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NASDAQ PRE-ENGAGEMENT ETHICS ACKNOWLEDGEMENT FORM

As a participant in financial markets, Nasdaq operates many legally regulated companies


which are overseen by national and international financial supervisory authorities. A
common requirement of these authorities is that Nasdaq’s employees and contractors at
all times avoid actual or perceived conflicts between personal interests and the interests
of Nasdaq and the financial market. Employees and contractors must also strictly adhere
to the law, including prohibitions on insider trading and manipulative trading activity.

As a participant in financial markets, Nasdaq operates many legally regulated companies


which are overseen by national and international financial supervisory authorities. A
common requirement of these authorities is that Nasdaq’s employees and contractors at
all times avoid actual or perceived conflicts between personal interests and the interests
of Nasdaq and the financial market. Employees and contractors must also strictly adhere
to the law, including prohibitions on insider trading and manipulative trading activity.

This document does not form an unconditional commitment for Nasdaq to enter into a
contractual employment relationship with you. Any and all data submitted here will be
handled and processed in confidence and in accordance with Nasdaq’s Privacy Policy
and applicable law.

Acknowledgement:

By providing my signature below, I acknowledge that I have been presented with a copy
of Nasdaq’s Global Code of Ethics, Global Trading Policy and Prohibited Company
List. Candidates for certain Nasdaq companies will also have received a Local Trading
Guideline. I note that, upon employment with Nasdaq, I will need to request from my
Nasdaq manager which specific requirements apply to my position with Nasdaq. I
understand the content of these policies, and have been provided with sufficient
opportunity to ask questions regarding their content and application. Should I become an
employee or contractor of Nasdaq, I agree to comply with these policies and recognize
that a breach of these policies may be considered gross misconduct under an
employment or vendor contract or as an employee at will. I also understand the
definition of “Associates” in the Global Trading Policy and that the Policy may be
applicable to my “Associates” as well. A few of the primary guidelines under the Global
Trading Policy and Code of Ethics are below, but I understand that I am bound by all
aspects of these policies.

Prohibited Company List - I understand that I am bound to disclose any Prohibited


Company List holdings by me or my Associates within 30 days of my hire or
engagement, and that I may need to divest any interest in such holdings.

Initial Public Offering 7-Day Rule - I understand that neither I nor my Associates may
purchase any Covered Securities (as defined in the Global Trading Policy, or Local
Country Guidelines as applicable) in an IPO on any exchange on the day of the offering
and for six calendar days thereafter,.

30-Day Minimum Hold Period - I understand that I and my Associates must hold all
Covered Securities for a minimum period of 30 calendar days, subject to the exceptions
noted in the Global Trading Policy, or any Local Country Guidelines as applicable.

Outside Business Activity and other Conflicts of Interest - I agree to promptly consult
with the Global Ethics Team and Nasdaq management regarding any potential or
perceived conflict of interest I may have before I am hired or begin my engagement, as
well as any other potential or perceived conflict of interest that may arise after hire or
engagement, including any outside business activity that may result in actual or potential
conflicts with Nasdaq’s interests.
Signature

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