This tax policy applies to Nasdaq, Inc. (“Nasdaq” or the “Company”) and all of our subsidiaries globally and describes the principles that form the foundation of our approach to tax. Our responsibilities as a global taxpayer include accurately calculating, reporting and paying the Company’s corporate income taxes. Our goal is to minimize organizational tax risk exposure by staying current on tax law changes, implementing robust controls around our processes and avoid overly aggressive tax planning strategies which would prevent the Company from paying its fair share of taxes and contributing to the economic success of countries in which we operate. We only engage in transactions with sufficient economic substance and do not invest in tax havens for the purpose of tax avoidance.

Management approach to Tax Policy

While the Global Head of Tax is responsible for day to day management of our tax policy, the Executive Vice President and Chief Financial Officer participates in the development of the tax policy and is responsible for ensuring its contents align with the organization’s overall strategy and goals. The Company is committed to complying with tax laws in a responsible manner and to having open and constructive relationships with tax authorities. Our approach to tax aligns with Nasdaq’s Code of Ethics, which clearly sets out what is expected of all directors, officers and employees of Nasdaq and its subsidiaries, as well as consultants and contractors and others who work on behalf of Nasdaq or its subsidiaries. We embrace good governance and hold ourselves to the highest ethical standards in all interactions as trusted partners to shareholders, regulators, clients and the wider investing public.

Tax governance, control, and risk management

We manage tax risks through an internally created risk assessment process across various tax functions to improve visibility for stakeholders and to reduce or avoid potential economic and reputational risk. Each tax function is responsible for periodically updating their material topic and creating transparency for management to track potential exposure to risk. The Tax department stays connected to the overall business strategy and advises on tax considerations. The Tax department is involved in forward looking processes, performing diligence in transactions to avoid risk during acquisitions and dispositions of companies.

Tax review is embedded in critical risk areas, including contract management, legal entity management, cross border arrangement, employee tax, financial accounting reporting and other areas. The Tax department provides regular training and updates on latest tax rates, rules and regulations, to other internal organizations. The Tax department acts as both a first and second line of defense to execute and monitor controls to identify tax risk. Risks are reported in the Tax organization to the Head of Tax and escalated as needed to the Chief Accounting Officer and the Chief Financial Officer, and the Audit & Risk Committee of the Board of Directors.

The Head of Tax and tax subject matter experts monitor the tax function for compliance with Nasdaq’s overall risk appetite. Nasdaq and its eligible subsidiaries file a consolidated U.S. federal income tax return and applicable state and local income tax returns, as well as our applicable non-U.S. income tax returns. We are subject to examination by federal, state, local, and foreign tax authorities.

Stakeholder engagement and management of concerns related to tax

We strive for open and transparent communication with the tax authorities, including timely responses to audit requests and effective disclosure. The Tax department partners with our public advocacy group across the globe to educate our stakeholders on potential legislation and the tax-related impact to Nasdaq and our subsidiaries.