Intercontinental Exchange
Corporate Responsibility

Investing in Our People

Offering opportunities and supporting core values

Being a part of the Intercontinental Exchange team means being at the heart of a global industry and being part of a dynamic company that emphasizes growth, results and opportunities. We engineer technology, and operate exchanges, clearing houses and an expanding data services business — all on a global scale.

Our culture is a combination of entrepreneurial spirit, a passion for our business and a commitment to serving customers. To reach our business goals, we must have a positive working environment and employees who are engaged and committed to success. Most of all, our employees must focus on delivering world-class products and services to our customers. Career opportunities for our employees are driven by our long-term focus on growth. ICE’s ability to attract and retain talented individuals is due in large part to our strong global reputation and our culture.

We aspire to four core competencies that apply to all employees regardless of roles, responsibilities or geography. We integrate functional expertise and skills with the development of our core competencies:


We also have a pay-for-performance culture that aligns the interests of our employees and shareholders. Our orientation toward performance-based compensation has been a part of ICE since our founding, and is evident throughout the organization. As employees gain more experience and responsibilities, their compensation becomes increasingly based on performance. Employees at all levels are eligible for performance incentives. The amount of compensation delivered via variable compensation programs varies by role, but we note that virtually all employees participate in variable compensation programs, including equity-based programs.

This pay for performance philosophy is also clearly evident at the senior executive level as well, where 87 percent of targeted compensation for our named executive officers (NEOs), as designated in our Proxy Statement, is earned through variable, performance-based compensation elements in 2015. In addition, 61 percent of targeted compensation was delivered through long-term equity-based incentives (composed of stock options and performance-based restricted stock unit awards) and 26 percent was delivered through annual performance incentives which were established through the targeted 2015 cash bonus awards under the Executive Bonus Plan.

The degree to which we focus on variable incentive compensation, rather than fixed compensation, distinguishes us from our peer group and supports and strengthens the culture that has made ICE successful.

For further detail, please review our Proxy Statement at http://ir.theice.com.

Framework built around core competencies

Our published core competencies are so integral to our results, and they serve as the foundation of our Global Code of Business Conduct, available at http://ir.theice.com. We believe that one person can make a difference, so it is vital that each individual acts with integrity. This Global Code of Business Conduct is our guide and demonstrates to our employees, customers, regulators, and shareholders that we take our responsibility as a global financial services company seriously. It also helps us maintain the trust we have built with our customers, fellow employees, and others who have a stake in our success. Additionally, our Code is supplemented with mandatory training programs for employees to support compliance and a full understanding of our ICE values and requirements.

Teamwork means that each of us offers assistance to colleagues and that we collaborate and interact without regard to title, level or position. Individuals share knowledge, mentor staff and work to develop others’ knowledge as well as their own. ICE employees contribute to recruiting and training others and share credit with the team. We also encourage employees to attend and participate in company and department level functions inside and outside the office to build and maintain important social networks.

Communication requires active listening. We look for individuals to approach communication in a transparent and open manner to facilitate clear messages, support learning and facilitate problem-solving. We work hard to build consensus among different views. We encourage constructive debate, but fully commit and support each other once decisions are made.

Problem-solving and decision-making requires an understanding of the urgent nature of our business and the need to proactively find and fix problems quickly and effectively. We want employees who take ownership and follow through on decisions. It is important to determine and fix the root cause, rather than just treat the symptoms. We embrace change wholeheartedly and find new ways to serve customers.

Professionalism and integrity ensures that employees demonstrate a willingness to make commitments based on all information and deliver on those commitments. We evaluate lessons learned from both success and failure, while not excessively celebrating victories or mourning defeats. ICE employees must model a “can do” attitude and take initiative, as well as inspire and motivate others to do the same. Employees must adhere to all corporate policies, make prudent use of company resources and act with complete integrity in all matters.

In addition to these core competencies, our competency framework extends to each specific functional area in the company -- operations, sales & marketing, technology, business support and product development. These functional competencies emphasize topics such as technical knowledge, quality and innovation.

One company and team culture

Our success has been built by operating as one company -- one culture and team, one focus on growth and innovation, and one measure of success which focuses on serving customers and delivering value to our shareholders. Our team works together toward achieving success by aligning our global efforts with the company’s priorities. We treat one another with respect. We keep an open mind to new ideas and points of view. We value the differences each of us brings to ICE. All of these points are central to ICE’s culture.

As a company that operates in dozens of markets around the world, it is a business imperative to attract and retain a workforce that reflects the diversity and global range of our client base and the markets in which we operate. We are committed to inclusion and to hiring a workforce representing a wide range of backgrounds, cultures, and experiences. Our commitment includes meeting all requirements for being an equal opportunity employer. Harassment and violence are not tolerated at any ICE location, and we encourage any employee who is concerned to report their concern to management or our whistleblower hotline. Additionally, we regard personal privacy and confidential information with utmost care for both our employees and our customers.

The company provides daily news clips and a weekly update distributed to all employees to ensure they stay educated about our global business. This includes a recap of our business news, including daily volumes for our businesses, media coverage highlights on our company and industry, relevant HR news, and upcoming events. Our employee intranet site gives every employee the opportunity to set up a personal blog site, and the community section is geared toward local news and activities.

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Culture of Compliance

ICE is committed to maintaining its strong culture of compliance, not only with ICE’s own policies and procedures, but also with labor laws, financial regulations, and other standards and ethics guidelines that apply to global businesses. Where appropriate, we require compliance of both our employees and of our consultants, such as requiring global personal trading policies.

We dedicate significant resources to provide training related to areas that if not upheld and understood, can lead to compliance violations. We have a detailed orientation program for all new employees that provide an overview of the policies and code of conduct that must be adhered to. Every employee is required to take web-based training on these policies as a new hire and also periodically throughout employment. We provide further specialized training for employees based on their job functions, including specialized training on compliance, risk management and ethics. Training is typically delivered via interactive electronic modules but also via in-person sessions where appropriate, each of which includes testing to ensure understanding. Through these sessions, ICE’s compliance team receives specific analytical feedback that illustrates where it may need to focus additional efforts.

Our web-based education system is customized for each employee to ensure compliance with the training that is mentioned above. The system captures mandatory training, as well as programs that are optional and available to all employees, including programs on communication, management and leadership, presentation skills, change management, customer service and technology training, among others. Managers also have the ability to develop and manage training programs for their team.

We also expect our employees to report violations of applicable laws and standards. Employees can submit an email through www.ethicspoint.com or call the toll-free hotline. All reports can be made on a fully disclosed or on an anonymous basis. In addition to the Global Corporate Compliance Department, employees may access the Legal Department for additional assistance. The Audit Committee Chair will receive all complaints and concerns related to corporate misconduct and internal controls or auditing matters, and may designate a person within the company to assist with the investigation.

Investing in our communities

An additional facet of ICE’s culture is our commitment to strengthening our local communities. We do this through financial support, primarily delivered via the ICE NYSE Foundation, and inspiring our employees to engage in charitable giving as well, with matching gift support. Our philanthropic efforts also complement our business activities, such as financial literacy, and provide employees opportunities to invest and engage in their communities while continuing their development outside of the workplace.

The ICE NYSE Foundation has a strong commitment to supporting financial literacy, military veterans’ initiatives, and charitable organizations. Our Foundation is proud to support the philanthropic activities of ICE employees through a matching gift program for financial contributions to employees’ chosen charities. Among the types of organizations that have benefitted from our matching gift program are universities, health organizations, food banks, global aid organizations and programs that benefit veterans.

Beyond the matching gift program, ICE and our employees also support larger programs, whether internationally or locally. Below are some examples:

  • Integrated in our company’s commitment to financial literacy is our support of The Museum of American Finance, based in New York City. The museum is the nation’s only independent museum dedicated to preserving, exhibiting and teaching about American finance and financial history. Housed in an historic bank building on Wall Street near the New York Stock Exchange, the Museum provides a setting for permanent exhibits on the financial markets, money, banking, and entrepreneurship. The museum also sponsors educational programs, including sessions featuring speakers from the NYSE.
  • On behalf of our customers, ICE makes an annual donation to help support the relief efforts of the Red Cross, which provides humanitarian aid amid disasters large and small, provides vital blood services, connects service members with their families and supports preparedness training.
  • We are honored to support the work of the Institute for Veterans and Military Families at Syracuse University (IVMF) as a Corporate Partner. Our commitment benefits the IVMF's hands-on programs, activities and projects focused on helping veterans and military families make the transition to post-service life. The support assists the growth of existing education and employment programming and seed development of new programs, initiatives and publications.
  • We are also proud to support Veterans on Wall Street (VOWS).
  • Over the past several years, and in partnership with Habitat for Humanity, ICE employees have helped construct new homes from start to finish for working families.
  • We are lending leadership and financial support to some long-term Atlanta community initiatives, such as the Atlanta BeltLine. This is a sustainable redevelopment project that will provide a network of public parks, multi-use trails and transit along a historic 22-mile railroad corridor circling downtown and connecting many neighborhoods directly to each other.
  • ICE employees participate in the JP Morgan Corporate Challenge series in multiple cities to support the JP Morgan Chase Foundation. The Foundation makes locally-designated donations at each event in six countries on five continents.
  • ICE employees participate in the SkyRise Chicago climb, an event that raises funds for the Rehabilitation Institute of Chicago’s world-class clinical care and innovative research. Participants climb 103 flights of stairs of Willis Tower.
  • ICE supports the annual A Leg To Stand On events held in Chicago and New York. A Leg To Stand On provides prosthetic limbs and corrective surgery to children in developing countries who have lost their limbs traumatically or congenitally.
  • The New York Stock Exchange proudly supports the New York Police Department and the Fire Department of New York as they protect the communities around the New York Stock Exchange.
  • Coffee and cocoa samples from our grading facility in New York are donated to various food banks. Samples of all lots of coffee deliverable under the ICE Futures U.S. Coffee C contract are roasted by our employees and graded by exchange-licensed graders. Unused coffee samples are roasted, ground, packaged by a New Jersey-based coffee company, and donated to non-profit organizations. In addition, ICE Futures U.S. routinely donates use of its grading room to coffee and cocoa trade organizations.
  • The ICE Futures Charitable Trust in the U.K. provides financial donations to charities supporting the welfare and education of children and others with special needs and other such purposes as determined by the directors. The Trust has continued to support a small number of charities in the London area, which are aligned to these objectives.
  • Many of our firm’s senior leaders are also active in their communities and lead by example.
    • Our Chairman and CEO, Jeffrey Sprecher, chairs the Atlanta Police Foundation 2016 Capital Campaign. The “Cutting Edge, Cutting Crime” campaign has a goal of raising over $15 million to increase the number of police officers on the streets, engagement from the business community and neighborhood residents, and the implementation of the latest technology. Jeff is also Chair Elect of the Metro Atlanta Chamber of Commerce for 2017.
    • Scott Hill, our Chief Financial Officer, serves on the board of Make-A-Wish Georgia and Junior Achievement of Georgia.
    • Tom Farley, NYSE Group President, serves on the board of the Partnership for New York City Georgetown University’s Business, Society and Public Policy Initiative, and on the International Advisory Board for British-American Business. He also is an active member of the Alliance for Downtown New York, the Battery Conservancy, and the World Economic Forum.

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