CME GROUP INC.
CHICAGO MERCANTILE EXCHANGE INC.
BOARD OF TRADE OF THE CITY OF CHICAGO, INC.
NEW YORK MERCANTILE EXCHANGE, INC.
COMMODITY EXCHANGE, INC.
BOARD OF DIRECTORSCODE OF ETHICS
The Boards of Directors (the “Board”) of CME Group Inc. (“CME Group”), Chicago Mercantile
Exchange Inc. (“CME”), Board of Trade of the City of Chicago, Inc. (“CBOT”), New York
Mercantile Exchange, Inc. (“NYMEX”) and Commodity Exchange, Inc. (“COMEX”) (collectively,referred to as, the “Company”), is committed to the highest standards of conduct in its
relationships with its employees, clients, members, shareholders, regulators and the public. Thismeans conducting our business in accordance with all applicable laws and regulations, and it
also means commitment to the spirit of the law. Our actions should reflect the Company’svalues, demonstrate ethical leadership, and promote a work environment that upholds theCompany’s reputation for integrity, ethical conduct and trust. This Code is intended to provide astatement of the fundamental principles applicable to our Board.
Directors are encouraged to bring questions about particular circumstances that may involve
one or more of the provisions of this Code to the Chairman and Chief Executive Officer, theChair of the Nominating and Governance Committee, the Lead Director or the General Counsel,
who may consult with legal counsel and/or the Managing Director, Chief Enterprise Risk
Management and Compliance Officer as necessary or appropriate.
Any directors who also serves as an officer of the Company must also comply with the CMEGroup Employee Code of Conduct.
On an annual basis, directors are required to acknowledge that they have read, understand, arein compliance with and agree to abide by this Code. The failure to acknowledge this Code will
not affect the application of any of its provisions.
The Nominating and Governance Committee shall periodically consider whether and how thisCode should be revised or amended.
WE WILL COMPLY WITH ALL APPLICABLE LAWS, RULES AND REGULATIONS
Obeying the law, both in letter and in spirit, and behaving in a manner consistent with theCompany’s values is the foundation of our ethical standards. All Board members are expected
to conduct their business and affairs in compliance with applicable laws, rules and regulations,and to encourage and promote such behavior for themselves, senior leaders and otheremployees.
WE WILL DEAL FAIRLY WITH OUR STAKEHOLDERS
Each Board member should deal fairly with the Company’s employees, clients, members,
shareholders, regulators, competitors and vendors. No Board member should take unfair
advantage of anyone through manipulation, concealment, abuse of confidential information,
misrepresentation of material facts, or any other unfair dealing practice.

WE ACT IN THE BEST INTERESTS OF OUR SHAREHOLDERS AND OUR COMPANY AND
APPROPRIATELY ADDRESS CONFLICTS OF INTEREST
In order to maintain the highest degree of integrity in the conduct of our business and tomaintain their independent judgment, Board members must avoid any circumstance that createsor appears to create a conflict between a Board member’s own interests and the interests of theCompany. A Board member may be a member, officer or owner of a member firm or a client ofone of the Company’s exchanges without creating a conflict or the appearance of a conflict.
However, a director’s affiliation may be relevant when evaluating whether a particular matter
before the Board presents a conflict of interest warranting further examination as to the role of
the affected director (See the Company’s Director Conflict of Interest Policy).
A conflict of interest arises when a Board member’s loyalties or interests are divided between
the Company's best interest and his or her personal interests directly or indirectly. For example,
a conflict of interest may be implicated when a Board member participates in a Board processthat could result in a benefit to his or her family, an individual with a close personal relationshipor an organization with which he or she is affiliated. Certain situations are so likely to create theappearance of a conflict of interest that they must be avoided. The Board has adopted theDirector Conflict of Interest Policy to provide additional guidance as to when a specific situation
may involve a conflict of interest and the appropriate procedures for resolving that conflict. Any
situation that involves, or may involve, a conflict of interest must be promptly disclosed inaccordance with the Company’s Director Conflict of Interest Policy.
Board members are also prohibited from competing with the Company or taking for themselves
personally or for the organizations with which they are affiliated opportunities that arediscovered through the use of Company property, information or position without the consent ofthe Board.
WE USE AND PROTECT THE COMPANY’S PHYSICAL ASSETS APPROPRIATELY
Each Board member has a duty to safeguard the Company's assets, including its physicalpremises and equipment, records, client information and Company names and trademarks.
Company assets should be used for Company business only. Without specific authorization,
Board members may not take, loan, sell or otherwise dispose of any Company property, or useCompany property, information or position for improper personal gain.
WE PROTECT AND PREVENT THE MISUSE OF CONFIDENTIAL AND MATERIAL NONPUBLIC INFORMATION
Board members may often receive or have access to confidential, sensitive and non-public
information about the Company and others. Board members should presume that any
information they receive about the Company or about the Company’s clients, members orothers through their work as a Board member is confidential and, therefore, should not be
disclosed or made public, except when disclosure is authorized or legally required. Boardmembers have an obligation to safeguard confidential information, whether generated internallyor acquired from others, and to use it only in the performance of their responsibilities as a Board
member. Without the prior written approval of the General Counsel, Board members may notuse any proprietary data or personal information collected or received by the Company for thepurpose of fulfilling its regulatory obligations for business or marketing purposes. The obligation
to preserve the Company’s confidential information is ongoing even after an individual’s service
as a director ends.
2WE ARE FAIR AND OPEN IN OUR COMMUNICATIONS
We keep investors, creditors, securities trading markets, employees and the general public
informed on a timely basis through the public release of relevant and understandable financial
and other information about our Company. In releasing the information about the Company, we
make every effort to ensure full disclosure is made to everyone without preference or favoritism
to any individual or group. We respond to public inquiries – including through news media,
governments or others – with prompt, courteous, honest responses through authorized
members of the Company’s Global Brand Marketing and Communications or Investor Relations
teams and other authorized individuals such as the Chairman and Chief Executive Officer andthe Chief Financial Officer, as described in CME Group’s External Communications Policy,
which is available from the Office of the Secretary. As part of this policy, we will not comment onrumors or other matters such as the following due to the material or confidential nature of thesubject:






Potential mergers, acquisitions or other strategic initiatives
Significant new product plans prior to receipt of the requisite approvals, publicannouncement and/or proposed regulatory filing
Matters to be presented to the Board for its approval
Matters relating to the Company’s future performance, such as anticipated future trading
volumes
Disciplinary actions or investigations relating to our markets or employees
Pending litigation
Changes in debt ratings

WE USE ELECTRONIC COMMUNICATIONS TECHNOLOGY RESPONSIBLY AND
PROFESSIONALLY
The Company’s computers and electronic communication systems, including computers, mobiledevices, voicemail, e-mail and the Internet, provide substantial benefits, but they also presentsignificant security and liability risks to the Company and its Board members. Board members
must take all necessary measures to safeguard the security of any issued Company technology.
When using Company resources to send e-mail, voicemail or to access Internet services, youare acting as a representative of the Company. Board members have a responsibility to use
these resources in a safe, ethical and lawful manner.
CME Group has implemented a number of policies and procedures consistent with applicablelaw to protect the confidentiality, integrity, and availability of its information and assets. To
support these efforts, the Company reserves the right to take possession, access, review,monitor, intercept, or conduct surveillance on any information stored on its systems, including
any messages sent or received using a Company issued computer, handheld device or email
address. In connection with litigation, internal investigations, or governmental, regulatory oradministrative inquiries or examinations involving the Company, we may be required to review
and produce information, including information sent or received by a Board member using oursystems or email addresses. Company e-mail should not be used in connection with any
confidential matter that is not related to Company business. In particular, Board member’s
personal privileged communications should not take place by means of Company
communication systems.

3

WE HANDLE “INSIDE INFORMATION” APPROPRIATELY AND LAWFULLY AND
PARTICIPATE IN THE MARKETPLACE ON FAIR TERMS
Board members are prohibited from buying or selling securities while in possession of material
non-public information about the issuer of that security, whether the issuer is CME Group oranother company. This conduct is known as “insider trading.” Passing such information on tosomeone who may buy or sell securities is known as “tipping” and is also prohibited. Further
guidance on the Company's policy prohibiting insider trading and the applicable securities laws
is set forth in CME Group’s Personal Trading Policy and its Supplement that applies to Board
members, copies of which can be obtained from the Office of the Secretary and are available inDirectors Desk.
Section 16 insiders, which include Board members, are also prohibited from entering into
pledging arrangements relating to their shares of CME Group Class A common stock, including
pledging shares for margin or collateral.
WE COMPETE FAIRLY
We depend on our reputation for quality, service and integrity. The way we deal with our clients,vendors and competitors molds our reputation, builds long-term trust and ultimately determines
our success.
The Company's activities are subject to antitrust and trade regulation statutes, which govern
how we interact with our competitors, clients and vendors. Generally, the antitrust laws and theCommodity Exchange Act prohibit activities which constitute unreasonable restraint of trade,
unfair trade practices and other anti-competitive practices which restrict or lessen competition.
Some of the most serious offenses in this area involve the creation of, or attempt to create amonopoly, or agreements between competitors to increase, decrease or stabilize prices, limit
the availability of products or services, or allocate clients, territories or markets.
Failure to comply with the antitrust laws could subject the Company and individuals involved tocriminal fines and jail terms, and the Company to large civil penalties and treble damages.
Board members should consult the General Counsel regarding any questions or concerns aboutthe antitrust laws and how they may apply.
WE DO NOT EXERT IMPROPER INFLUENCE
In dealing with our clients, vendors, public officials, business partners and others, we firmly
adhere to ethical business practices. We will not seek to influence others, either directly orindirectly, by providing something of value in order to improperly influence their decision-making.
What can be considered an improper payment is not limited to a cash bribe and may include
discounts, services, gifts, employment or consulting arrangements, charitable or politicalcontributions, travel, and excessive entertainment. Improper conduct that we cannot do directly,
cannot be engaged in indirectly by us through a third party such as a business consultant.
Board members may not engage in any activity on behalf of the Company that is a violation ofapplicable anti-bribery laws, including the U.S. Foreign Corrupt Practices Act or the U.K. Bribery
Act. If you have any questions about the scope of this prohibition, please contact the GeneralCounsel or the Managing Director, Chief Enterprise Risk Management and Compliance Officer.

4

GIFTS AND ENTERTAINMENT WILL NOT BE PROVIDED OR RECEIVED FOR AN
IMPROPER PURPOSE
The purpose of business entertainment and gifts in a commercial setting is to create goodwill
and sound working relationships. Therefore, Board members and members of their immediatefamilies may accept unsolicited business courtesies and gifts that are reasonable andcustomary. Board members and members of their immediate families, however, may not accept
gifts from persons or entities where the Board member knows that any such gift is being madein order to influence the Board member’s actions as a member of the Board, or where such gift
could create the appearance of such influence. For these purposes, a gift shall include
compensation or other award for services where such compensation or award isdisproportionate to the services.
Board members may provide gifts consisting of Company promotional branded items with anominal value which may be obtained through the Global Brand Marketing Department. No
other gifts may be provided in connection with Company business unless otherwise approvedby the Chairman and Chief Executive Officer or the Managing Director, Chief Enterprise Risk
Management and Compliance Officer.
Board members may provide entertainment to the Company’s clients, members, strategic
partners and other business partners, provided the entertainment is considered reasonable andappropriate based upon the recipient’s position and circumstances and to the occasion and isprovided for a proper business purpose and not for the purpose of influencing the recipient toact improperly in relation to any relevant function. Heightened caution should be exercised whenproviding gifts or entertainment to an individual that may be considered a foreign official, suchas an officer of a state owned institution. To the extent practicable, such entertainment should
be coordinated with a Company employee. CME Group sponsored events (meaning more than10 participants) must be coordinated through the Global Brand Marketing and Communications
Division.
WE PARTICIPATE IN PUBLIC MATTERS IN AN APPROPRIATE MANNER
Our Board members should feel free to participate in public matters and political processes
according to their individual beliefs and citizenship rights. Where Board members participate asindividuals in public matters or the political process, they must be mindful that such activity isdone in their individual capacity as private citizens and not on behalf of the Company, and theymust make this clear to all involved. Any such participation must be made on the Board
member’s own time and at his or her own expense. Board members may not use Company
funds, facilities or assets for political purposes or contributions.
The Company often takes a position on issues of public policy that could impact our business.
We also engage in efforts to affect legislation or government policy. However, regulations onsuch activities in this area are complicated and vary around the globe. Therefore, only certainindividuals within the Company may engage in lobbying efforts on the Company’s behalf. Board
members who are not authorized by the Company may not contact a government official in anattempt to influence legislation or government policy on behalf of the Company unless such
efforts have been approved by the General Counsel.

5

WE REPORT INFORMATION AND COOPERATE WITH REQUESTS RELATING TO
INVESTIGATIONS, INQUIRIES AND COMPLAINTS
We maintain a cooperative, candid and proactive relationship with governmental, regulatory andadministrative authorities. The Legal Department, Market Regulation and Compliancesupervises contacts with such agencies and is responsible for coordinating any such interaction.
Board members who are contacted directly in connection with an inquiry or investigation
seeking a response or information from the Company should contact the General Counsel or
the Managing Director, Chief Enterprise Risk Management and Compliance Officer.
RETALIATION WILL NOT BE TOLERATEDBoard members should promote ethical behavior and encourage an environment in which theCompany encourages employees to talk to supervisors, managers or other appropriate
personnel about illegal or unethical behavior. The Company has established avenues ofcommunication to enable employees or others to report suspected misconduct, including theCME Group’s Compliance & Ethics Helpline (1.877.338.4545 and www.ethicspoint.com).
No one will be subject to retaliation for raising suspected misconduct based on reasonable
belief.
Board members should communicate any suspected violations of this Code promptly to theChairman and Chief Executive Officer, the Chair of the Nominating and Governance Committeeor the Lead Director who shall then inform the General Counsel and/or the Managing Director,
Chief Enterprise Risk Management and Compliance Officer.
THE BOARD TAKES VIOLATIONS OF THIS CODE SERIOUSLYThe Nominating and Governance Committee of the Board shall determine appropriate actions tobe taken in the event of violations of this Code of Ethics. Such actions shall be reasonably
designed to deter wrongdoing and to promote accountability for adherence to the Code. In
determining what action is appropriate in a particular case, the Nominating and GovernanceCommittee shall take into account all relevant information, including the nature and severity ofthe violation, whether the violation appears to have been intentional or inadvertent, and whether
the individual in question had been advised prior to the violation as to the proper course ofaction.
WAIVERS OF THIS CODE WILL BE GRANTED ONLY ON A LIMITED BASIS
The Company will waive application of the policies set forth in this Code only wherecircumstances warrant granting a waiver. Waivers of the Code for Board members may bemade only by the Nominating and Governance Committee of the Board and will be promptly
disclosed as required by law or regulation.
RELATIONSHIP TO OTHER CME GROUP POLICIES, PROCEDURES AND GUIDELINES
The responsibilities described in this Code are in addition to and not instead of, anyresponsibilities described in any other Company policy, procedures or guidelines that apply toyou.

6IF REQUIRED BY REGULATION, THE BOARD WILL CONSULT WITH THE CHIEFCOMPLIANCE OFFICER FOR THE APPLICABLE TRADE REPOSITORY OR SWAP DATAREPOSITORY FOR MATTERS RELATING TO SUCH BUSINESS
To the extent matters relating to the responsibilities described in this Code pertain to CME’strade repository or swap data repository including, but not limited to, any suspected violations ofthe Code and/or any waivers of the Code, the chief compliance officer for the applicable traderepository or swap data repository must be consulted, if required by regulation. Questions
regarding your obligations may be sent to Corporate Compliance.
BOARD MEMBERS WILL DISCLOSE POTENTIAL CONFLICTS OF A CHIEF COMPLIANCE
OFFICER OF A TRADE REPOSITORY OR SWAP DATA REPOSITORY
Board members must disclose any potential conflict situation of which he or she has actual
knowledge involving a chief compliance officer for the applicable trade repository or swap datarepository that are relevant to the ability of such officer to satisfy their obligations to the businessthey serve. Such conflicts shall be disclosed to the Market Regulation Oversight Committee.
Approved by Nominating and Governance Committee: August 1, 2023
Approved by Board of Directors: November 8, 2023

7