Our Sustainability Oversight Structure
Our Board is committed to overseeing Nasdaq’s integration of sustainability principles and practices throughout the enterprise. The Nominating & Governance Committee has formal responsibility and oversight for corporate sustainability policies, goals, and programs and receives regular reporting on key matters. The Audit & Risk Committee oversees company-wide risk management, including sustainability-related risks.
Sustainability Oversight Structure
Board Composition
(As of June 11, 2025)
Our directors represent a wide range of diverse backgrounds, experiences, leadership, and skills that together embody the knowledge relevant to Nasdaq’s strategic long-term vision and global operations. 11 out of 12 (92%) are independent and five out of twelve (42%) are women.
92%
Independent
Ethics & 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.
All full- and part-time employees and contractors are required to complete trainings and certifications both at onboarding and on an annual basis. Town hall events and webinars augment this training to employees on a periodic basis. In addition, Nasdaq conducts role-based trainings and exercises to reinforce policies and procedures.
Training Topics Include:
Ethics, Integrity, and Conflicts of Interest
Cybersecurity Awareness and Privacy
Risk Management
Anti-Financial Crime and Anti-Money Laundering
Economic Sanctions and Trade Controls
Insider Trading
Responsible Use of AI
Nasdaq's SpeakUp! Program
Anti-Harassment and Discrimination*
Anti-Corruption, Gifts, and Business Entertainment
*Required training for U.S. employees residing in states where training is mandated.
Whistleblower Program and Protections
Nasdaq provides multiple channels for reporting misconduct under our SpeakUp! Program. Our SpeakUp! Line enables anonymous whistleblowing, including as required by applicable laws and regulations. The Line is available and accessible online and via a call center 24/7.
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.
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 introduces 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. Nasdaq’s AI Risk Management and Responsible Use Policy is accessible to all employees.
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.