Approach
Our directors are focused on managing sustainability risks and opportunities at both the full Board level and on multiple Board committees. At the committee level, the Nominating and Corporate Governance Committee is charged with reviewing and assessing the company’s environmental, social and governance initiatives and making recommendations to the company to further its sustainability goals (NCGC Charter). The committee reviews sustainability matters at two or more meetings each year. In addition to the mandate of the Nominating and Corporate Governance Committee, important aspects of managing these risks and opportunities are a focus for the following committees:
- Risk Committee – Cybersecurity and climate related risks
- Compensation Committee – Human capital management issues, including diversity and pay parity
Each committee briefs the full Board on topics addressed at the committee level and the full Board further discusses issues as needed.
Our overall strategy is guided by a Sustainability Governance Committee comprised of senior officials from across the company, including the:
- President
- Chief Financial Officer
- Chief Operating Officer
- Corporate Risk Officer
- General Counsel
- Human Resources Officer
- President, Sustainable Finance & Chief Regulatory Officer
- President, New York Stock Exchange
- President, Fixed Income & Data Services
- President, ICE Mortgage Technology
- Senior Vice President, Futures Exchanges
- Vice President, Corporate Affairs & Sustainability
This committee meets quarterly and communicates frequently to assess ESG risks and opportunities across the company.
Several departments play a critical role in our approach to sustainability, including the human resources, facilities, risk management and business continuity teams. Our vice president of sustainability coordinates these efforts and oversees our disclosures and strategy.
Our president for sustainable finance oversees the development of sustainable products and services companywide and guides our mission to provide innovative market tools to help our clients achieve their own climate risk and opportunity strategies and meet other sustainability goals.
We believe that the success of our business relies on our ability to deliver on our purpose as a company for each of our major stakeholders. Good shareholder returns go hand-in-hand with engaged employees and satisfied customers.
To ensure we fully understand the views of our stakeholders, we worked with a third-party consultant to conduct a formal materiality analysis in 2020 to gather feedback from our employees, customers, investors, suppliers and communities. We have informally refreshed the assessment since then through ongoing dialogue with our stakeholders and plan to do a formal update following the acquisition of Black Knight.
Our sustainability reporting focuses on the areas deemed to be most relevant for our business and stakeholders based on this analysis.
We began publishing annual sustainability reports in 2016 and we continue to evolve and refine our reporting each year. Our website also includes additional details that are updated throughout the year to provide a more real-time view of what we are doing. Additionally, we use reporting standards to enhance our disclosures, including:
- Taskforce on Climate-related Financial Disclosures (TCFD)
- Carbon Disclosure Project (CDP)
- Sustainable Accounting Standards Board (SASB)
- UN Sustainable Development Goals (SDGs)
In addition to the actions we take within our own business, we monitor the impact we can have through our supply chain, including:
- Vendor Onboarding - Through our vendor onboarding and assessment processes we are collecting ESG data points to inform our decision making. ICE suppliers are required to complete a sustainability questionnaire during initial onboarding. Material vendors (Tier 1 & Tier 2) are required to complete a sustainability questionnaire annually for ongoing due diligence. This includes efforts to track and expand our spend with diverse-owned businesses and assess efforts by our vendors to measure and reduce carbon emissions. We are still in the early stages and are actively working to build out the appropriate framework.
- Code of Conduct - Our business partners and third parties are an extension of our organization. We expect that our suppliers, agents and business partners will follow ethical standards similar to our own when working with us or on our behalf. This means that we will consider terminating contracts with vendors or partners that do not strive to meet our high standards or contractual obligations.
- Human Rights - Our Modern Slavery Act Policy reflects our commitment to acting ethically and with integrity in all ICE business relationships, and to implementing and enforcing effective systems and controls to help ensure slavery and human trafficking is not taking place anywhere in our supply chains.