Ensuring fair & efficient markets

ICE is uniquely positioned to enhance and facilitate the optimal functioning and efficiency of global markets. Owning and operating global exchanges can expose us to certain risks, including the regulatory responsibilities to which our businesses are subject. Our exchanges are responsible for enforcing rules and listed company compliance with applicable listing standards, overseeing regulatory policy determinations, rule interpretation and regulation-related rule development, and conducting trade reviews. Potential failure by our exchanges to comply with and enforce compliance by their members with relevant exchange rules and securities laws could significantly harm our reputation, prompt regulatory review and adversely affect our business and operating results.

We allocate significant resources to fulfill our self-regulatory responsibilities at our exchanges. To that end, we are committed to not only foster a culture of compliance within our organization, but also to collaborate with organizations and relevant stakeholders on matters relating to transparency, bribery, corruption, and other compliance matters.

Fostering a Culture of Compliance

Whistleblower Procedures

Complaints or concerns related to ICE accounting, auditing, internal controls or financial reporting can be submitted anonymously and confidentially. ICE employees around the world have access to the Whistleblower Hotline which can be easily found on the company’s internal website. For external parties wishing to access the Whistleblower Hotline, they can refer to the Global Code of Business Conduct document available at ir.theice.com.

ICE also has separate policies on the following business procedures and these are available on the company website.

Our Board of Directors sets high standards for the company’s employees, officers and directors. Implicit in this philosophy is the importance of sound understanding of the company’s policies and procedures. As highlighted in the “One company and team culture” section of this report, ICE has implemented robust training programs for all employees to be regularly trained on policies and procedures, and regularly evaluates where ICE is doing well and where it may need to focus additional efforts.

Regulation and Compliance

ICE works with regulators and policy makers around the world regarding the supervision, compliance and reliable operation of our network of global futures and equity exchanges. As a leader in the development of transparent, global markets, ICE works with market participants to maintain the confidence of participants and the integrity of markets. The following is a partial list of some of the regulatory organizations we work with:

Advocacy and Collaboration

Our business principles encourage us to contribute to discussions on policy issues that affect our businesses, employees and the communities in which we operate. These principles also support and encourage respect, transparency and compliance, while prohibiting bribery, corruption and discrimination. We share our knowledge and expertise with legislators, regulators, industry organizations and others to contribute to the development of policy initiatives.

ICE has a U.S. political action committee (PAC) and it is supported entirely by voluntary employee and director contributions. Our policies prohibit the use of corporate funds to make contributions to candidates, political party committees and political action committees (PAC), or to fund independent political expenditures. 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 FEC.gov.

Through collaboration with and membership in various industry organizations around the world, we engage and understand different perspectives from a variety of customers and stakeholders. Examples of membership in these groups, including those required to be disclosed through the ICE PAC requirements, include:

New York stock exchange global visibility

We advocate on behalf of our listed companies and provide them with a venue for promoting their respective businesses to employees, customers and the broader financial community. Ringing The Opening® or Closing® Bell at the New York Stock Exchange is a unique experience, and one that garners visibility and media coverage around the world twice a day. We offer the opportunity to ring the bell, visit the trading floor and conduct interviews with the media to a variety of governmental, academic and non-profit organizations every year. The list is long of those organizations that have participated, but the list below offers a sampling of those non-profits that have participated.