Our compliance policies are approved by the board’s Nominating and Corporate Governance Committee and reviewed regularly and assessed for effectiveness. All employees (full and part time) globally, as well as contractors, are trained, tested and must attest that they have read and understand the appropriate policies upon hire and annually thereafter. Test scores are assessed to ensure understanding. Any breach of our policies is investigated, and, when necessary, appropriate actions are taken, which may include termination of employment. Our policies include:

Our Code of Business Conduct is an outline of the rules and principles by which we operate on a global basis. It is not a comprehensive manual that covers every possible situation – no document could be. It is a guide that serves as a reference and a reminder. At ICE, we do the right thing not because it is written in a code but because it is part of our ethos and the commitment we are making to our customers who trust us with their investing and risk management needs.

The Code is framed around ICE’s core values: collaboration, problem solving, communication, integrity & professionalism and leadership.

It encourages employees to come forward with questions, concerns and reports of actual or suspected misconduct with the confidence that ICE’s commitment to non-retaliation is firm. We take all claims of retaliation seriously, investigating each one thoroughly and taking appropriate action.

The Code covers topics including:

Procedures are in place requiring that gifts, meals and entertainment given to or received from a business partner above certain thresholds must be reported to and approved by the compliance department. Additionally, gifts, meals and entertainment given to or received from a government official must be reported at any level.

As part of our Global Reporting and Anti-Fraud Policy, we have a Protected Disclosure Hotline (formerly known as the Whistleblower Hotline) that can be accessed easily through both external and internal resources.