Global Trading

Policy
Effective November 1, 2022
Global Trading Policy

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 market technology, market data, and transactions
services; and providing corporate solutions to companies across the globe, requires that we maintain the highest ethical
standards. Our success depends upon the respect and confidence of the public, regulators, the securities industry, and our
customers. The trading rules in this Policy are designed to further these objectives.

Supplemental Policies
The Policy is supplemented by policies applicable to Associates in certain jurisdictions or Nasdaq legal entities or business
segments (referred to in this Policy as a “Supplemental Policies” or “Supplemental Trading Policies”). In addition, the Directors
and Executive Officers Trading Policy prescribes rules applicable to directors and executive officers of certain Nasdaq entities.

Local Laws & Regulations

This Policy is not intended to supersede any applicable law, professional duties applicable to employees (e.g., broker-dealer
employees), or, where applicable, 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 a Supplemental Policy, 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 any trading activity that violates the intent and/or spirit of this Policy will be prohibited.

Policy Compliance and Enforcement

Each Associate is accountable for compliance with this Policy and any applicable Supplemental Policies and must have and
exercise sufficient control over all trading activity to ensure compliance. In the case of Associated Persons (as defined below),
the Associate must make best efforts to ensure that Associated Persons (1) are informed of the Policy and any applicable
Supplemental Policies and (2) agree to conduct their investment activities in compliance with the terms of this Policy.1
Associates may not circumvent the provisions of this Policy by using third party accounts, including those of family members or
legal entities.

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.

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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 Global Ethics Team, their
Compliance Officer, the Office of General Counsel and/or Internal Audit. In addition, Associates and Associated Persons may be
required to provide information to Nasdaq’s regulators in connection with their regulation and oversight of Nasdaq. 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 or violations of laws and regulations
related to trading activity or non-public data handling may lead to disciplinary action as set forth in the Code of Ethics, up to and
including termination of employment. Subject to applicable law, corrective actions may include requiring the sale of securities or
closing of positions in violation of this Policy and other actions to address gains or avoided losses arising from a violation of
this Policy.

Importantly, as detailed in the Code of Ethics, the calculation of compensation awards will be impacted should there be
any unethical behavior, up to and including lowering an award or deciding to give no award at all, at the full discretion of
management. Violations and/or suspicious trading activity may also be subject to regulatory referral or reporting which could
lead to civil or criminal prosecution.

Insider Trading, misappropriation of non-public information and “tipping” (as outlined in “Section 2: Insider Trading & Market
Abuse”) are serious criminal offenses and may be punishable by imprisonment and substantial fines.

Policy Components
This Policy is comprised of the following sections:

Section 1: Applicability & Scope

Section 2: Insider Trading & Market Abuse

Section 3: Global Trading Policy Rules

Section 4: Certification, Brokerage Account Disclosures, & Trading Reporting Requirements

Table 1: Disclosure & Reporting Requirements

Table 2: Application of Policy Requirements Based on Type of Account

Section 5: Supplemental Trading Policies

Section 6: Watch List & Restrictions on Trading NDAQ Securities

The Code of Ethics, this Policy, Supplemental Trading Policies, and the Prohibited Company List may be provided to an
Associate’s Associated Persons, financial advisors, and brokers to facilitate compliance with this Policy (notwithstanding
its classification as an Internal Use Only document); any other distribution of this Policy must be approved in advance by
the Ethics Team.

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Section 1: Applicability & Scope

This 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., Nasdaq’s U.S. Exchange subsidiaries, and Nasdaq CXC
Limited are not subject to Sections 3 and 4 of this Policy;

• non-management board of directors members of Nasdaq European subsidiaries shall only be subject to Sections 3 and 4 of
this Policy to the extent required by the Supplemental Policy for their legal entity and/or terms of engagement for the board
member; and

• non-employees may not be required to comply with certain provisions of this Policy as further detailed below and in the
Code of Ethics.

In addition, this Policy is applicable to “ASSOCIATED PERSONS,” defined as:

• An Associate’s spouse2, cohabitee or domestic partner, minor children, and any person with whom the Associate has a
financial interest or exercises financial control or influence;

• 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
decisions3; and

• Certain “closely affiliated persons” and “controlled organizations” as defined in applicable Supplemental Policies.

All Associated Persons must abide by the rules outlined in this policy, to include financial disclosure rules. Brokerage accounts
(including managed accounts) and trusts (including blind trusts) are governed by the terms outlined in Section 4 of this Policy.

2. 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.

3. Associates are responsible for obtaining approval prior to establishing such a legal entity or taking such a role regarding a legal entity as required by the “outside business activity” and
conflict of interest provisions in the Code of Ethics. Legal entities where an Associate serves as a director or other role on behalf of Nasdaq are not Associated Persons.

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Covered & Non-Covered Securities
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 Non-Covered Securities

All securities listed below must follow the Global Trading Policy The following securities are not subject to the rules of the
rules outlined in Section 3 of this Policy4: Global Trading Policy outlined in Section 3 of this Policy. All
Associates subject to a Supplemental Trading Policy must
• Publicly-traded stocks and other equities (including REITs) reference the applicable policy to determine if any of the listed
• American Depository Receipts securities are covered by the Supplemental Trading Policy.
• Global Depository Receipts
• Mutual Funds
• Similar certificates or depository receipts representing
• ETFs & ETNs5
securities
• Indexes
• All types of publicly-traded:
• Commodities
• Corporate debt
• Foreign Currency
• Bonds
• Cryptocurrencies & Digital Assets6
• Convertible bonds
• Money Market Funds
• Hybrid bonds
• Government, municipal, or other public debt
• Equity warrants
• Index warrants
• Covered warrants
• Basket warrants
• Derivatives on equities and corporate debt, e.g.
• Derivatives on:
• Options
• Mutual Funds
• Single stock futures
• ETFs & ETNs
• Commodities
• Foreign Currency
• Government, municipal, or other public debt

4. As outlined in Section 4 of this Policy, securities held in a pension account, 401-K account, or similar retirement accounts are not subject to trading restrictions if they are held as part of a
limited menu of options available, and the account holder cannot trade them as individual stocks.

5. 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, Supple-
mental Policies for Index Associates and Associates supporting Nasdaq Sweden and Denmark include certain ETFs within the definition of Covered Securities.

6. See “Digital Assets” below for rules specific to Digital Assets.

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Digital Assets
“Digital Assets” are defined, for purposes of this Policy, as the broader of (a) any asset issued, minted, exchanged, and/or
transferred using distributed ledger or blockchain technology (“distributed ledger technology”), including, but not limited to,
so-called “virtual currencies,” “coins,” and “tokens” or (b) the definition for such assets applicable in the jurisdiction in which the
Associate resides.

Associates are cautioned that the legal status of Digital Assets as a security, commodity or other asset type is uncertain and
may vary from one jurisdiction to another. Associates must comply with all laws and regulations related to Digital Assets in the
jurisdiction where they are located or that apply to their trading activity and ownership of Digital Assets. Further, Associates
must comply with all professional standards and regulation that apply to their ownership and trading of Digital Assets.

Associates and Associated Persons may not use or trade Digital Assets to engage in any unlawful or unethical activity or to
evade any legal obligations.

Nasdaq’s Code of Ethics and Information Security policies apply to all non-public information accessed or available to Associates
related to their work for Nasdaq. Regardless of whether Digital Assets constitute a security, commodity or other asset type,
Associates may not use non-public information learned related to their work for Nasdaq to buy or sell Digital Assets or provide or
“tip” such information to others.

In addition, Associates much comply with all Code of Ethics and related policy provisions related to conflicts of interest, private
investment and outside business activities related to any activities involving Digital Assets.

Digital Assets are not currently Covered Securities under this Policy7. At any time, Nasdaq may identify certain Digital assets or
categories of Digital Assets as being Covered Securities under this Policy. Nasdaq may also change this Policy or requirements
related to the ownership or trading of Digital Assets at its sole discretion. Associates and Associated Persons must comply
with any such policy changes in the specified timeframe. Accordingly, Associates are cautioned to account for such potential
changes in their ownership or trading of Digital Assets.

Regardless of a Digital Asset’s status as a Covered Security, Nasdaq may establish Prohibited and/or Restricted Digital Assets
lists for the purposes of regulating Associate or Associated Person investments in digital assets. Nasdaq may prohibit Associate
or Associated Person investment in any Digital Asset determined to have or advance an illegal or unethical purpose or to have
been determined to be subject to regulatory requirements inconsistent with their ownership by Nasdaq Associates.

To the extent that Nasdaq publishes a Supplemental Policy for Digital Assets Associates, such Associates will be subject to the
additional restrictions and disclosure requirements as set forth in such policy.

7. Digital Assets may be subject to different treatment and/or additional restrictions and requirements in a Supplemental Policy.

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Section 2: Insider Trading & Market Abuse

Most jurisdictions where Nasdaq conducts business prohibit,

What is Insider Trading?
by law, insider trading and other forms of market abuse. Insider Trading is buying or selling publicly traded
Associates who are aware of material non-public information securities when you have important information
(MNPI) relating to Nasdaq or to any other company are about a company that members of the public do not
reminded that they may not buy or sell Nasdaq securities or have. It is illegal in most jurisdictions and can result
such other company’s securities or give, communicate, or in a fine and/or imprisonment.
in any other way tip or convey such information to another Associates are prohibited from trading securities
person. These restrictions apply regardless of whether you when they are in possession of material non-public
received information as an intended recipient or received it information, or MNPI.
incidental to your work at Nasdaq (e.g., received it as part of a
For information to be considered public, it must
group email or accidentally overheard a conversation). These
have been disclosed in public filings or widely
restrictions apply regardless of whether the security involved
disseminated through press releases and widely
is a Covered Security under this policy.
available in news media, websites, or webcasts.

What is MNPI?
The term “material non-public information” (MNPI) 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.8

MNPI includes, but is not limited to, confidential information (until any such information is generally known to the public)
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;
• Self-certification, de-certification, approval, or removal of a Digital Asset or type of digital asset for custody, listing, or any
other business purpose;
• News of a significant new business transaction;
• 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.

8. Even if non-public information is not “material,” under Nasdaq’s Code of Ethics, Associates are prohibited from using any non-public information learned during their employment at Nas-
daq except to perform their work for Nasdaq; Associates are also prohibited from disclosing this information except as explicitly authorized. Violations of these requirements can result in
disciplinary action, up to and including termination.

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Protecting MNPI
Just like other forms of confidential information that you may learn during your employment at Nasdaq, MNPI cannot be
communicated to other persons in any manner. Even inadvertent communications must be avoided. Any inadvertent disclosure
of MNPI must be immediately reported to the Global Ethics Team or the Office of General Counsel. Practical measures to protect
the confidentiality of information include:

• Logging off of your computer when you leave your desk and the building;

• Setting your screen saver setting to a short duration and password protect your screen saver;

• Physically securing laptops or iPads in lockable drawers when not in use;

• Locking confidential information away when it is not being used;

• Removing sensitive documents from desks, photocopiers, printers or fax machines;

• When disposing of documents that are not required to be kept by our retention policy, using the paper shredders or
shredding bins provided on site or, if working remotely, bringing documents to the office for shredding or coordinating with
your manager to ensure appropriate shredding;

• Accompanying visitors through the building at all times;

• Guarding against inadvertent disclosure of information through conversations that might be overheard;

• Avoiding reading or discussing confidential or sensitive information in public areas and where it cannot be avoided, using
screen filters to prevent on-screen information being readable by others and abbreviations or code names where possible;

• Checking distribution lists carefully when sending emails with confidential and sensitive content; and

• Escalating any data breaches, loss, or leakage (inadvertent or not) to the Ethics Team or the Office of the General Counsel
as soon as you become aware of them.

Working from Home

If you are working in a home office or other remote work location and your role requires accessing material non-public
information, you must take appropriate measures such as those identified above to secure such information from disclosure
to others present in your home or work location. When working remotely, you should avoid accessing material non-public
information outside of your primary home office or remote work location (e.g., avoiding public settings). You should consult with
your manager, Compliance Officer and/or the Ethics Team if you have questions about how to implement appropriate measures
in a non-office location.

Market Abuse
Market abuse offenses typically cover the insider trading situations mentioned above, but may also include far broader scenarios
and involve a wider variety of securities. These broader scenarios may include:

• misuse of information;

• manipulating transactions which give a false or 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.

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Conflicts of Interest
Associates must carefully consider how their trading activity, even where permitted by this policy, would be perceived by
Nasdaq’s regulators or other stakeholders. In addition to the specific requirements set forth in this Policy, Associates must avoid
situations where their personal financial interests or the interests of an Associated Person could reasonably give the appearance
that the Associate is acting to benefit such interests or otherwise has a conflict of interest regarding a matter being worked by
the Associate for Nasdaq. This obligation is especially important where an Associate is an executive level employee, decision
maker or key participant in performing Nasdaq’s duties as a self-regulatory organization (SRO) (regardless of whether the
Associate is a Regulatory Associate under Section 5 of this Policy); developing policy proposals on behalf of Nasdaq; or, making
public comments on behalf of Nasdaq or related to a company doing business with it.

Associates must immediately disclose any such potential conflicts of interest to the Global Ethics Team and the management.
Based on the nature of the potential conflict of interest and other relevant factors, the Global Ethics Team may require the
Associate to recuse him/herself from a decision or activity or take other actions to mitigate the potential conflict of interest.

Prior to an Associate undertaking certain activities, Nasdaq may require the Associate to certify that neither the Associate nor
any Associated Person (a) has any financial holdings or (b) has engaged in or plans to engage in any transactions that could
reasonably create the appearance of a conflict of interest.

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Section 3: Global Trading Policy Rules

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 activity in any security, commodity
or other instrument or asset (including ETFs or other assets not covered within the definition of “Covered Securities” under this
Policy) that is not consistent with these requirements may be subject to additional scrutiny and potential disciplinary action.
Where an Associated Person (as defined in this Policy) is engaged in frequent trading, the Associate must 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.

Global Trading Policy Rules

The following Global Trading Policy Rules apply to all trading activity in Covered Securities by Associates and their
Associated Persons.9

1. Trading Disclosures & Transaction Reporting Rule

Associates must disclose the following in Nasdaq’s Ethics, Trading, and Compliance Hub (the “Hub” or the “Ethics Hub”)
(accessible via Okta on Nasdaq’s intranet):

(1) all brokerage and trading accounts capable of holding Covered Securities that are held in the Associate’s name or
that is actively managed or used by the Associate or their Associated Persons, and

(2) all holdings and transactions of Covered Securities in these accounts or that are held in physical form.10

U.S. Associates must maintain accounts at approved brokerage firms unless they have been granted a hardship waiver.
Further information is provided in “Section 4: Certification, Brokerage Account, & Transaction Reporting Requirements.”

2. 30-Day Hold Rule

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 an exempted financial account (see “Account-Specific Rules” in Section 4 of this Policy);

• 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.

For calculating the holding period, the date of purchase is considered the first day of the 30-day Hold Period; the Covered
Security must be held for a full 30 calendar days. For example, if a Covered Security is purchased on March 1st, it cannot be
sold until March 31st as the required holding period would run from March 1 until March 30.

9. Guidance on how these rules apply to options is posted to Insider.

10. Contractors, interns, and student workers are not required to disclose their brokerage accounts or holdings in the Ethics Hub, but they must maintain quarterly account statements (paper
or electronic) and provide them for inspection and review at the request of the Global Ethics Team, applicable Compliance Officer, and/or Internal Audit. See “Associate Exemptions” in
“Section 4 – Certification, Brokerage Account Disclosures, & Trading Reporting Requirements” for more information.

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3. Prohibited Company List Rule
All Associates and Associated Persons are precluded from trading the Covered Securities in any company included on the
Companywide Prohibited Company List, which primarily includes publicly traded exchanges that directly compete with
Nasdaq.

The Prohibited Company List and current Supplements are posted on Nasdaq’s intranet and are reviewed quarterly and/
or as business circumstances change. Any sale of existing Prohibited Company List securities is subject to pre-clearance.
Once pre-clearance is provided, the Associate or Associated Person must sell the affected Covered Securities within 24
hours; such time period may be extended to 48 hours for lightly traded securities (as determined by the Ethics Team).

An Associate must obtain a written waiver (using the designated form) from the Ethics Team to purchase (or have an
Associated Person purchase) a Prohibited Company List security. Absent exigent circumstances, such requests will be
denied.

4. Initial Public Offerings (IPO) Rule

All Associates and Associated Persons are precluded from purchasing Covered Securities in an IPO on any exchange during
the first seven (7) calendar days from when it begins trading, including the offering date. Associates must seek guidance
prior to participating in any initial coin offerings (ICOs).

5. Short Selling Rule

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.

Associates are not permitted to engage in short selling of Covered Securities except where (1) the short selling is part of risk
management or hedging strategy reviewed and documented 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.

Any Associate engaging in “short selling” must do so consistent with the objectives and requirements of 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.

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Waivers and Exceptions
Waivers
Waivers to this Policy are considered and granted by the Ethics Team where there is a reasonable, documented 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 Global
Ethics Team. An Associate may request a waiver by completing a Waiver Request Form found in the Ethics Hub under the
“Certifications” tab.

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 2 in Section 4 (page 18) outlines exceptions to the general rules which apply to brokerage accounts.

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Section 4: Certification, Brokerage
Account Disclosures, & Trading Reporting
Requirements

Annual Compliance Certification

All Associates must confirm within thirty days of hiring and annually that they (1) are in compliance and will comply with
applicable requirements in Trading Policy and (2) have completely and properly disclosed, to the extent required by this Policy
and any applicable Supplemental Policy, all brokerage/trading accounts and relevant trading activity.
Nasdaq may, also from time to time, require 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.

Brokerage Account What financial accounts need to

& Disclosure Requirements
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. Associates are required to disclose in the
Ethics Hub for themselves and their Associated Persons: (1) all
brokerage and trading accounts capable of holding Covered
Securities that are held in the Associate’s or Associated
Person’s name, and (2) all holdings and transactions of
Covered Securities in these accounts. Account disclosure is
required within 30 days of the Associate’s hire date and within
10 days of the opening of any new brokerage account.
Associates can reference Table 1 (below) for specific
disclosure requirements depending on their location and the
brokerage firm they are using.
be disclosed?
A “brokerage account” for the purposes of this Policy
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.”
Retirement, educational saving, and similar accounts
that limit the holder to a restricted list of highly-
diversified funds as investment options do not need
to be disclosed.

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U.S. Associates
U.S. Associates and their Associated Persons may only establish and maintain accounts at brokerage firms that provide
automatic updates to Nasdaq through an electronic data feed. A current list of approved “Electronic Feed Firms” is posted on
the Ethics Hub homepage. Associates and Associated Persons must complete any documentation or authorizations required by
their brokerage firm to provide an electronic data feed to Nasdaq.

Some firms that provide automated account services including through “robo-advisers” do not provide Nasdaq with an
electronic data feed. Robo-advisor and similar accounts that can hold Covered Securities are considered brokerage accounts
under this policy and are subject to all rules and requirements of the policy. Associates should limit the use of robo-advisors
to accounts that can only hold investments that do not constitute Covered Securities such as exchange traded funds, mutual
funds, and other securities not encompassed by the definition of Covered Securities.

U.S.-based Associates who require a letter of authorization to open or maintain an account at an approved electronic feed
brokerage firm can request a letter of authorization from CodeofEthicsNasdaq@Nasdaq.com.

Electronic Feed Brokerage Account Hardship Waivers

US Associates must obtain a hardship waiver for any account by the Associate or their Associated Person that does not
provide Nasdaq an electronic data feed. Waivers are not granted as a matter of course, but on reasoned grounds when
limiting the Associate to the use of an electronic feed account is not possible without a substantial negative impact on
the Associate or the affected Associated Person. Associates are encouraged to speak with the Ethics Team regarding the
waiver process. Associates may request a waiver from the electronic feed requirement by submitting a the “Brokerage
Account Waiver Request” through the “Certifications” tile in the Ethics Hub. Such request must explain the hardship on the
Associate if he/she were not permitted to use the non-electronic feed broker.

If a hardship waiver is approved by the Global Ethics Team, the Associate must (1) report transactions in Covered Securities
in the Hub within seven (7) days of the transaction closing and (2) maintain quarterly account statements (paper or
electronic) available for inspection and review at the request of the Global Ethics Team, applicable Compliance Officer, and/
or Internal Audit for three years.

Global Associates
Associates whose primary work location is outside of the United States can, but are not required to, maintain brokerage
accounts at firms that provide automatic trading updates to Nasdaq through an electronic data feed. A list of “Electronic Feed
Firms” available to Global Employees is listed on the Ethics Hub homepage.

Global Associates and their Associated Persons who maintain accounts at non-electronic feed firms must (1) report transactions
in Covered Securities in the Hub within seven (7) days of the transaction closing and (2) maintain quarterly account statements
(paper or electronic) available for inspection and review at the request of the Global Ethics Team, their Compliance Officer, and/
or Internal Audit for three years.

Where the Associate/Associated Person (1) has accounts at a financial institution providing an electronic feed of holdings and
trades to Nasdaq, (2) reported the account in the Hub as an electronic feed account, and (3) authorized an electronic feed to
Nasdaq if required by the financial institution and/or local law, the manual reporting requirements detailed above do not apply.

Supplemental Policies
For Associates in specific locations, conducting certain work functions, or registered with U.S. broker-dealer affiliates of Nasdaq,
there may be Supplemental Policies, guidelines, and requirements with respect to disclosure of brokerage accounts and/
or holdings. Associates must consult “Section 5: Supplemental Trading Policies” and the appropriate Supplemental Policy for
guidance on the scope and application of these rules.

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Table 1: Disclosure & Reporting Requirements

U.S. Employees Global Employees

Electronic Required for all U.S. Associates.
Feed Firm Employees must ensure their Ethics Hub profile is
updating their security holdings correctly (1) 6-8
weeks after disclosing the account in the Ethics
Hub and (2) annually in conjunction with their annual
compliance certification. Employees must notify the
Global Ethics Team if their holdings are not reflected
correctly in the Ethics Hub.
Optional for Global Associates. Employees must
submit any authorization forms required by their
brokerage firms to enable feed. Employees must
ensure their Ethics Hub profile is updating their
security holdings correctly (1) 6-8 weeks after
disclosing the account in the Ethics Hub and (2)
annually in conjunction with their annual compliance
certification. Employees must notify the Global
Ethics Team if their holdings are not reflected
correctly in the Ethics Hub.

Non- Only permitted in approved waiver cases where
Electronic migrating accounts to an approved Electronic Feed
Feed Firm Firm poses a significant financial hardship for the
employee. Employees are required to enter all
transactions of Covered Securities into the Ethics
Hub within seven (7) days of the transaction taking
place. Employees must certify annually that their
disclosures are made in compliance with this Policy.
Optional for Global Associates. Employees are
required to enter all transactions of Covered
Securities into the Ethics Hub within seven (7) days
of the transaction taking place. Employees must
certify annually that their disclosures are made in
compliance with this Policy.

Disclosure Accuracy
Associates are responsible for the completeness and accuracy of their disclosures in the Hub. This includes ensuring the
accuracy of account information to enable electronic data feeds.11 Associates must certify to the accuracy of the disclosures
annually, to include ensuring the electronic feed is updating the Ethics Hub appropriately.

Associate Exemptions
Non-Employees (Contractors, Consultants, & Interns)
Associates that are non-employees (e.g., contractors and consultants) or interns (e.g., student workers) are not required to
disclose their brokerage accounts or provide electronic feeds to the accounts except where required by a Supplemental Policy,
applicable law, or contract terms (for non-employees). Associates not subject to disclosure duties must maintain quarterly
account statements (paper or electronic) and may be required to provide the statements or other documents evidencing
compliance as part of a compliance review, audit, or investigation at the request of the Global Ethics Team, applicable
Compliance Officer, and/or Internal Audit.

Specific Geographic Locations

Employees in certain countries may be exempted from disclosure requirements and rules outlined in this Policy in order 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.

11. Data entered into the Ethics Hub is solely used for compliance purposes and is subject to the applicable Associate Privacy Policy posted on Nasdaq’s intranet (which applies to both
information about the Associate and any Associated Persons stored in the system).

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Account-Specific Rules
The following account types are subject to various trading and disclosure rules, requirements, and/or exemptions.

Managed Accounts
A managed account is an account over which the Associate or Associated Person exercises no discretion, influence, or control
over the day-to-day activities or trading. An account is considered a managed account when the financial advisor exercises
discretion over the holdings and trades based on account parameters or a strategy selected by the Associate/Associated Person.

Rule Exemptions
When registered with Nasdaq’s Global Ethics Team in advance (see “Account Registration” below), a managed account is not
subject to the 30-Day Hold Rule or Short Selling Rule as outlined in “Section 3: Global Trading Policy Rules” of this Policy.

The Prohibited Company List and IPO restrictions apply to all managed accounts as set forth in Table 1. At all times, the
Associate remains fully accountable for the financial advisor’s compliance with this Policy. 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.

Account Registration
To be excluded from the 30-Day Hold Rule and Short Selling Rule, an account must be registered with the Global Ethics
Team by completing the appropriate form in the “Certifications” tile of the Ethics Hub. After a review of the submission, the
Global Ethics Team will notify the employee’s financial advisor of the registration with Nasdaq’s Global Ethics Team.

For U.S.-based Associates, managed accounts at firms that do not provide Nasdaq with electronic data feed of holdings
and trades are discouraged and must separately be approved for a hardship waiver under the “Brokerage Account Hardship
Waivers” in Section 4 of this Policy. For non-electronic feed managed accounts, 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.

Disclosures & Reporting

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 disclosure options
described in this Policy, 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 Supplemental Policies, 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.

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Trusts
A trust is an account that allows a third party, the trustee, to hold assets on behalf of a beneficiary. For the purposes of this
Policy, Nasdaq recognizes three trust scenarios:

Blind Trust
A blind trust is an account in which a non-Associate trustee exercises full control and where an Associate or their
Associated Person is a designated beneficiary and has no knowledge of or influence over the holdings.

Third Party Trustee

In a trust managed by a third party where the Associate or their Associated Person is a designated beneficiary, the
Associate or their Associated Person has knowledge, but no control over the holdings within the trust.

Associate Trustee
In cases where the Associate or their Associated Person is the trustee, the Associate has discretion, influence, and/or
control over the trust.

Blind Trusts & Third Party Trustee

When the Associate or their Associated Persons exercise no discretion, influence, or control over the day-to-day activities
or trading, the accounts are exempted from the 1. Trading Disclosures & Transaction Reporting Rule, 2. Prohibited
Company List Rule, 3. Initial Public Offerings (IPO) Rule, 4. 30-Day Hold Rule, and 5. Short Selling Rule outlined in Section 3
of this Policy.

Associate Trustee
When the Associate or their Associated Person exercises discretion, influence, and/or control over the day-to-day activities
or trading, the trusts are considered a brokerage account for the purposes of this Policy and are subject to all rules and
disclosure requirements outlined in this Policy.

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Table 2: 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.

Applicable Global
Trading Policy Rules

3. Prohibited Company List Rule

Transaction Reporting Rule

4. Initial Public Offerings

1. Trading Disclosures &

2. 30-Day Hold Rule

5. Short Selling Rule

(IPO) Rule
Account Type Brief Description

Brokerage Account Any account in an Associate’s name

which is capable of trading or holding
Covered Securities Yes Yes Yes Yes Yes
(Including accounts managed or serviced
by a “robo-adviser” 12)
Managed Account Account in the Associate’s name over
which s/he exercises no discretion,
influence, or control Yes No Yes Yes No
(Ethics Team registration and broker
notification is required)
Trust where Associate is the trustee Associate has control over trust
(Treated like a Brokerage Account)
Yes Yes Yes Yes Yes

Trust managed by a third party trustee Third party has full control over trust,
(including blind trusts) with Associate Associate may have knowledge but no
or Associated Person as beneficiary discretion, influence, or control No No No No No

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

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Section 5 – Supplemental Trading Policies

Certain Nasdaq Associates are subject to supplemental trading policies when their work location or job responsibilities are
subject to specialized regulatory requirements or present unique compliance or conflict of interest risks. Supplemental Trading
Policies posted to the Policy Library on Nasdaq’s intranet include:

Role-Based Supplemental Policies

• Regulatory and Surveillance Associates Supplemental Policy
• Index Team Supplemental Policy
• Digital Assets Associate Supplemental Policy
• Dorsey, Wright & Associates Supervisory Procedures
• Applicable Broker-Dealer Associates Supplemental Policies
• Directors & Executive Officers

Location-Specific Supplemental Policies

• Nasdaq Affiliates in Denmark Supplemental Policy
• Nasdaq Affiliates Domiciled in Estonia Supplemental Policy
• Nasdaq Affiliates Domiciled in Finland Supplemental Policy
• Nasdaq Affiliates Domiciled in Iceland Supplemental Policy
• Nasdaq Affiliates Domiciled in Latvia Supplemental Policy
• Nasdaq Affiliates Domiciled in Lithuania Supplemental Policy
• Nasdaq Affiliates in Norway Supplemental Policy
• Nasdaq Affiliates in Sweden Supplemental Policy

Sensitive Information Supplemental Policies

Some Associates, by virtue of their job functions and the information to which they routinely have access or can be presumed
to have routine access, are subject to additional trading restrictions. Associates, who by virtue of their job function fall into more
than one of the groups listed below or in another section of this policy, will be held to the stricter of the applicable standards.

The following categories of Sensitive Information Associates are determined by the Associate’s job function. Associate inclusion
in these categories is outlined in the corresponding supplemental policy.

Regulatory Associates
Regulatory Associates are Nasdaq Associates who perform functions related to regulatory oversight or investigation of companies.
This includes Associates involved in listing qualifications, investigations, enforcement, hearings, and Nasdaq’s performance of its
obligations as a self-regulatory organization (SRO). Regulatory Associates are subject to the Regulatory & Surveillance Associates
Supplemental Policy. As further detailed in the supplemental policy, Regulatory Associates must obtain pre-clearance approval
prior to trading Covered Securities, must disclose to their management whether they or an Associated Person owns the Covered
Securities of an entity subject to their oversight, and are prohibited from transacting in Covered Securities of companies under
review, investigation, or consideration for delisting from the time of the start of their review until such time as the matter concludes.

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Exchange Sensitive Information Associates
Exchange Sensitive Information Associates are Nasdaq Associates who are involved in MarketWatch or market surveillance
functions (or have equivalent access to information as Associates performing such function). Exchange Sensitive Information
Associates are subject to the Regulatory & Surveillance Associates Supplemental Policy and must obtain pre-clearance approval
prior to trading Covered Securities as outlined in the Supplemental Policy.

Index Associate
Index Associates are Associates who are involved in the development, management, maintenance, and/or sale of indexes or
benchmarks. As further set forth in the Supplemental Policy for Index Associates, Index Associates are subject to additional
restrictions and preclearance requirements to avoid actual or perceived conflicts of interest related to Nasdaq’s index and
benchmark businesses.

Digital Assets Associate

Digital Assets Associates are Associates who are part of Nasdaq’s Digital Assets business unit (including legal entities
established within it) or are determined to be substantially involved in its operations. Associates involved in these functions
may be subject to restrictions and requirements related to their ownership and trading of digital assets as further set forth in a
supplemental policy.

Dorsey, Wright & Associates Access Persons

For Associates considered “access persons13,” related to the business of Dorsey, Wright & Associates, there are additional
guidelines and requirements with respect to personal trading. Those guidelines and requirements can be found in the Dorsey,
Wright & Associates Written Supervisory Procedures, which applies to such Associates as a Supplemental Policy to this policy.

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.

Directors and Executive Officers

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 disclose or
provide electronic feeds to their brokerage accounts or disclose holdings. 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.

Location-Specific Supplemental Policies

Associates whose primary work location is in certain geographical locations may be subject to additional trading restrictions.
Associates should reference the Policy Library on Nasdaq’s intranet for further information.

13. For the purpose of this Policy, “access person” is a person who provides investment advice on behalf of an investment adviser and is subject to the supervision and control of the invest-
ment adviser, who has access to non-public information regarding clients’ purchase or sale of securities, is involved in making securities recommendations to clients or who has access to
such recommendations that are non-public. Access persons may include, but are not limited to, officers, portfolio management personnel, and client service representatives who commu-
nicate investment advice to clients.

nasdaq.com For Internal Use Only | 20

Section 6 - Restrictions on Trading NDAQ
Securities & Watch List

Short Selling & Options Involving NDAQ Securities

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. Ownership in NDAQ securities provides an opportunity to share in
the long-term growth of the company. Short-term investments based on market fluctuations are incompatible with this objective
and may put your personal gain in conflict with the best interests of Nasdaq and its shareholders.

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. In addition, Associates and Associated Persons are prohibited from selling
option contracts against any NDAQ Securities that they own or otherwise trading in options on NDAQ Securities.

Watch List Associates

Watch List Associates are individuals identified as having access to Nasdaq internal financial statements or other material non-
public information (MNPI) about Nasdaq related to the development of its quarterly and annual financial reporting. Associates
identified as Watch List Associates will be notified that they are on the Watch List.

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 during a closed trading window.

Trading Windows
Trading window status is posted to Nasdaq’s intranet.

Window Open
Trading windows typically open one full trading day after financial results for the fiscal quarter have been publicly disclosed.
Nasdaq may close or delay the opening of a trading window for Watch List Associates, or any smaller subset of Associates,
at any time it deems necessary or advisable. Watch List Associates will be notified at the opening of a trading window.

Window Close
Trading windows typically 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. Nasdaq may close the trading window outside of the listed dates if it
deems necessary or advisable. In the event the trading window is closed outside of the listed dates, Watch List Associates
will be notified.

Gifting NDAQ
You may not make a gift of NDAQ securities while aware of material nonpublic information or, for Watch List Associates, during a
closed window unless (a) the gift is made to a family member or to an entity that you or your family members control (such as a
trust, foundation or other organization over which you exercise control with respect to the sale of the gifted securities), and (b)
you ensure that the recipient does not sell such securities during any period when you are not permitted to sell NDAQ securities
under this policy. Directors and Section 16 officers also must obtain pre-clearance from the Office of General Counsel before
making any gift of NDAQ securities.

nasdaq.com For Internal Use Only | 21

Equity Incentive & Employee Stock Purchase Plans
The sale of any shares acquired under the Equity Incentive Plan or Employee Stock Purchase Plan (ESPP) is subject to Watch
List restrictions.

No Safe Harbor – Possession of Material Non-Public Information

Trading in NDAQ Securities during the open trading window should not be considered a “safe harbor.” Even during an open
trading window, any person possessing material non-public information (MNPI) 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. Nasdaq Associates should refrain from any transactions in Nasdaq Securities until
at least one full trading day has passed after the public announcement of information, whether or not the Associate is on the
Watchlist.

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 non-public information (MNPI). While not required, Watch List Associates and Associates who regularly
may possess material non-public information (MNPI) due to their normal work responsibilities are encouraged to enter into a
10b5-1 Plan.

Other NDAQ Restrictions

When deemed necessary, Nasdaq 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.

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