Upholding Robust Governance for a Resilient Future
This summary highlights key initiatives from the Governance section of the Nasdaq 2025 Sustainability Report.
Sustainability Oversight Structure
The Nominating & Governance Committee of Nasdaq's Board oversees sustainability policies and receives regular sustainability-related updates. The Board Audit & Risk Committee addresses company-wide and sustainability-related risks.
As of June 10, 2026:
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, five out of 12 (42%) are women, and two out of 12 (17%) have sustainability-related skills and expertise.
92%
Independent
Employee Trainings
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.
100%
of full- and part-time employees receive training
Topics Include:
- Ethics, Integrity, and Conflicts of Interest
- Human Rights and Modern Slavery
- Cybersecurity Awareness and Privacy
- Anti-Financial Crime and Anti-Money Laundering
- Economic Sanctions and Trade Controls
- Insider Trading
- Nasdaq's SpeakUp! Program
- Risk Management
- Responsible Use of AI
- 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 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.
"At Nasdaq, we prioritize information security risks, while operating on an adaptable and resilient cybersecurity platform."
- Louis Modano, EVP and Chief Information Security Officer, Nasdaq
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 unique risks 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 (NIST) AI Risk Management Framework. It is administered and available to all employees through company‑wide policies, procedures, and supporting preventative and detective controls. In 2025, to help advance internal AI governance and adoption, Nasdaq established a dedicated AI Integration Team led by the newly appointed Chief AI Integration Officer.
"Robust governance and ethical guidelines enable our use of AI to remain responsible, transparent, and aligned with our corporate values.”
- Donald Beery, Chief AI Integration Officer, Nasdaq
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.