. securities, information held by Nasdaq (or
derivative, and option exchanges and those acting on its behalf); it is
clearing agencies. Consult with the also responsible for representing
Office of General Counsel if you have Nasdaq where there is potential legal
any questions regarding your duties. liability to a governmental body or
third party. If you receive a request
for information or inquiry from any
Regulatory Referrals
governmental or self- regulatory
As Associates of a United States organization related to Nasdaq’s
Self-Regulatory Organization (SRO) business or a subpoena or search
or an affiliate, you have an obligation warrant for Nasdaq data, materials
to report through our Regulatory or property, you must immediately
Referral process any regulatory contact the Office of General
violation of securities-related Counsel. Pending direction of the
regulations and rules you believe has OGC Office of General Counsel, you
occurred or may occur. You must must preserve all relevant documents
report any suspicious conduct or and materials in your possession that
potential rule violations related to could be related to such request or
the markets we own and operate the matter it concerns.
through the designated Regulatory
Referral system. The SpeakUp! Line is
Nasdaq’s Regulatory Referral system.

nasdaq.com 15
4.
Responsibilities as a
Nasdaq will not tolerate, either directly by an
Associate or by any contractor or other service

Public Company provider:

թ Any false or misleading entry in our books and

records;
Accurate Reporting & Public թ The creation of any disclosed or unrecorded fund,
Disclosure asset or entity for any purpose;

Because of our rigorous market regulation of թ the approval or making of any payment with the
financial reporting and public communications agreement or understanding that any part is to be
for listed companies, our own standards must used for any purpose other than that described by
be above reproach. Our robust internal controls the supporting documents;
ensure our records accurately and fairly reflect the թ The use of Nasdaq funds or assets for any
transactions and dispositions of our assets. Nasdaq unlawful purpose; or,
Public Disclosure Policy reflects our commitment to
թ Any action to coerce, manipulate, mislead or
accurate, timely, and complete disclosure of financial
fraudulently influence Nasdaq’s independent
information and material events to the market.
auditors.
Every Associate is responsible for ensuring that
all created, updated, or modified business records Financial Reporting Concerns
completely and accurately reflect the underlying
transaction(s). All Nasdaq records must be retained If you have concerns about the accuracy of Nasdaq’s
in Nasdaq systems or facilities; as further set forth financial reports or its financial reporting processes
in Nasdaq’s Information Security policies, you may or internal controls, in addition to the above
not store records on a personal device or use points of contact, you may direct your concerns
applications such as third party messaging apps to the Chairman of the Audit & Risk Committee
(unless authorized in advance) to conduct business of the Board of Directors. The Chairman can be
communications. You must comply with the relevant reached at the [email protected] or by mail
records retention policy in maintaining records under addressed to Audit & Risk Committee Chairman c/o
your control. Nasdaq, 805 King Farm Blvd, Rockville, MD 20850.
Any correspondence marked confidential will be
All Associates must comply with record hold notices distributed unopened to the Audit & Risk Committee
provided by the Office of General Counsel. If you Chairman. Regardless of the resource that you
become aware that a particular matter may be under select, if you report a concern, the matter will be
dispute or subject to investigation, you must retain reviewed on a confidential basis and investigated
records related to it in their current state pending promptly and thoroughly. You will receive a
resolution unless directed to do otherwise by the response, subject to privacy and legal requirements
Office of General Counsel. that may limit what can be provided.

nasdaq.com 16
5.
Diversity, Inclusion, & Belonging
At Nasdaq, we strive to foster an environment that values diversity, encourages inclusion, and nurtures
a feeling of belonging in the workplace. In line with our Core Values to Lead with Integrity and Play as a
Team, we expect everyone to value and respect the unique contributions and diverse perspectives of
our Associates, customers, suppliers, and others at all times. We believe this diverse and inclusive work
environment, leads to higher sense of belonging and commitment, fueling our efforts to achieve the best
results for the company and the ecosystem we serve.

Diversity Inclusion Belonging

Diversity is the unique makeup of Diversity flourishes where there is Diversity and Inclusion lead to a greater
characteristics in all of us, combined Inclusion. “Inclusion” means being sense of Belonging in the Nasdaq family.
in one company – it is essentially valued, respected, and supported Belonging is about having a sense of
any dimension that can be used to within the organization. For Nasdaq, connection and psychological safety in
differentiate groups and people from Inclusion involves embracing the the workplace and among colleagues.
one another, such as differences in multiple perspectives that our diverse Belonging includes understanding true
age, race, color, national origin, native associates share with the organization. equality in the way we treat others with
language, ancestry, religion, gender, Inclusive practices across the employee respect and professionalism, within and
sexual orientation, gender identity experience ensure that all Associates outside the workplace. It is our aspiration
and/ or expression, disability, veteran can thrive and engage to their fullest to foster an environment which we feel
status, genetic background, different potential. proud of and want to belong to.
perspectives, economic backgrounds,
work experiences, family status, life
styles, and cultures.

We encourage our Associates to bring

their diverse traits, experiences, and
perspectives to work, and we value
that diversity. Our ongoing commitment
is to attract, retain, include, and
empower diversity in our workplace and
marketplace because it is both good and
right for our employees, our customers,
and our business.

nasdaq.com 17
Our Individual Duties color, disability, national origin, ancestry, race,
religion, gender, sex (including but not limited
Nasdaq expects Associates to demonstrate to pregnancy, childbirth, breastfeeding, or
a commitment to diversity, inclusion, and medical conditions relating to breastfeeding,
belonging in our daily work activities, and to pregnancy, or childbirth), sexual orientation,
adhere to all workplace conduct requirements gender identity and/or expression, veteran or
as stated in applicable Employee Handbooks. military status, marital and/or familial status,
Any Associate who has any concerns about genetic information, or any other legally
diversity, inclusion or belonging, as well as protected classification or characteristic
equal opportunity, in the Nasdaq workplace protected by law in any of the applicable
may contact their manager or more senior jurisdictions.
management, HR business partner, a member
of the Global Ethics Team, or the Office of
Policy Against Discrimination,
General Counsel. Discrimination, harassment,
bullying, and retaliation for speaking up are not
Harassment, & Retaliation
tolerated at Nasdaq. We want everyone to feel Nasdaq will not tolerate any form of unlawful
proud of being a part of Nasdaq. discrimination, harassment, bullying, or
retaliation by its Associates towards any
Our Standards person, including other employees, officers,
consultants, contractors, vendors, customers,
Reflecting our Values, Nasdaq is committed to clients, or guests based on the classifications
the principles in leading international standards and characteristics noted above. This includes,
including the United Nations (UN) Declaration but is not limited to, sexual, racial, workplace,
of Human Rights; the UN Global Compact; the online, or other forms of harassment by or
UN Guiding Principles on Business and Human against any Associate. Violations are subject
Rights; the International Labour Organization to disciplinary action, up to and including
Declaration on Fundamental Principles and termination of employment.
Rights at Work; the UN Women’s Empowerment
Principles; and, the UN Lesbian, Gay, Bi, Trans, It is expected that all Associates will observe
& Intersex People Standards. All Associates the highest standards of conduct and will
are expected to conduct their work for Nasdaq avoid any behavior that could be interpreted
consistent with these standards and principles. as unlawful. Employees, managers, and
other Associates who experience or witness
behavior or conduct which may constitute
Equal Employment or contribute to discrimination, harassment,
Opportunity or retaliation must immediately report such
occurrences using the reporting channels
Nasdaq is committed to creating a work
designated in this Code. Refer to your
environment that promotes personal and
Employee Handbook for further details.
professional growth and that fully utilizes the
abilities of its employees— regardless of age,

nasdaq.com 18
6.
Conflicts of Interest
թ Outside employment, activities, advisory roles, or
board activity involving digital assets;

թ Being involved in any way in hiring, invoicing, or

oversight activities involving friends or family
Duties of Loyalty members, either in their individual capacity or as
As an organization, we are dependent on each other employees of an entity doing business with, or
for the success of our business and, as employees looking to do business with, Nasdaq; and
of a publicly traded company, we owe duties to our թ Accepting gifts, business courtesies, or any other
shareholders to advance Nasdaq’s best interests items of value from any person or entity doing
in everything that we do. Each of us is expected business with, or looking to do business with,
to demonstrate loyalty to Nasdaq in our business Nasdaq.
conduct. Each of us must apply judgment in the
performance of our duties that is untainted by
personal or financial interests. Conflicts of interest
Outside Activities
may arise when: Nasdaq’s Outside Activities - Conflicts of
Interest Policy (Outside Activities Policy) outlines
թ Your own private interests, personal or financial,
requirements for Associates who want to engage
interfere in any way (or could be perceived as
in an Outside Business Activity (OBA). Nasdaq
interfering in any way) with the interests of
Associates are not permitted to engage in Outside
Nasdaq;
Business Activities (OBAs) requiring approval unless
թ Your activities might raise questions as to whether the activity has been approved in advance by their
you are acting for personal gain or for the benefit management, the Global Ethics Team, and other
of a third party, rather than in Nasdaq’s interests; relevant teams based on the nature of the OBA.
or OBAs include activities such as:
թ You owe a duty of loyalty to an entity or person
թ Service as a board member,
whose business interests are not aligned with
Nasdaq’s or others could reasonably perceive that թ Secondary employment including gig work,
you owe such a duty. թ Operating your own business including start-up
work,
Even a perception of a conflict can undermine
confidence in Nasdaq and impact the effort put թ Open source projects, and
forward by other Associates. This is why any real թ Political appointments or elected public office.
or perceived conflict of interest must be avoided or
disclosed and appropriately addressed. Associates planning to engage in an OBA must
read and abide by the Outside Activities Policy and
Common situations involving conflicts of interest contact the Global Ethics Team if they have any
include: questions.

թ Personal investments or other financial or

employment interests in a Nasdaq competitor,
supplier, contractor, or other entity with a current
or prospective business relationship with Nasdaq;

թ Outside employment, activities, advisory roles,

or board activity involving a Nasdaq competitor,
supplier, contractor, or other entity with a current
or prospective business relationship with Nasdaq;

nasdaq.com 19
Prohibited Outside Activities into a transaction, arrangement, or relationship
where the aggregate amount exceeds, or is
Nasdaq Associates are not permitted
expected to exceed, $120,000 and a “related
to engage in OBAs that involve primary
person” has an interest. Related persons
responsibilities directly or indirectly related to
include a Nasdaq Board Member or nominee,
the issuance, purchase, sale, investment or
a Nasdaq executive officer, immediate family
trading of securities or futures on securities,
members of the foregoing, and a beneficial
commodities, Digital Assets (such as
owner of more than five percent of any class
cryptocurrencies and NFTs, as defined in
of Nasdaq’s voting securities. A related person
the Global Trading Policy), or similar types of
may have a direct or indirect material interest
investments.
in a transaction between Nasdaq or one of its
subsidiaries and another entity if he or she is
Improper Financial Benefits a general partner, executive officer or greater
than 10% shareholder of another entity. A list
Nasdaq Associates may not enter into any
of potential related persons is available on
financial relationship or obtain/seek to obtain a
Nasdaq’s intranet.
loan from any person or entity doing business
with or seeking to do business with Nasdaq You are responsible for reviewing the list of
under terms that are more favorable than those potential related persons and considering
offered to members of the public. it in connection with potential transactions,
arrangements, or relationships. Potential

Related Person Transactions related person transactions must be reported

to the Office of the Corporate Secretary.
As Associates, we must all be diligent in our
monitoring and reporting of potential "related
Broker-Dealer Affiliate
person transactions.” As further described in
the Related Person Transactions Policy, these
Employees
transactions can present potential or actual If you are registered with a US broker-
conflicts of interest and create the appearance dealer affiliate of Nasdaq, you are subject to
that decisions made by Nasdaq are based on additional guidelines and requirements with
considerations other than the best interests of respect to outside business activities. Please
Nasdaq and its shareholders. consult with the Broker-Dealer Compliance
Officer for guidance on the scope and
Related person transactions generally occur
application of these rules.
when Nasdaq or one of its subsidiaries enters

nasdaq.com 20
7.
Personal Trading
What is Insider Trading?
& Investments Insider trading is trading while in
possession of material non-public
As Associates, you may have access to non-public information (MNPI). It also includes
information that may affect the price of our stock providing or “tipping” such information to
or the stock of other companies. Even if you do not others so that they can trade. Material
have such access (or have only limited access in non-public information includes any
certain areas but not others), due to Nasdaq’s role and non-public information that could be
business lines, there may be the perception that you important to an investor making a
have such access. Therefore, your investment and decision to buy, sell, or hold a security.
trading activity must be above reproach.
Insider trading, misappropriation of
information for personal use or the
Global Trading Policy benefit of others, and other forms of
market abuse are prohibited by Nasdaq
The Global Trading Policy and applicable Supplemental
policy and applicable law. Violations can
Policies detail your obligations regarding your ownership
subject you to criminal prosecution and
and trading of securities and other types of tradeable
regulatory enforcement.
assets including digital assets such as cryptocurrencies.
In addition to outlining measures to prevent any
perception of a conflict of interest or misuse of
information, the policies also detail your disclosure
obligations so that Nasdaq can document and validate
compliance.

All Associates must annually certify compliance with the

Global Trading Policy and applicable related policies.
New hires must certify compliance and complete all
disclosures within thirty days of starting at Nasdaq.

Covered Persons
All Nasdaq Associates and their Associated Persons
must abide by the Global Trading Policy. Associated
Persons consist of anyone whose finances you control
or influence, including a spouse/cohabitee, minor or
dependent children, and any legal entities you own,
control, or exercise financial influence over.

Covered Securities
The Global Trading Policy rules apply to publicly
traded stocks and equities, publicly traded bonds
and other debt, and derivatives on equities and debt.
(Supplemental policies may expand the definition of a
Covered Security to include ETFs and other securities.)

nasdaq.com 21
Global Trading Policy Rules blockchain technology (“distributed ledger
technology”), including, but not limited to, so-
Disclosures called “virtual currencies,” “coins,” and “tokens”
or (b) the definition for such assets applicable
All Associates are required disclose (for
in the jurisdiction in which the Associate
themselves and their Associated Persons) all
resides.
brokerage accounts and Covered Security
holdings in Nasdaq’s Ethics system. Employees Digital Assets are not treated as Covered
located in the United States must maintain Securities under the Global Trading Policy.
trading accounts at approved brokerage firms The policy includes restrictions on using
unless a hardship waiver is granted non-public information related to Digital
Assets or using Digital Assets for unlawful or
30-Day Hold Rule unethical purposes. As detailed in the policy,
All Associates and Associated Persons must Nasdaq may impose certain ownership or
hold Covered Securities for 30 Days before trading restrictions on certain Digital Assets.
selling. Digital Assets Associates may be subject to a
supplemental trading policy.
Prohibited Company List
Nasdaq employees are prohibited from owning Supplemental Trading
Covered Securities in any companies listed on Policies
the applicable Prohibited Company List.
Certain Nasdaq Associates are subject to
7-Day IPO Rule supplemental trading policies when their work
location or job responsibilities are subject to
Associates and Associated Persons cannot
specialized regulatory requirements or present
trade for seven days following an Initial Public
unique compliance or conflict of interest risks.
Offering (IPO) or direct listing.
Role-based supplemental policies may apply to
Short Selling Regulatory and Surveillance Associates, Index
Associates, Digital Assets Associates, Dorsey
Short selling and other similar positions are
Wright Associates, Broker-Dealer Associates,
prohibited unless approved by the Ethics Team
and Directors and Executive Officers. Location-
in advance.
specific supplemental policies are posted to
Associates must consult the full policy and Nasdaq’s intranet.
any applicable supplemental policies to ensure
full compliance. For additional questions, you
can contact the Global Ethics Team or your
compliance officer.

Digital Assets
Under the Global Trading Policy, “Digital
Assets” are defined as the broader of (a)
any asset issued, minted, exchanged. and/
or transferred using distributed ledger or

nasdaq.com 22
Watch List թ Any ownership by you or an immediate
family member of a 5% or greater interest in
Watch List Associates are those identified as a company that does business with Nasdaq
having access to Nasdaq’s internal financial or is seeking to do business with Nasdaq.
statements or other material non-public
In addition to the specific interests detailed
information (MNPI) about Nasdaq related to
above, remember you must disclose (1) as an
the development of its quarterly and annual
OBA, any ownership interest (regardless of
financial reporting will be prohibited from
level) that involves your active involvement in
trading in Nasdaq stock during a closed trading
the operation of the activity or entity or (2) any
window as determined by Nasdaq’s Office of
interest that constitutes or could reasonably be
General Counsel.
perceived as constituting a conflict of interest
with your obligations to Nasdaq.
Private Investments &
Personal Financial Interests All personal financial interests meeting the
listed requirements must be disclosed in
Disclosing Private Investments Nasdaq’s Ethics and Compliance Hub using the
form “Private Transaction,” Divestitures, sales,
The following passive financial interests must
and disposals must be updated using the same
be disclosed to Nasdaq via the Ethics and
form.
Compliance Hub:
You may not participate in any Nasdaq
թ Any ownership interest in a partnership as a
decisions or internal discussions/deliberations
general partner;
related to an entity for which a financial
թ Any ownership interest in a partnership disclosure is required (in accordance with the
as a limited partner where your ownership bullet points above) unless, in exceptional
interest is more than 5% of the partnership; circumstances, a waiver has been granted by
թ Any ownership interest in a corporation, your management and the Global Ethics Team
LLC or other similar type of legal entity to address the actual or perceived conflict of
constituting more than 5% of the entity’s interest.
ownership;

թ Any ownership or investment in a private

investment fund constituting more than a
5% ownership interest or contribution to the
fund; and

nasdaq.com 23
8.
Gifts, Entertainment, Entertainment

& Anti-Corruption Business-related entertainment is a type of gift

involving a meal or event whose purpose is to enable
substantial and legitimate business interaction
Nasdaq has a zero-tolerance policy for bribery with a business contact. Because of this purpose,
and corruption. All Associates are expected to Entertainment is treated differently than other types
maintain the highest levels of integrity in all business of gifts in the Gifts Policy. The Gifts Policy sets forth
exchanges. Offering or accepting a gift in exchange specific criteria that must be met for a meal or event
for taking action, or even just to influence someone to qualify as “Entertainment” – if all criteria are not
to act, may violate anti-corruption laws which can met, the meal or event constitutes a gift.
result in criminal prosecution, regulatory action, and/
or civil fines. Even where there is no improper intent, Prohibited and Highly Restricted Gifts
giving or accepting business courtesies/gifts can
As further detailed in the Gifts Policy, certain gifts
generate a sense of personal obligation on the part
are prohibited including, but not limited to:
of the recipient. It may also give the impression to
others that business dealings may be influenced by թ Gifts provided to influence the other party or
personal favors. for an improper purpose, or in response to a
solicitation for a gift
The Gifts, Entertainment, & Anti-Corruption Policy
(“Gifts Policy”) addresses giving or receiving work- թ Gifts that would violate a contractual commitment

related gifts or business courtesies with outside made by Nasdaq

parties. թ Gifts that violate a professional standard

applicable to the recipient
The Gifts Policy documents Nasdaq’s full
commitment to compliance with anti-corruption թ Gifts that violate a corporate policy of the

laws and standards, including the US Foreign recipient

Corrupt Practices Act (FCPA), the UK Bribery Act, թ Gifts to an Associate from an entity involved in a
and the Organisation for Economic Cooperation regulatory matter or investigation in which they
and Development (OECD) Guidelines/International are involved
Chamber of Commerce’s Rules of Conduct and
թ Cash, cash equivalents, securities or digital assets
Recommendations to Combat Extortion and Bribery.
թ Facilitation payments (as further described in the
To support Nasdaq’s compliance with the FCPA,
Gifts Policy)
Associates must maintain accurate documentation
of all transactions and adhere to all internal
accounting controls.

Gifts
A “Gift” is anything for which the recipient does
not pay fair market value – it includes both items
and service provided for free or at a reduced cost.
The Gifts Policy includes a detailed list of types of
gifts including merchandise, travel and hospitality,
services, cash or cash equivalents, donations, and
opportunities.

*  Internal Nasdaq gift-exchanges are subject to People@Nasdaq gift guidance.

nasdaq.com 24
As further detailed in the Gifts Policy, certain You should contact the Ethics Team in advance
gifts are subject to strict limitations and may if you are uncertain about the application of
be prohibited in some or many circumstances. the Gifts Policy to a particular situation.
Associates contemplating any such gift should
seek guidance from the Ethics Team or their
Anti-Corruption
Compliance Officer in advance. These include,
but are not limited to: Diligence and Contract Terms
թ Gifts involving Government Officials All suppliers, distributors and resellers must be
(which include employees of state-owned prescreened by the Supplier Risk Management
enterprises as further described in the program prior to engagement. Review the
policy); Gifts Policy for Corruption Red Flags related to
supplier engagement. Anti-corruption contract
թ Gifts involving Nasdaq’s independent auditor;
clauses are required for certain vendor types.
թ Non-local travel or accommodations

թ Charitable donations Supplier Payments

թ Political contributions All expenses, vendor payments, and other
transactions are subject to compliance
monitoring and testing. Nasdaq Associates
Approvals and Reporting of
are expected to comply with any request
Gifts and Entertainment for information related to such monitoring.
The Gifts Policy sets forth the conditions under Additional requirements apply to Associates
which Gifts and Entertainment permitted by registered with U.S. broker-dealer affiliates;
the policy may be offered/given or accepted. consult with the broker-dealer compliance
officer for guidance on these rules.
Where an Associate is providing a Gift or
Entertainment, they must comply with the Intermediaries
Gifts Policy and all relevant Finance policies You may not authorize or request any
including the Travel and Entertainment intermediary including any supplier, contingent
Policy. The Gift or Entertainment must work or other party doing business with
properly categorized in Nasdaq’s expense Nasdaq to provide any Gift or Entertainment
reimbursement or purchasing system and all not permitted by the Gifts Policy. In the event
supporting information related to the individual you learn that any such individual or entity
recipient and their organization documented. provided a Gift or Entertainment on Nasdaq’s
Associates must cooperate with any behalf or under circumstances where it would
compliance testing or auditing done related to appear to be on Nasdaq’s behalf you must
Gift Policy compliance. report the matter through one of the Reporting
Channels set forth in this Code.
Associates may accept certain Gifts and
Entertainment subject to the approvals and
reporting required in the Gifts Policy. The
Gifts Policy sets forth approval and reporting
thresholds based on the type, value and
frequency of receiving Gifts or Entertainment.
Where applicable, further limits may apply to
certain Nasdaq legal entities, individuals subject
to professional standards or certain locations.

nasdaq.com 25
Record Retention Lobbying and Political Donations
All records and supporting documentation You may not lobby government officials
relating to Gifts and Entertainment must be (executive or legislative branch) or hire a
maintained in Nasdaq’s systems in accordance lobbyist to act for Nasdaq without prior
with the Code of Ethics, the Policy and authorization from our Government Relations
all relevant Nasdaq purchasing, expense team. You may not contribute Nasdaq funds or
management and accounting policies, other assets for political purposes without the
procedures and controls. If you become express permission of your supervising EVP
aware of a potential violation of this policy and the Office of General Counsel.
or any corruption laws or regulations (or any
investigations related thereto), you must
preserve all records and documentation related
to such matter.

nasdaq.com 26
9.
Trade Controls & Overview of Trade Control
Compliance Program
Economic Sanctions Nasdaq has appointed its Global Co-Chief
Compliance Officers as its Trade Control Compliance
As a global enterprise, our work can trigger trade Officials. The Trade Control Compliance Officials
control or export rules almost invisibly. Depending are authorized to review any questions about
on the laws involved, technology, services or compliance, investigate potential or suspected
information does not need to physically or even violations, and refer matters to executive
electronically cross a geographic border to be management or governing boards for resolution.
considered an international transaction – the fact
that the recipient (even a fellow Associate) is a Every Associate has the authority to place a “hold”
citizen of another country can be enough for it to be on any transaction or activity that he or she believes
deemed to be an export. Nasdaq is committed to may not comply with applicable trade control laws.
complying with all trade-related laws and regulations Pending resolution of the concern by a Trade Control
including those related to economic sanctions, Compliance Official, the transaction or activity will
export control, and boycotts. not proceed.

Prior to engaging in any transaction, Nasdaq Nasdaq does not engage in business dealings with
Associates must ensure that all required sanctions Sanctioned Locations. Any Associate contemplating
and trade control screening has been performed. any work involving such countries or entities in them
Because unique compliance requirements may must review the transaction with a Trade Control
apply, you must pay special attention to any Compliance Official. Unless permitted by applicable
international transactions or exports of technology- law, such work will not be approved. In addition, the
related information and ensure that they accord Trade Controls and Economic Sanctions Compliance
with all relevant Nasdaq policies including the Trade Policy identifies certain “High Risk Countries” that
Controls and Sanctions Compliance Policy. present a heighted risk of trade control compliance;
certain transactions involving such countries require
pre-approval by a Trade Control Official.
International Travel
Associates should reference the “Economic
Prior to traveling internationally, you should verify
Sanctions Export Control” table posted to Nasdaq’s
that no trade control restrictions prevent you
intranet for details on how we comply with Economic
from taking your Nasdaq laptop, phone, or other
Sanctions and Export Controls requirements as part
IT devices to your destination. This includes both
of our trade control compliance program. Please
situations where you are traveling for work or
consult our Trade Controls and Economic Sanctions
personal reasons. Business travel to ”Sanctioned
Compliance Policy and supplemental Nordic/Baltic
Locations” as set forth in the Trade Controls and
Sanctions Policy for specific requirements regarding
Sanctions Compliance Policy is prohibited except
these topics. The policy also addresses how Nasdaq
with prior approval per the policy. If you are traveling
complies with US anti- boycott regulations which
to these locations for personal reasons, you may not
prohibit Nasdaq from participating in any boycott
conduct any work activities for Nasdaq while there
that the US Government does not support including
or take any Nasdaq IT devices with you.
any boycott of Israel.

nasdaq.com 27
10.
10. Antitrust & Fair
թ Engage in Concerted Exclusions: We do not
propose, support or participate in concerted

Competition refusals to deal with, or exclusions of,

particular competitors, suppliers or customers;

թ Share Competitively Sensitive Information:

Nasdaq operates in a highly competitive
We do not share or exchange competitively
environment. We rely on superior performance,
sensitive information other than in certain
transparency, and fair business practices
legitimate collaborations or joint vendors that
for our competitive advantage. We require
are approved by OGC;
compliance with all applicable anti-trust and fair
competition laws. The intent of these laws is to թ Meet with Competitors Outside of Controlled
preclude deceptive practices, unfair methods of Environments: To avoid the appearance of
competition, and activities designed to restrain impropriety, we do not meet with a competitor
trade. They are discussed more fully in the outside a controlled environment to discuss
Antitrust and Unfair Trade Practices Policy. competitively sensitive information. Even
in controlled environments such as formal
Subject to certain exceptions outlined in the meetings, we take care not to engage
policy, we DO NOT do the following: in or facilitate an improper discussion of
competitively sensitive information;
թ Discuss Pricing and Related Topics with
Competitors: We do not discuss with actual թ Obtain Information about Competitors
or potential competitors fees, prices, pricing Unethically: We do not obtain information
policies, levels of output or sales, or other about our competitors through improper
competitively sensitive topics; means or misrepresentation or accept or use
information that has been gained or offered
թ Reveal Strategies for Anti-Competitive
through improper means;
Purposes: We do not reveal current or future
product development or marketing strategies թ Violate Prior Employment or Other
where that could be interpreted as inviting Agreements: We do not share confidential
competitors to allocate customers, product information of prior employers or violate any
markets or territories; terms of a non-disclosure, non-compete or
other similar agreement entered into prior to
joining Nasdaq.

nasdaq.com 28
11.
Anti-Money
laundering or using Nasdaq services to facilitate
money laundering including, where applicable,

Laundering notifying the compliance officer for the affected

Nasdaq entity and supporting the filling of any
required Suspicious Activity Report (SAR).
Money laundering includes any attempt to
disguise the proceeds of illegal activities so that To address money laundering-related risks to
they appear to come from legitimate sources our business, Nasdaq has implemented a global
or activities or the use of legal proceeds to Anti-Money Laundering Policy. This policy is
further future illegal activities. We comply with supplemented by additional anti-financial crime
all anti-money laundering (AML) laws and and AML policies applicable to subsidiaries
regulations that apply to our business. Where and business teams subject to specific AML
applicable, this means that we do not engage requirements.
in transactions with a potential customer until
know-your-customer (KYC) diligence has been
completed and any concerns resolved; if you
are working for a Nasdaq entity that must
complete KYC diligence, you must support the
KYC process and comply with all applicable AML
procedures. You must report any transaction
where you suspect that a customer, supplier
or other third party may be engaging in money

nasdaq.com 29
12.
Confidentiality &
have access to confidential non-public
customer or other information should

Information Security implement appropriate risk-based measures

to prevent the improper internal sharing of
such information. Such measures should
be heightened where the information is
Confidential Information sensitive or internal sharing could create an
As Nasdaq Associates, you may have actual or perceived conflict of interest or
access to non-public, confidential and/or unfair advantage to Nasdaq. All measures
proprietary information about Nasdaq, our must comply with Nasdaq Access Control
listed companies, member firms, customers, Standard and other relevant Information
partners, or suppliers. This information is Security Standards. Where appropriate,
owned exclusively by Nasdaq (or third parties the measures adopted by a team should
who have provided information to Nasdaq on a be memorialized in an internal procedures
confidential basis) and entrusted to you solely document. All Associates that support the
for authorized employment or contractual- operation and administration of the UTP
related purposes. All materials and outputs that securities information processor must comply
you create as an Associate belong to Nasdaq with relevant information security procedures
and must be treated confidentially and only and controls.
used for work for Nasdaq. You may not use,
disclose or retain Nasdaq’s confidential or Nasdaq Information
proprietary information for personal or non-job Technology Assets
related purposes.
An important component to safeguarding
You must also protect any non-public information is properly using Nasdaq
information learned during your work information technology assets. Accordingly,
for Nasdaq in accordance with relevant you must comply with applicable policies and
Information Security Policies and Standards. related guidance when using Nasdaq laptops,
Key policies include: smartphones and/or other devices. Key
policies include:
թ The Information Security Policy which
provides the overarching framework for թ The Acceptable Use Policy which defines
complying with all other Information Security the activities that are permissible when
documentation and requirements you use any Nasdaq computer, device, or
թ The Data Classification Policy which communication system
provides minimum compliance requirements թ The Mobile Device Policy which outlines
for Nasdaq data classification and the proper practices and requirements for the safe use
handling of each data category of mobile devices including smartphones
and other portable computing devices like
When receiving third party information subject
iPads, PDAs, or other tablets
to a non-disclosure agreement (NDA), you
must comply with the terms of agreement թ The Nasdaq Travel Restrictions which
including limiting use, internal distribution and prohibits business travel to certain locations
retention as required by the NDA. without prior approval and may restrict which
IT assets may be taken to certain locations
Teams within Nasdaq that, as part of their
during either business or personal travel
ordinary service delivery or functions, may

nasdaq.com 30
As further detailed in the Acceptable Use Any Associate who observes or suspects
Policy, Nasdaq IT assets are provided that a data breach may have occurred
for business use and may only be used or has a data breach reported to them
for incidental personal use in a limited by a vendor or other third party must
manner as explicitly allowed in the immediately report it to the InfoSec
policy. In no event may personal devices Hotline at DL-InfoSec-HOTLINE@nasdaq.
be used to perform work for Nasdaq, com or +1 212- 231-5750 and to their
except in exceptional circumstances management. Where data is at imminent
(e.g., a Business Continuity Plan event) risk, you should take actions reasonable to
where an individual may be instructed to secure the data. You must also preserve
leverage their personal device by Nasdaq’s all information that you have related to
Information Security and Group Risk the incident and make such information
Management teams. Any such approval will available to the team investigating it.
include safeguards to secure information
and enable compliance with record
retention requirements.

Subject to applicable local law and

Nasdaq policies, procedures and privacy
notices, use of Nasdaq IT assets may
be monitored, audited and/or inspected
to protect the security of Nasdaq’s
information, operations, and personnel.

Reporting Potential Data

Breaches
A data breach may include any situation
data may have been inappropriately
accessed, modified or destroyed or where
the security of information may have
been compromised. This includes both
situations involving IT system security as
well as those involving information stored
in “hard copy” or paper files. For any data
breach, you must support Nasdaq efforts
to minimize its impact and comply with
its legal and contractual obligations
(including any relevant special
requirements that may apply if the
affected data includes personal data).

nasdaq.com 31
13.
Use of Open
Source Software
Any use of “open source” software in any Nasdaq
product must be done in accordance with the
Open Source Usage Licensing Policy. “Open
source” software includes any software that is
subject to an “open source,” or similar license
(such as, e.g., any of the licenses approved
by the Open Source Initiative. Open source
software is different from proprietary software
as its authors make the source code available to
others who would like to view the code, copy,
learn from it, alter or share it. Any use of open
source software in Nasdaq products needs to
be assessed to ensure that Nasdaq can comply
with relevant licensing terms and obligations,
and that any such use does not pose undue
legal or security risks. Please contact the Open
Source Committee at [email protected]
prior to utilizing open source software, or should
you have questions about whether certain open
source software is suitable to be used for a
particular product.

nasdaq.com 32
14.
Personal Data & Privacy
Nasdaq considers privacy and personal data protection to be a fundamental human right. We are
committed to respecting and complying with all laws and regulations that apply to the collection,
use, distribution, destruction, and other processing of personal data. Personal data encompasses
any data about an identified or identifiable individual. For each jurisdiction in which we operate,
personal data includes any information governed by applicable privacy and personal data
protection laws.

Nasdaq applies to the following core concepts which are based on the principles within the
European Union General Data Protection Regulation (GDPR) to its processing of personal data:

Description Principle
Lawfulness, Fairness and Transparency We are transparent about how we use personal data - we “say what we do and do what we say”
Purpose Limitation We only process personal data for explicit and legitimate purposes
We limit use of personal data to what is relevant and what is necessary in relation to the purpose
Data Minimization
for processing it
Accuracy We keep personal data accurate and current – inaccurate data should be corrected or deleted
We retain personal data only as long as necessary to achieve the purpose for which it is being
Storage Limitation
processed
We ensure appropriate security against improper use, modification or loss and report any
Integrity and Confidentiality suspected or identified breach, loss or misuse of personal data. Report any potential breach to the
InfoSec Hotline: 1-212-231-5750 or [email protected]

The Data Classification Policy documents how different types where the data originates, circumstances where Nasdaq IT
of personal data correlate to Nasdaq’s data categories for systems storing the data are located outside of the jurisdiction
information security purposes. In addition to the applicable or situations where Nasdaq engages a supplier (including a
Information Security Policies and Standards, the following are key cloud storage service provider) that is located outside of such
privacy policies: jurisdiction. You should consult with OGC prior to making or
authorizing such a “cross-border” transfer of personal data;
թ Nasdaq’s general Privacy Policy posted at https://www.
if required, OGC will conduct a transfer assessment and
nasdaq.com/privacy-statement documents how Nasdaq
may require that additional measures or contract terms be
processes personal data in the execution of its business
implemented to address the transfer.
operations

թ Nasdaq’s Data Processor Privacy Notice posted at https:// When using personal data for marketing purposes, you must

www.nasdaq.com/privacy-statement-processor applies to adhere to relevant Nasdaq policies and procedures. These

services where Nasdaq processes personal data on behalf include those related to ensuring that any needed consents to

of a customer conduct marketing are obtained and any required notifications

provided.
թ Nasdaq’s Associate Privacy Notices document how
Associates’ personal data is processed We respect individuals’ exercising their legal rights over their
personal data including, as allowed under applicable law, the
In addition, certain privacy laws such as the EU GDPR may
right to obtain and correct information and the right to have
restrict transferring personal data to another jurisdiction or
information deleted. If you receive a request from an individual
require that Nasdaq conduct an assessment prior to making
about personal data held by Nasdaq, you should refer the
such a transfer. These restrictions may apply to transfers to
individual to the Privacy Team in the Office of General Counsel
Nasdaq affiliates established outside of the “home jurisdiction”
at [email protected].

nasdaq.com 33
15.
Ethical Supplier
policies and/or disclose financial holdings or
certain business activities. Specific application

& Expense of this Code or a particular policy requirement to

such an individual may be set forth in relevant
Management policies, the contract, individual certifications, or
other documents executed by the non-employee.

As stewards of Nasdaq and its assets, each of

us has a responsibility to use company resources Ethics & Compliance
wisely. This includes only engaging suppliers Expectations for Suppliers
that share our commitment to ethical business
Consistent with its expectations for Associates,
and making purchasing decisions that advance
Nasdaq seeks to only conduct business with
Nasdaq’s best interests, adhere to applicable
reputable suppliers who share our commitment
policies and procedures, and manage risk. It
to ethics and compliance in the conduct of
also includes carefully monitoring suppliers
their business. Nasdaq’s Supplier Code of
that we have retained to ensure that they are
Ethics sets forth its expectations for suppliers
meeting all specifications and requirements and
doing business with Nasdaq. Nasdaq expects
that all conditions for payment have been met.
suppliers to comply with Nasdaq’s Supplier Code
By doing so, we not only protect the company
of Ethics either through internally established
from risk but also optimize performance and
policies or adhering to the standards therein.
promote efficiency. Any concerns about improper
contracting practices, fraud or unauthorized All suppliers are subject to pre-engagement and
invoicing must be escalated immediately through continuous screening in accordance with our
one of the Guidance and Reporting Channels set Supplier Engagement and Management Policy.
forth in this Code. In particular, Nasdaq does not do business
with suppliers that are known or reasonably
Application to Suppliers and suspected of:
Contractors
Nasdaq vendors, suppliers, and temporary/ թ Engaging in human rights abuses (including
contingent staffing companies contracting with activities that violate the rights of native or
Nasdaq or an affiliate are expected to conduct indigenous peoples), child labor, forced labor
themselves in a manner consistent with this or human trafficking including, but not limited
Code when doing work for Nasdaq and may to, any activities that are considered “modern
be contractually required to comply with this slavery” under the UK or Australia Modern
Code, Nasdaq’s Supplier Code of Ethics, and any Slavery Acts;
applicable Nasdaq policies. No employee may թ Dealing in counterfeit or “black market” goods
authorize any supplier to engage in any activities or the unauthorized resale or distribution of
prohibited by this Code or applicable Nasdaq goods or services;
policies.
թ Being owned or controlled by any specially
Application of this Code to a non-employee designated national, blocked person or
performing work for Nasdaq will be consistent other individual with whom Nasdaq may not
with the nature and scope of the role of the do business under U.S., European Union or
individual relative to Nasdaq’s business. Based United Nations sanctions;
on the services performed by a non-employee թ Serving as an intermediary or “front” for an
and the Nasdaq legal entity receiving the enterprise engaging in unlawful activities or
services, the individual may be required to the evasion of legal requirements;
certify compliance with this Code and related

nasdaq.com 34
թ Being subject to unsatisfied judgments, suppliers or making purchases on behalf of
liens, delinquent debt, unpaid taxes or other Nasdaq. Key relevant policies include:
factors indicating financial instability or
թ The Expense Management Policy which
incapacity to perform;
contains standards, rules and processes
թ Infringing on the intellectual property rights
to be followed when procuring necessary
of others; or,
goods and services on behalf of Nasdaq
թ Providing inadequate protection and security
թ The Supplier Engagement and Management
to sensitive or personal data.
Policy which sets forth various stakeholder

When assessing whether to engage a supplier, roles and responsibilities as well as

in addition to cost and technical qualifications, standards, rules, and processes when

each of us involved in the decision making engaging a supplier to provide goods and/

is expected to evaluate the capability of or services to Nasdaq, including pre-

the supplier to meet relevant compliance contract supplier due diligence and ongoing

obligations and the potential risk to Nasdaq of monitoring of existing supplier relationships

an ethics or compliance failure by the supplier. թ The Contingent Workforce Policy which
Additional considerations, as relevant, should contains the standards, rules and process
include Nasdaq’s goals and commitments to be followed when onboarding or seeking
related to sustainability, environmental impact, the services of non-employees at Nasdaq to
human rights and promotion of diversity. perform work for Nasdaq
Such evaluation should consider whether the
թ The Contract Review and Approval Policy
supplier will be subcontracting part of the
which ensures that all contracts to which
work and the risk posed to Nasdaq by the
Nasdaq is a party are properly reviewed,
supplier’s own supply chain (including whether
prepared, approved, and executed by
such supply chain poses compliance risk to
authorized personnel
Nasdaq). In no event may an Associate engage
թ The Global Signature Authorization and
a third party for any activity that is prohibited by
Delegation of Authority Policy which
this Code, Nasdaq policies or applicable law.
establishes a framework for identifying
As set forth in this Code, each of us must individuals who have the properly delegated
report any conflicts of interests related to a authority to execute contracts and certain
contemplated supplier and must comply with other categories of documents on behalf of
the Related Parties Transactions Policy for a Nasdaq company
any contract.
թ The Travel & Entertainment Reimbursement
Policy which contains the standards,
Compliance with Supplier rules and processes to be followed when
Selection & Contracting committing Nasdaq funds for a travel
or business expense and when seeking
Policies
reimbursement for such expenditures
Nasdaq has established a number of policies to
By following Nasdaq’s policies and drawing on
address risks and requirements related to the
expertise within the Strategic Sourcing team,
supplier engagement, contracting and payment
we are able to achieve better outcomes, avoid
process. These policies help ensure that
duplication of effort and leverage Nasdaq’s
Nasdaq complies with relevant regulations,
aggregate buying power to reduce cost. This
manages risk and promotes ethical supply
includes using preferred suppliers that have
chain management. Associates must comply
been approved by Strategic Sourcing.
with all relevant policies when engaging with

nasdaq.com 35
In approving invoices and accepting work/
Reporting Concerns
deliverables, you must apply reasonable
scrutiny to ensure that relevant specifications You should immediately report any ethics and
and requirements have been met. Where work compliance concerns related to any part of
is not acceptably performed, the Office of Nasdaq’s supply chain to one of the Guidance
General Counsel and Strategic Sourcing should and Reporting Channels identified in this
be engaged to protect Nasdaq’s contract rights Code. This can include potential fraudulent
and best interests. or unethical billing practices by a supplier;
failure by a supplier to meet its compliance
obligations; or, unlawful or corrupt activities by
Use of Corporate
a supplier or one of its employees.
Credit Cards
Similarly, suppliers doing business with
You may only use corporate credit cards
Nasdaq are expected to report any ethics or
only for transaction types permitted by the
compliance concerns that they have related to
Travel and Entertainment Reimbursement
their work with Nasdaq. Such concerns can be
Policy. Non-employees are prohibited from
raised to the Supplier Risk Management Team,
using corporate credit cards. Unless you have
the Office of General Counsel or the SpeakUp!
been authorized to incur other expense types
Line. Nasdaq will investigate any reported
on your corporate card, all other expenses
concerns consistent with how it reviews other
must be appropriately categorized and
alleged violations.
routed through the procurement process.
In submitting an expense report, you are
certifying that the claimed amounts and
related descriptions are true and accurate to
the best of your knowledge.

nasdaq.com 36
16.
External
receive compensation from any source other
than Nasdaq for a teaching, speaking or writing

Communications engagement that relates, or provides any

benefits to your official duties at Nasdaq without
prior written approval from your supervisor, who
may consult with the Global Ethics Team (see
Public Speaking, Teaching, & provisions on Outside Business Activities above).
Writing Engagements Expenses incurred in connection with approved
speaking engagements on behalf of Nasdaq
Corporate Communications is responsible for
(e.g., travel and accommodations) should be
managing all external speaking roles on behalf of
paid by Nasdaq.
Nasdaq. An Associate may not speak on behalf
of Nasdaq or engage in a panel or other external
presentation related to their role at Nasdaq Social Media
or professional activities unless specifically
The Nasdaq Social Media Policy provides
authorized to do so by their manager, business
guidance on communicating via social media.
unit leader and Corporate Communications.
As further described in the policy, the Code
Written approval must be obtained from all and all policies apply to use of social media as
three before accepting any such engagement. they would apply in any other situation. Take
Requests for speaking roles should be sent to care in all communications, including social
[email protected] for approval. media, to avoid disclosing Nasdaq or third party
confidential information (including material
All writing engagements on behalf of Nasdaq
non-public information). Remember that you
(e.g., byline, research paper, op-ed) must also
represent Nasdaq outside of the workplace,
be approved by the business unit leader, OGC
including anything you post or comment on via
and Corporate Communications. You may not
your online presence.

nasdaq.com 37