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We contribute to discussions on policy issues that impact our businesses, industries, employees and the communities in which we operate. We share our knowledge and expertise with legislators, regulators, industry organizations, the media and others to contribute to the development of well-informed policy initiatives.

Corporate Political Donations

Our policies prohibit the use of corporate funds to make contributions to any candidates, political committees or other entities organized primarily for political activities under section 527 of the Internal Revenue Code or under 501(c)(4) of the Internal Revenue Code, or to any political party that would use the money to support any candidates. Our policies also prohibit direct independent expenditures as defined by the Federal Election Commission.

Board Oversight

Our Board of Directors has oversight of the Company’s policies related to political and campaign contributions and other political expenditures with explicit authority in the Nominating and Corporate Governance Committee charter.

Employee Political Action Committee

ICE has a Political Action Committee, or PAC, in the U.S., which is supported entirely by voluntary employee and director contributions. A statement of organization for ICE PAC was filed with the Federal Election Commission in January 2008 and all expenditures of the PAC are publicly available at

Industry Organizations

We collaborate with, and belong to, various industry organizations around the world to help further engage and understand different perspectives from a variety of customers and stakeholders. This includes the following organizations, which we pay annual fees of $25,000 or more to, none of which exceed $150,000:

  • Analysis & Resilience Center (ARC)*
  • Bond Dealers of America (BDA)
  • CCP12City UK*
  • Commodity Markets Council (CMC)*
  • Cotton Council International
  • European Association of CCP Clearing Houses (EACH)
  • Federation of European Securities Exchanges (FESE)*
  • Financial Information Services Division (FISD)*
  • Financial Services | Information Sharing and Analysis Center (FS-ISAC)
  • Futures Industry Association (FIA)*
  • Index Industry Association*
  • Institute for Information Security and Privacy - Georgia Tech
  • International Emissions Trading Association (IETA)
  • International Swaps and Derivatives Association (ISDA)*
  • National Futures Association (NFA)*
  • Practising Law Institute
  • World Federation of Exchanges (WFE)*
* Per the ICE-PAC Operating & Political Contribution Guidelines, the above list includes all U.S. trade organizations to which we paid membership dues, special assessments or other payments in excess of $50,000, and to the extent available, the portion of such payments in excess of $50,000 reported by the Company as being used by the association for political purposes.