Our Sustainability Oversight Structure


Our Board is committed to overseeing Nasdaq’s integration of sustainability principles and practices throughout the enterprise. The Nominating & ESG Committee has formal responsibility and oversight for ESG policies and programs and receives regular reporting on related key matters. The Audit & Risk Committee oversees company-wide risk management, including ESG-related risks.

42%
of our Directors have experience with environmental and social matters

Board Diversity

The Board values diversity in evaluating new candidates and seeks to incorporate a wide range of attributes across the Board of Directors and on each of our Committees.

Ethics and Compliance

The Nasdaq Code of Ethics, in conjunction with other policies, procedures, standards and handbooks, outlines the responsibilities expected of Nasdaq officers, directors and employees in conducting business in accordance with the highest standards of ethics and compliance.

In 2023, we furthered the use of automation and analytics in supporting compliance programs to drive effectiveness and reduce risk, completed updates of our Code of Ethics and related policies to make them more engaging to our employees and address evolutions in our business and enhanced employee training programs through additional focus on targeted topics.

The Nasdaq Code of Ethics, in conjunction with other policies, procedures, standards and handbooks, outlines the responsibilities expected of Nasdaq officers, directors and employees in conducting business in accordance with the highest standards of ethics and compliance.

In 2023, we furthered the use of automation and analytics in supporting compliance programs to drive effectiveness and reduce risk, completed updates of our Code of Ethics and related policies to make them more engaging to our employees and address evolutions in our business and enhanced employee training programs through additional focus on targeted topics.

A list of icons and text describing the Training topics included in Nasdaq's Ethics and Compliance according to the 2023 Sustainability Report.
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Cybersecurity and Information Security

Cybersecurity is an integral part of risk management at Nasdaq. The Information Security Department (ISD) is responsible for coordinating the protection of our core business operations and information against real-world cyber threats by employing technology, policy, processes, education programs and sound design techniques across the organization. 

On an annual basis, the Information Security team reviews and updates its governance documents, such as the Information Security Charter, the Information Security Policy and the Information Security Program Plan and then presents the revised documents to the Audit & Risk Committee for review and/or approval.

During 2023, the Information Security team finalized a new three-year Cybersecurity Strategic Plan, which outlines the strategic vision and associated goals for the cybersecurity of Nasdaq's global operations for 2023 through the end of 2025.

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Responsible AI Practices

We are committed to the ethical and responsible use of AI in our products, services and business operations. Our AI governance structure aligns the application of AI with our core values through a framework that addresses the new and unique risks that AI technology presents, while enabling us to explore innovation and take advantage of opportunities that AI presents to better serve our customers, advance our business objectives and bring value to our shareholders.

The framework puts into practice Nasdaq’s responsible AI usage principles and considers the U.S. National Institute of Standards and Technology AI Risk Management Framework. It is administered through company-wide policies, procedures and supporting preventative and detective controls.

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Climate-Related Risk

Nasdaq regularly evaluates climate risks that may affect our products and services, value chain, operations and investments. We perform detailed evaluations focused primarily on the types of risks that are likely to increase direct costs or interrupt our primary business functions.

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