Global Trading Policy
Effective November 1, 2020 / Updated from November 1, 2019 / Ethics Team / OGC
Purpose & Statement of Policy
This Trading Policy is adopted to protect the regulatory
integrity and reputation of Nasdaq, the financial markets,
and our shareholders, customers and employees.
Nasdaq’s business of operating exchanges around the
world; delivering trading technology, market data, and
transactions services; and providing corporate solutions
to companies across the globe, requires that we adopt
high ethical standards. Our success depends upon the
respect and confidence of the public, regulators, and the
securities industry and our customers.
The trading rules in this Policy are designed to further
these objectives. The Policy is supplemented by Local
Trading Guidelines that provide details and definitions
that may be applicable only in certain jurisdictions and
the Directors and Executive Officers Trading Policy
which prescribes rules applicable to directors and
executive officers of certain Nasdaq entities.
This Policy is not intended to supersede any applicable
law, professional duties applicable to employees (e.g.,
broker-dealer employees) or the Rules of the Swedish
Securities Dealers’ Association (SSDA Rules). Rather,
the Policy should be applied in conjunction with local
law/professional standards and in a manner consistent
with the Nasdaq Code of Ethics. Where Local Trading
Guidelines, applicable law, or the SSDA Rules impose
trading rules that differ from this Policy, the stricter and
broader of the rules shall apply.
This Policy may not directly address every situation
or issue that can arise with respect to trading. Trading
strategies or issues not specifically addressed in this
Policy will be analyzed by reference to the policy
objectives in this document and the Code of Ethics, and,
after thorough analysis, any trading activity that violates
the intent and/ or spirit of this Policy will be prohibited.
GLOBAL TRADING POLICY
QUESTIONS?
Unsure about the application of a rule to your own particular
circumstances? Check the Ethics Program FAQs on Qnet.
Still not certain? Contact any member of the Ethics Team or
send them your question via email to codeofethicsnasdaq@
nasdaq.com.
Acceptable Trading Levels – Investment
Orientation
As a general rule, Associates’ trading should be kept to
a reasonable level reflecting an investment orientation.
Specifically, trading may not interfere with work duties,
or be so frequent as to raise concern about one’s
work efforts during normal working hours. Associates
should not engage in “day trading” or similar types of
speculative trading. Trading should be oriented toward
investment rather than speculation, and should not
distract from work responsibilities. Trading activity in
any security (including ETFs or other assets not covered
within the definition of “Covered Securities” under this
Policy) that is not consistent with these parameters or
that is disproportionate to an investment orientation
– either because of the magnitude of trading activity
or the type of securities traded – or is considered
otherwise excessive will be subject to additional
scrutiny. Where an Associated Person (as defined in this
Policy) is engaged in frequent trading, the Associate
should consult with the Ethics Team to ensure that such
activity is documented in advance and any specific
compliance requirements related to the Associate’s role
have been addressed.
1
Nasdaq Ethics, Trading and Compliance Hub Policy Components
The Nasdaq Ethics, Trading and Compliance Hub (“Ethics Importantly, as detailed in the Nasdaq Compensation
and Compliance Hub” or "the Hub") (accessible via the Program, the calculation of compensation awards will be
Ethics Team pages on Qnet) is the primary system for impacted should there be any unethical behavior, up to
disclosure and compliance certification with this policy. and including lowering an award or deciding to give no
The Ethics and Compliance Hub must be used to report award at all, at the full discretion of management.
brokerage/trading accounts and transactions. Associates This Policy is comprised of the following sections:
are responsible for the completeness and accuracy
• Section 1 – Applicability and Scope
of their disclosures in the Ethics and Compliance Hub
including accurate account information to enable • Section 2 – Compliance with Insider Trading and
electronic data feeds. Associates should contact the Market Abuse Laws
Ethics Team with any questions about using the system. • Section 3 – General Trading Restrictions
Data entered into the Ethics and Compliance Hub is
solely used for compliance purposes and is subject to • Section 4 – Special Associate Categories and
the applicable Associate Privacy Policy posted on Qnet Restrictions on Limited Groups of Associates
(which applies to both information about the Associate • Section 5 – Watch List Associates and Other
and any Associated Persons stored in the system). Restrictions on Trading Nasdaq Securities
• Section 6 – Certification, Brokerage Account and
Policy Compliance and Enforcement
Transaction Reporting Requirements
Each Associate is accountable for compliance with this
• Table 1 – Application of Policy Requirements Based
Policy and must have and exercise sufficient control
on Type of Account
over all trading activity encompassed by this Policy to
ensure compliance. In the case of Associated Persons (as This Policy and the Prohibited Company List may be
defined below), the Associate must make best efforts provided to an Associate’s Associated Persons, financial
to ensure that Associated Persons are informed of the advisors and brokers to facilitate compliance with this
Policy and agree to conduct their investment activities Policy (notwithstanding its classification as an Internal
in compliance with the terms of this Policy.1 Use Only document); any other distribution of this
Policy must be approved in advance by the Ethics Team.
Associates may not circumvent the provisions of this
Policy by using third party accounts, including those of
family members or legal entities.
Associates and Associated Persons may be asked for
information regarding their trading activity including
but not limited to sources of funds, volume of trading,
trading size and patterns, and source of information
by the Ethics Team, their Compliance Officer and/
or the Office of General Counsel. Subject to local law,
Associates must cooperate in any such review and
provide full and accurate information to address an
inquiry.
Any breach of the trading rules or other provisions in
this Policy or a Supplemental Policy may lead to internal
disciplinary action up to and including termination.
Violations and/or suspicious trading activity may also
be subject to regulatory referral or reporting which
could lead to civil or criminal prosecution.

1 In situations where an Associated Person’s primary income is derived from trading in Covered Securities, the Associate may contact the Ethics Team to
develop a compliance plan to address the application of this Policy to such Associated Person. Any such plan must account for the Associate’s role at
Nasdaq (including any non-public information accessible to the Associate) and the principles of this Policy. Absent an approved compliance plan, this
Policy will apply to activities of any Associated Person.

2 GLOBAL TRADING POLICY

Section 1: Applicability & Scope
This Trading Policy is applicable to all Nasdaq “ASSOCIATES”, as defined in the Nasdaq Code of Ethics (which
includes employees, officers, directors, contractors and consultants as further defined in the Code of Ethics)
provided that:
• non-management board of directors members of Nasdaq, Inc., and non-employees shall not be required to
comply with certain provisions of this Policy as further detailed below and in the Code of Ethics;
• non-management board of directors members of Nasdaq European subsidiaries shall only be subject to Sections
3-6 of this Policy to the extent required by the Supplemental Policy for their legal entity and/or terms of
engagement for the board member.
In addition, this Trading Policy is applicable to “ASSOCIATED PERSONS,” defined as:
• An Associate’s spouse*, co-habitee or domestic partner, minor children, and any person for whom the Associate
exercises control, has influence, or any financial interest;
• Any legal entity (including but not limited to any LLC, partnership, corporation, trust or other organization)
where the Associate owns a controlling interest, exercises operational control and/or has responsibility or
influence on investment decisions, and
• Certain “closely affiliated persons” and “controlled organizations” as defined in applicable Supplemental Policies.
This Trading Policy outlines specific restrictions applicable to “COVERED SECURITIY/IES” (for Associates in the
Nordics and Baltics and Index Associates, see separate definition of Covered Securities in the relevant Supplemental
Policies). As reminder, insider trading and market abuse rules as well as policy restrictions on excessing trading
apply to all securities and other investments regardless of whether they are a Covered Security or not.
Employees should exercise good judgement and contact/consult with the Ethics Team in the case of any uncertainty
as to whether an asset is a Covered Security.

COVERED SECURITY NOT A COVERED SECURITY NOTES, WAIVERS AND EXCEPTIONS

Publicly-traded equities; • Mutual Funds Covered Securities held in a pension account,

American Depository Receipts;
Global Depository Receipts,
and similar certificates
or depository receipts
representing securities
All types of publicly-traded
• Corporate debt
• Bonds
• Convertible bonds
• Hybrid bonds
• Equity warrants
• Covered warrants
Derivatives on equities and
corporate debt, e.g.
• Options
• Single stock futures
• ETFs and ETNs*** 401-K account, or similar retirement accounts
are not subject to trading restrictions if they
• Indexes are held as part of a limited menu of options
• Commodities available, and the account holder cannot
trade them as individual stocks.
• Foreign Currency
• Crypto Currency**** Stock or options acquired through Nasdaq
sponsored plans such as the Equity Incentive
• Money Market Funds Program (EIP) and Employee Stock Purchase
• Government, municipal or other public Program (ESPP) are exempt from the 30-Day
debt Hold Rule.
• Index warrants Covered Securities on which a “stop-loss”
• Basket warrants order is placed at time of purchase are
not subject to 30-Day Hold Rule for a sale
Derivatives on triggered by the order.
• Government, municipal or other public Stock received through a tender offer,
debt dividend, bonus or scrip issue is not subject
• ETFs and ETNs*** to 30-Day Hold Rule.
• Mutual Funds Brokerage accounts, including managed
• Commodities accounts, and trusts, including blind trusts,
are governed by the terms in Section 3
• Foreign Currency

* Note that where an Associate is legally separated or has a limited divorce from a spouse and has completely ceased any involvement in the financial affairs
of the spouse, the Associate may request that the Global Ethics Team exclude the separated spouse from the definition of Associated Person (pending
finalization of the Associate’s final divorce). Pending approval from the Global Ethics Team, the separated spouse is considered an Associated Person.
** Associates should consult the Ethics Team as to whether Initial Coin Offerings may constitute Covered Securities. Remember that although crypto
currency itself is not a Covered Security, equity, debt or derivatives of “coin miners” and others involved with a currency may be.
*** Associates should consult any applicable Supplemental Policies to confirm that they do not expand the definition of Covered Securities to include ETFs
and ETNs. In particular, Supplemental Policies for Index Associates and Associates supporting Nasdaq Sweden and Denmark include certain ETFs within
the definition of Covered Securities.
**** Associates should consult the Ethics Team as to whether Initial Coin Offerings may constitute Covered Securities. Although crypto currency itself is not a
Covered Security, equity, debt or derivatives of “coin miners” and others involved with a currency may be.

GLOBAL TRADING POLICY 3

Section 2: Compliance with Insider Trading and Market Abuse Laws
Most jurisdictions where Nasdaq conducts business
prohibit, by law, insider trading and other forms of
market abuse. Associates who are aware of material
non-public information relating to Nasdaq or to any
other company are reminded that they may not buy
or sell Nasdaq securities or such other company’s
securities or give, communicate, or in any other tip or
way convey such information to another person. These
restrictions apply regardless of whether you received
information as an intended recipient or received it
incidental to your work at Nasdaq (e.g., received it
as part of a group email or accidentally overheard a
conversation). These restrictions apply regardless of
whether the security involved is a Covered Security
under this policy.
The term “material non-public information” is broadly
construed. It includes any information that, if publicly
disclosed, (a) might have an effect on the market for
the securities of the issuer generally, (b) might affect an
individual investment decision of a reasonable investor,
or (c) might cause an insider to change his/her trading
patterns.
Material non-public information includes, but is not
limited to, confidential information relating to:
• Financial results and projections of future earnings or
losses;
• News of a pending or proposed merger, acquisition,
tender offer or other corporate development or that
discussions or negotiations with respect thereto are in
progress;
• Information related to the potential de-listing of a
company or the non-payment by a listed company of
its listing fees;
• News of a significant new business transaction;
4 GLOBAL TRADING POLICY
• Possible dividend increases or decreases, a
declaration of a stock split or the offering of
additional securities;
• Significant new products or services;
• Significant litigation or litigation developments,
actual or threatened disputes or governmental
investigations;
• Significant data breaches or cybersecurity risks or
incidents;
• Any significant changes in management or control of
the issuer of the securities; and
• Significant new contracts or loss of business.
Material non-public information cannot be
communicated to other persons in any manner. Even
inadvertent communications must be avoided, and
every practicable step to preserve the confidentiality
of information must be affirmatively taken. For
example:
• Log off of your computer when you leave your desk
and the building;
• Set your screen saver setting to a short duration and
password protect your screen saver;
• Physically secure laptops or iPads in lockable drawers
when not in use;
• Lock confidential information away when it is not
being used;
• Do not leave sensitive documents on desks,
photocopiers, printers or fax machines;
• When disposing of documents that are not required
to be kept by our retention policy, use the paper
shredders provided on site; Accompany visitors
through the building at all times;
 Section 3: General Trading Restrictions
• Guard against inadvertent disclosure of information The following restrictions apply to all trading activity
through conversations that might be overheard in Covered Securities by Associates and Associated
between departments; Persons.

• Avoid reading or discussing confidential or sensitive Prohibited Company List

information in public areas and where it cannot be
All Associates and Associated Persons are precluded
avoided, use abbreviations or code names where
from holding and trading the Covered Securities in any
possible; company included on the Prohibited Company List.
• Check distribution lists carefully when sending emails The Prohibited Company List is posted on Qnet and is
with confidential and sensitive content; and reviewed quarterly and/or as business circumstances
change. Associates and Associated Persons who hold
• Escalate any breaches (inadvertent or not) to the
Covered Securities on the Prohibited List at the time
Ethics Team or the Office of the General Counsel as
of their hire/engagement or at the time a company is
soon as you become aware of them. added to the Prohibited List, are required to sell or close
If you are working in a home office or other remote out their position within 30 days with pre-clearance
work location and your role requires accessing material approval from the Ethics Team.
non-public information, you must take appropriate Once pre-clearance is provided, the Associate must sell
measures such as those identified above to secure such the affected Covered Securities within 24 hours; such
information from disclosure to others present in your time period may be extended to 48 hours for lightly
traded securities (as determined by the Global Ethics
home or work location. You should consult with your
Team).
manager, Compliance Officer and/or the Ethics Team if
you have questions about how to implement appropriate An Associate must obtain a written waiver (using the
designated form) from the Ethics Team to continue to
measures in a non-office location.
hold or to purchase a Prohibited Company List security.
Market abuse offenses typically cover the insider
trading situations mentioned above, but may also Initial Public Offerings (IPO)
include far broader scenarios and involve a wider
All Associates and Associated Persons are precluded
variety of securities, such as commodities. These
from purchasing Covered Securities in an IPO on any
broader scenarios may include:
exchange, for the first seven calendar days of trading,
• misuse of information; including the offering date. Seek guidance prior to
• manipulating transactions which give a false or participating in any initial coin offerings (ICOs).
misleading impression as to the supply, demand, or
price of a security;
• dissemination of information likely to give a false or
misleading impression; and
• transactions which might distort the market.
Insider trading and market abuse are extremely serious
offenses that undermine public confidence and can have
a detrimental effect on the company’s credibility and
business. Both the company and individual Associates
may be subject to criminal and civil liability for any
such violations.

GLOBAL TRADING POLICY 5

Minimum Hold Period
All Associates and Associated Persons must hold all
Covered Securities for a minimum period of 30 calendar
days.
The following are NOT subject to the 30-day minimum
hold period:
• Covered Securities held in a registered managed
account or trust – please “Managed Account and
Trust” provisions below. To qualify the account must
be registered and approved by the Ethics Team;
• Stock or options acquired through Nasdaq-sponsored
plans such as the Equity Incentive Program (EIP) and
Employee Stock Purchase Program (ESPP);
• Covered Securities sold based on a “stop-loss” order
that was placed at the time of purchase; and
• Stock received through a tender offer, dividend,
bonus or scrip issue.
Short Selling Covered Securities
Any Associate engaging in “short selling” must do so
consistent with the objectives and requirements of
this Policy. Because short selling is often a short term
trading strategy, Associates may not engage in short
selling of Covered Securities except where (1) the short
selling is part of risk management or hedging strategy
reviewed with the Ethics Team in advance to ensure
it is consistent with this policy, (2) the short selling is
done as part of an investment strategy reviewed in
advance with the Ethics Team where the short positions
are expected to be held open for at least 30 days and
is otherwise consistent with this policy, or (3) the short
selling is done by the financial advisor of a managed
account or trust registered with the Ethics Team in
accordance with this policy. To account for review times,
Associates should contact the Ethics Team to seek any
required approval well in advance of implementing it;
any significant change in the approved strategy will
require review and re-approval by the Ethics Team.
If an Associate or Associated Person wishes to execute
a complex transaction involving multiple Covered
Securities or using a derivative to hedge a position in an
underlying Covered Security that has been held for more
than 30 days, and the transaction may result in some of
the Covered Securities not being held for the minimum
hold period, he/she should consult with the Ethics Team
in advance of executing the transaction.
The transaction will be analyzed and may be considered
acceptable if it does not otherwise breach any other rule
of the Policy and the intent and/or spirit of the Policy.
6 GLOBAL TRADING POLICY
Managed Accounts and Trusts
Registered managed accounts and trusts are not subject
to the 30-day minimum hold period or short-selling
restrictions set forth above. A managed account or trust
is an account over which the Associate or Associated
Person exercises no discretion, influence or control
over the day-to-day activities or trading; for a managed
account, the account is managed by a financial advisor
who exercises discretion over the holdings and trades
based on account parameters or a strategy selected by
the Associate/Associated Person. To be excluded from
the 30-day minimum hold period and short selling
restriction, an account must be registered with the
Ethics Team and the employee/financial advisor/trustee
must submit paperwork required by the Ethics Team.
To register and seek approval for a managed account or
trust, contact the Ethics Team at codeofethicsnasdaq@
nasdaq.com. Based on the type of assets held in the
managed account or trust, the Ethics Team may require
you and/or your financial advisor/trustee to complete
documentation regarding the account. Note that the
Prohibited Company List and IPO restrictions apply to
all managed accounts an most trusts as set forth in Table
1. At all times, you remain accountable for the trustee’s
or financial advisor’s compliance with this Policy. For
US Associates, managed accounts at brokers that do not
provide Nasdaq with electronic data feed of holdings
and trades are discouraged and must be separately
approved for a hardship waiver under Section 6 of this
Policy.
Waivers and Exceptions
WAIVERS
Waivers to this Policy are considered and granted by the
Ethics Team where there is a reasonable basis, such as for
undue hardship or for accounts or investments which pre-
date employment with Nasdaq or changes to the rules.
Associates should not assume a waiver will be granted
and should not act absent written communication
and approval from the Ethics Team. An Associate may
request a waiver by completing a Waiver Request Form
found on Qnet and sending it to the Code of Ethics
mailbox (codeofethicsnasdaq@nasdaq.com).
EXCEPTIONS
Some types of accounts or other investment vehicles
may be exempted from all or some of the restrictions
set out in this Policy. Table 1 outlines exceptions to the
general rules which apply to brokerage accounts.
Section 4 – Special Associate Categories and Restrictions on
Limited Groups of Associates
Sensitive Information and Regulatory Associates and received a waiver from the Ethics Team to work
on the matter. Associates involved in responding
Some Associates, by virtue of their job functions and
to regulatory or government requests related to
the information to which they routinely have access or
a company cannot change his/her position in any
can be presumed to have routine access, are subject to
Covered Securities of such company or an affiliate.
additional trading restrictions. Associates, who by virtue
of their job function fall into more than one of the • Client Service Information Associates are Associates
groups listed below or in another section of this policy, who have access to non-public information related
will be held to the stricter of the applicable standards. to their service to clients. As further set forth in
role-related guidelines, Associates in this category
Each Associate’s manager determines whether the
are subject to restrictions on holding and/or
Associate falls into one of the categories below by
trading (without a waiver or a pre-clearance) the
completing a questionnaire in Workday based on
Covered Security of a company*: (1) the Associate
the Associate’s job responsibilities and/or access to
is the relationship/account manager or similar
information. Associates subject to these restrictions will
role for Nasdaq, (2) whose confidential, non-public
be notified of their status via Workday.
information the Associate can regularly access
• Exchange Sensitive Information Associates are as part his/her role or (3) that is under subject
Associates who regularly have access to non- to restriction under the guidelines applicable to
public information about Nasdaq listed companies Associates involved in determining the composition
or exchange activities. Except where a waiver (for of an index or benchmark.
holding) or preclearance (for buying/selling) has
been obtained Exchange Sensitive Information Dorsey, Wright & Associates Access Persons
Associates are prohibited from holding or trading
For Associates considered “access persons,” related to
Covered Securities on the exchanges with which they
the business of Dorsey, Wright & Associates, there are
interact*. Any holding of these securities requires a
additional guidelines and requirements with respect to
waiver from the Ethics Team and any trade involving
personal trading. Those guidelines and requirements
them requires pre-clearance.
can be found in the Dorsey, Wright & Associates Written
• Regulatory Associates are Associates who perform Supervisory Procedures, which applies to such Associates
functions related to oversight or investigation of as a Supplemental Policy to this policy.
companies. An Associate in this category cannot:
For the purpose of this policy, “access person” is a
(1) trade Covered Securities of companies under
person who provides investment advice on behalf of
regulatory review or consideration for delisting or
an investment adviser and is subject to the supervision
(2) change his/her position in any Covered Securities
and control of the investment adviser, who has access
of any company that is the subject of any regulatory
to nonpublic information regarding clients’ purchase
action or investigation by an exchange which the
or sale of securities, is involved in making securities
Associate supports while the regulatory action or
recommendations to clients or who has access to such
investigation is pending. If a Regulatory Associate
recommendations that are nonpublic. Access persons
holds a Covered Security of a company subject to
may include, but are not limited to, officers, portfolio
regulatory review or consideration for delisting,
management personnel, and client service representatives
such Regulatory Associate may not work on such
who communicate investment advice to clients.
matter unless he/she has disclosed such ownership

*D
 oes not apply to Nasdaq-company securities or debt (e.g., stock issued as part of incentive or ESPP programs). Any such transactions must comply with all
other provisions of this policy including, but not limited to, restrictions related to Watch List employees and requirements to not trade while in possession
of material non-public information.

GLOBAL TRADING POLICY 7

Associates Registered with U.S. Broker- Dealer
Affiliates
For Associates registered with U.S. broker-dealer
affiliates of Nasdaq, there are additional guidelines and
requirements with respect to personal trading that are
considered Supplement Policies to this policy. Please
be sure to consult with the broker-dealer compliance
officer for guidance on the scope and application of
these rules.
Officers and Directors
Further restrictions and limitations are contained in
the Director and Executive Officer Insider Trading
Policy which is applicable to Directors, Section 16
Officers, Presidents, Executive Vice Presidents and
the Controller/ Principal Accounting Officer. Except as
required by the Directors and Executive Officers Trading
Policy, non-management directors are not required to
provide electronic feeds to their brokerage accounts or
disclose holdings.
Section 5: Watch List Associates and
Other Restrictions on Trading Nasdaq
Securities
Trading NDAQ Only During Trading Windows
To avoid any improper transaction in Nasdaq Securities
(NDAQ) or the appearance of impropriety, Watch List
Associates and their Associated Persons are precluded
from trading NDAQ securities except during a Trading
Window and when they are not in possession of
material non-public information about Nasdaq.
WATCH LIST ASSOCIATES
Watch List Associates are individuals that have been
identified in Workday by their managers as ordinarily
having access to Nasdaq internal financial statements
or other material non-public information about Nasdaq.
Associates identified as “Watch List” Associates will be
notified that they are on the Watch List and will receive
annual training on their obligations/responsibilities to
keep confidential all material non-public information on
Nasdaq.
8 GLOBAL TRADING POLICY
At regular intervals, Nasdaq managers will be surveyed
via Workday to review and update the names on the
“Watch List.” Throughout the year, Watch List Associates
receive announcements pertaining to the training
window (see below).
TRADING WINDOWS
Trading windows are announced quarterly, and typically
open one full trading day after financial results for the
fiscal quarter have been publicly disclosed and close at
the end of the trading day on the fourteenth (14th) day
of the last month of each quarter (March 14, June 14,
September 14 and December 14). Watch List Associates
will receive a communication each quarter providing
information about the trading window, and the dates of
the Trading Window will be provided on the Qnet. Note
that Nasdaq may close or delay the opening of a trading
window at any time it deems necessary.
NO SAFE HARBOR
Trading in NDAQ Securities during the open trading
window should not be considered a “safe harbor.” Even
during the trading window, any person possessing
material nonpublic information concerning Nasdaq must
not engage in any transactions in NDAQ Securities until
such information has been sufficiently publicized so
that the public has had the opportunity to evaluate the
information. As a general rule, all Nasdaq Associates
should refrain from any transactions in Nasdaq
Securities until one full trading day has passed after the
public announcement of information, whether or not the
Associate is on the Watchlist.
EXERCISE OF OPTIONS AND ESPP EXEMPT
The exercise of stock options under the Equity Incentive
Plan or the purchase of shares under the Employee
Stock Purchase Plan (“ESPP”) is exempt from the
requirement that Watch List Associates trade NDAQ
stock only during a Trading Window, since the other
party to the transaction is Nasdaq itself and the price
does not vary with the market but is fixed by the terms
of the option agreement or the plan. However, the sale
of any shares acquired under the Equity Incentive Plan
(including broker-assisted cashless exercise of options)
or the ESPP is subject to this restriction.
Short-Selling
Associates and Associated Persons are prohibited
from selling NDAQ securities “short,” or from creating
any similar short position in NDAQ through the use of
derivatives. Short selling is the sale of securities you
do not own at the time of sale, but that you promise to
deliver in the future, and is an attempt to profit from
an anticipated drop in market prices. Investing in NDAQ
securities provides an opportunity to share in the long-
term growth of the company. Short-term investments
based on fluctuations in the market are incompatible
with this objective, and may put your personal gain
in conflict with the best interests of Nasdaq and its
shareholders.
The simultaneous sale of securities acquired through
an option grant under the company’s compensation
plan or the Nasdaq Global Equity Incentive Plan is not
considered short selling.
Rule 10b5-1 Plans
Rule 10b5-1 of the U.S. Exchange Act provides an
affirmative defense under the U.S. Federal Securities
laws from certain insider trading violations. Trades
by Associates in NDAQ Securities that are executed
pursuant to a Plan that meets the requirements of Rule
10b5-1 and is approved by the 10b5-1 Administrator
in Finance, are not subject to the restrictions set forth
above relating to the trading window, and are not
subject to pre-clearance procedures, where applicable.
A Rule 10b5-1 Plan specifies (including by formula)
the amount, pricing and timing of transactions in
advance, or delegates discretion on those matters to
an independent third party. Once the Plan is adopted,
the person adopting the Plan may not exercise any
influence over the amount of Securities to be traded,
the price at which they are traded or the date of trade.
Rule 10b5-1 Plans may only be adopted, amended, or
modified during an open trading window period and by
a person who is not aware of any material nonpublic
information.
Other NDAQ Restrictions
From time to time, the company may preclude the
trading of NDAQ stock by all or some Associates or
Associated Persons due to developments known within
the company but not disclosed. Consistent with US
Securities and Exchange Commission guidance, this may
include events that constitute significant data breaches
or cybersecurity events.
GLOBAL TRADING POLICY
Section 6 – Certification, Brokerage
Account and Transaction Reporting
Requirements
Compliance Certifications
All Associates must confirm within thirty (30) days of
hiring and annually that they are in compliance and will
comply with the trading rules contained in this Trading
Policy, and that they have completely and properly
disclosed, to the extent required by the Policy and Local
Trading Guidelines applicable to them, all brokerage
accounts and relevant trading activity. This certification
is in addition to, but generally occurs simultaneous with,
the annual certification to the Code of Ethics.
Nasdaq may, also from time to time, ask any
Associate or Associated Person to confirm that he/
she is in compliance with this Policy and/or applicable
Supplemental Policies. Nasdaq may also request
documentation supporting such compliance.
Disclosure and Monitoring of Various Account
Types
In order to maintain confidence about compliance
with the key provisions of this Policy, Nasdaq has
implemented a disclosure and monitoring process
applicable to all Associates and Associated Persons.
The types of accounts and their treatment are set out
in Table 1. Local policies in the Nordics and Baltics may
vary, as set out in Local Trading Guidelines.
NON-EMPLOYEES (CONTRACTORS AND CONSULTANTS)
AND INTERNS
Associates that are non-employees (e.g., contractors
or consultants) or interns are not required to disclose
their brokerage accounts or provide electronic feeds
to them except where required by a Supplemental
Policy, applicable law or contract terms (for non-
employees). Associates not subject to disclosure duties
may be required to provide brokerage statements or
other documents evidencing compliance as part of a
compliance review, audit or investigation.
NON-MANAGEMENT BOARD OF DIRECTORS MEMBERS
Non-management board of directors members are
not required to disclose their brokerage accounts or
provide electronic feeds to them. To the extent that a
provision in this policy conflicts with the Directors and
Executive Officers Trading Policy, such policy shall take
precedence and govern over this one.
9
EXEMPTED LOCATIONS OR ACCOUNT TYPES
Employees in certain countries may be exempted from
the disclosure requirements in this Policy as required to
comply with local laws and regulations as determined
by Nasdaq on a case-by-case basis.
As set forth in the applicable Supplemental Policy for a
non-US jurisdiction, certain types of accounts may be
excluded from disclosure for Associates subject to such
Supplemental Policy.
Disclosure and Reporting Requirements
All Associates are required to report via the Ethics and
Compliance Hub:
• all brokerage accounts held in the Associate’s name
or that is actively managed or used by the Associate
• all holdings of Covered Securities in these accounts
or that are held in physical form
• all brokerage accounts for Associated Persons
This disclosure is required within thirty (30) days of the
Associate’s hire date and within ten (10) days of the
opening of any new brokerage account. Associates must
also certify to the accuracy of the disclosures annually.
Associates in certain locations may be excluded from
some or all of these requirements based on local legal
requirements.
A “brokerage account” for these purposes is any account
that enables or allows the account holder to trade or
maintain positions in Covered Securities, whether or
not the account currently holds any Covered Securities.
It includes accounts in the Associate’s name over
which the Associate does not exercise control, such as
managed or discretionary accounts.
It also includes accounts where trading activity and
portfolio management services are, in whole or in part,
automated and provided by what is commonly referred
to as a “robo-adviser.” For these accounts, Associates
are strongly recommended to limit their use to exchange
traded funds, mutual funds and other securities not
encompassed by the definition of Covered securities.
10
Retirement, educational saving and similar accounts
that limit the holder to a restricted menu of funds as
investment options need not be disclosed.
Associates are encouraged to reach out to the Ethics
Team if they have any questions concerning what
brokerage accounts or holdings are subject to this
reporting and disclosure requirement.
After the initial disclosure of brokerage accounts and
holdings, the purchase or sale of any Covered Security
shall be disclosed as required by this Policy based on
the Associate’s primary work location. In addition to
the options described below, an additional option may
be available upon application to the Ethics Team: this
entails providing a quarterly certification of compliance
with the Trading Policy from an independent third party
acceptable to Nasdaq, and at the employee’s expense.
For Associates registered with U.S. broker-dealer
affiliates of Nasdaq, there may be additional guidelines
and requirements with respect to disclosure of
brokerage accounts and/or holdings. Please be sure to
consult with the broker-dealer compliance officer for
guidance on the scope and application of these rules.
US Associates: Electronic Feed and Disclosure
Requirements
U.S. Associates and Associated Persons may only establish
and retain accounts with the brokerage firms that provide
an electronic data feed to Nasdaq for monitoring unless
a hardship waiver as described below has been granted.
A current list of firms providing data feeds to Nasdaq is
posted on the Ethics Team pages on Qnet.
Please note that some firms that provide automated
account services including through “robo-advisers” do
not provide Nasdaq with an electronic data feed. Robo-
advisor accounts are considered brokerage accounts
under this policy and are subject to the data feed or
hardship waiver requirements.
GLOBAL TRADING POLICY
Hardship Waivers: US Associates must obtain a hardship Non-US Associates: Disclosure Requirements
waiver for any account by the Associate or Associated
For non-electronic feed accounts of Associates and
Person that does not provide Nasdaq an electronic data
Associated Persons located outside of the US, the
feed.
Associate must (1) report transactions in Covered
Waivers are not granted as a matter of course, but on Securities in the Ethics and Compliance Hub within
reasoned grounds when limiting the Associate to the use seven (7) days of the transaction closing and (2)
of an electronic feed account is not possible without a maintain quarterly account statements (paper or
significant negative impact on the Associate. Associates electronic) available for inspection and review at the
are encouraged to speak with the Ethics Team regarding request of the Ethics Team, their Compliance Officer
the waiver process. and/or Internal Audit for three (3) years. For non-
Associates may request a waiver from the electronic electronic feed managed accounts and trusts, the
feed requirement by submitting a request to the Associate must (1) provide the Ethics Team completed
Ethics Team via email at codeofethicsnasdaq@nasdaq. managed account paperwork and/or other certifications
com. Such request should explain the hardship on the required by the Ethics Team upon submission of the
Associate if he/she were not permitted to use the non- account and thereafter and (2) maintain quarterly
electronic feed broker. account statements (paper or electronic) available for
inspection and review at the request of the Ethics Team
For non-electronic feed brokerage accounts, the
and/or Internal Audit for three years.
Associate must (1) report transactions in Covered
Securities in iTrade within seven days of the transaction Where the Associate/Associated Person (1) has accounts
closing and (2) maintain quarterly account statements at a financial institution providing an electronic feed of
(paper or electronic) available for inspection and review holdings and trades to Nasdaq, (2) reported the account
at the request of the Ethics Team and/or Internal Audit in the Ethics and Compliance Hub as an electronic feed
for three years. account and (3) if required by the financial institution
and/or local law, authorized an electronic feed to
For non-electronic feed managed accounts and
Nasdaq to the Ethics and Compliance Hub, the manual
trusts, the Associate must (1) provide the Ethics
reporting requirements detailed above do not apply. The
Team completed managed account paperwork and/
Ethics Team can advise Associates on which financial
or other certifications required by the Ethics Team
institutions outside the US offer electronic feeds to the
upon submission of the account and thereafter and
Ethics and Compliance Hub.
(2) maintain quarterly account statements (paper or
electronic) available for inspection and review at the
request of the Ethics Team, applicable Compliance
Officer and/or Internal Audit for three years.
For non-electronic feed managed accounts and trusts
(which require a hardship waiver from the Ethics
Team), the Associate must (1) provide the Ethics
Team completed managed account paperwork and/
or other certifications required by the Ethics Team
upon submission of the account and thereafter and
(2) maintain quarterly account statements (paper or
electronic) available for inspection and review at the
request of the Ethics Team and/or Internal Audit for
three years.

GLOBAL TRADING POLICY 11

OFFICE OF GENERAL COUNSEL

Table 1: Application of Policy Requirements Based on Type of Account

Disclosure by Associates of their brokerage accounts, holdings, and/or trading activity, and certification of
adherence to this Trading Policy, are critical components of Nasdaq’s Ethics Program. The process for, and scope
of, disclosure and certification varies from jurisdiction to jurisdiction. This Policy outlines the minimum obligations
of Nasdaq Associates with respect to disclosure of their trading activity and accounts. It is supplemented by the
Supplemental Policies, the SSDA Rules, and the Directors and Executive Officers Trading Policy, as applicable.
These documents provide specific information regarding the types of transactions that must be declared by the
individuals to which they apply, the timeframe within which they shall be declared, and the closely affiliated
persons or controlled organizations that may also be subject to the duty to declare.

TRADING POLICY
ACCOUNT TYPE BRIEF DESCRIPTION DISCLOSURE PROVISIONS MONITORING

Blind trusts Trustee exercises full control and Yes 30 day hold No No
beneficiaries have no knowledge of 7 day IPO No
or influence over holdings – requires Prohibited list No
certification by the executor as to the
nature of the trust

Trust managed by a third Third party has full control over trust, Yes 30 day hold No Yes
party trustee with Associate Associate has knowledge, no control – 7 day IPO Yes
or Associated Person as treated like a managed account Prohibited list Yes
beneficiary

Trust Associate is the Associate has control over trust – treated Yes 30 day hold Yes Yes
trustee and non-Associated like a brokerage account 7 day IPO Yes
Person is beneficiary Prohibited list Yes

Managed account Associate
has no influence or control
and the broker is willing
to provide a certification
attesting no control
Account in the Associate’s name over Yes 30 day hold No Yes
which s/he exercises no discretion, 7 day IPO Yes
influence or control. A broker certification Prohibited list Yes
as to the nature of the account and
attesting to compliance is required.

Brokerage account Any account in an Associate’s name which Yes 30 day hold Yes Yes
is capable of trading or holding Covered 7 day IPO Yes
Securities, including accounts managed or Prohibited list Yes
serviced by a “robo-adviser”1

1F
 or accounts managed or serviced by a robo-adviser, Associates are strongly recommended to limit their use to exchange traded funds, mutual funds and
other securities not encompassed by the definition of Covered Securities.

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GLOBAL TRADING POLICY - INTERNAL USE ONLY 12