We have an Enterprise Risk Management team, led by the Chief Corporate Risk Officer. The team includes regional Chief Risk Officers that oversee each business unit.

We employ a three-lines model to enterprise risk management, a concept endorsed by the Institute of Internal Auditors. This framework helps ensure strong redundancies and preparation.

ICE ensures both the physical and digital security of our markets, clearing houses, data and mortgage software through industry-leading security technology and processes. Our Information Security Department consists of diverse and skilled teams that work to protect confidential data and systems from unauthorized access, misuse, disclosure, destruction, modification or disruption.

We employ the activities, processes and strategies to help evaluate, manage and address these risks, which are described in our 10-K.

Additional details are available in our Privacy & Security Center.

ICE maintains a robust technology infrastructure and business continuity strategy designed to ensure the reliability and security of our critical market operations.

Our comprehensive approach to operational resilience encompasses:

We implement redundancy strategies across:

Our resilience strategy is supported by:

By maintaining a dynamic and comprehensive approach to operational continuity, we mitigate potential disruptions and preserve the integrity of our critical services.

Our Board and management team set the tone for our culture and hold all employees, contractors and consultants accountable for operating ethically and in compliance with labor laws, financial regulations and other standards that apply to our businesses. We provide relevant tools, resources and training to help employees succeed and to recognize ethical decision-making. Our compliance team is led by the Vice President for Compliance, who reports to the General Counsel.

Our compliance policies are approved by the board’s Nominating and Corporate Governance Committee and reviewed regularly and assessed for effectiveness. All employees (full and part time) globally, as well as contractors, are trained, tested and must attest that they have read and understand the appropriate policies upon hire and annually thereafter. Test scores are assessed to ensure understanding. Any breach of our policies is investigated, and, when necessary, appropriate actions are taken, which may include termination of employment. Our policies include:

Our Code of Business Conduct is an outline of the rules and principles by which we operate on a global basis. It is not a comprehensive manual that covers every possible situation – no document could be. It is a guide that serves as a reference and a reminder. At ICE, we do the right thing not because it is written in a code but because it is part of our ethos and the commitment we are making to our customers who trust us with their investing and risk management needs.

The Code is framed around ICE’s core values: collaboration, problem solving, communication, integrity & professionalism and leadership.

It encourages employees to come forward with questions, concerns and reports of actual or suspected misconduct with the confidence that ICE’s commitment to non-retaliation is firm. We take all claims of retaliation seriously, investigating each one thoroughly and taking appropriate action.

The Code covers topics including:

Procedures are in place requiring that gifts, meals and entertainment given to or received from a business partner above certain thresholds be reported to and approved by the compliance department. Additionally, gifts, meals and entertainment given to or received from a government official must be reported at any level not considered de minimis.

As part of our Global Reporting and Anti-Fraud Policy, we have a Protected Disclosure Hotline (formerly known as the Whistleblower Hotline) that can be accessed easily through both external and internal resources.

Good governance is the bedrock of capital markets and as a publicly-traded company and the owner of the New York Stock Exchange we recognize its importance and consider ourselves stewards in promoting it. It is the duty of the Board of Directors to serve as a prudent fiduciary for shareholders and to oversee the management of the company's business.

Note: As of May 2025.