WHERE FUTURES ARE MADE.

CODE OFCONDUCT
Leading with Conviction and Integrity
JULY 2024

2024 CME GROUP CODE OF CONDUCT

1

Table of Contents
A Letter From Our Chairman & Chief Executive Officer:

3

1.

We Follow Our Code of Conduct

4

2.

We Protect Our Company and its Assets

12

3.

We Conduct Our Business with Integrity and Do What is Right

15

4. We Respect Our Commitments as an Employer of Choice

20

5.

22

We Value Being a Good Corporate Citizen

6. We Follow All Applicable Regulatory Requirements

24

2024 CME GROUP CODE OF CONDUCT2

A LETTER FROM OUR CHAIRMAN & CHIEF EXECUTIVE OFFICER:
At CME Group, leading with conviction and integrity has always been core to our
success. As we continue to develop our business and strengthen our corporate culture, it
is more important than ever that we empower our people to make good decisions witha sense of accountability. This means acting lawfully, honestly, ethically, and in the bestinterests of the company and our clients, while also creating an environment of respect
and inclusion among our colleagues. It also means conducting our business fairly, withthe highest professional standards and in strict adherence to local legal and regulatory
obligations in all of the countries where we operate.
Our Code of Conduct provides guidance on how we should all conduct ourselves asrepresentatives of CME Group. By using this roadmap to navigate difficult decisions andseeking guidance as necessary, you will do what is right for our clients, our shareholders
and each other. We do not expect you to be an expert in all the laws, rules andregulations relevant to our business. What we do expect is that you are able torecognize situations that require consultation with others to determine the appropriate
course of action. This is especially important in today’s ever-evolving environment. We
are more likely to make better decisions if we slow down and seek advice.
Please read the Code carefully and use it as a reference to steer your day-to-day
decisions and actions. It provides useful guidance for the management of criticalcompliance areas such as confidentiality and privacy; conflicts of interest; information
security and physical security; improper payments, and authority to act for thecompany. Think about how the Code applies to your role. Discuss what it means withyour manager and colleagues, reviewing it and its related policies often. Compliancewith the Code and our regulatory obligations is everyone’s responsibility. If you becomeaware of any deviations from these standards or the expectations set forth in the Code,or if you have questions about how the Code applies to a situation, you must promptly
raise them using any of the available reporting channels, including our Compliance &Ethics Helpline. No concern or question is too small to raise.

“

Thank you for supporting our values and advancing our reputation.

Compliance with the Code and our regulatory
obligations is everyone’s responsibility.

Sincerely,

Terrence A. Duffy
Chairman and Chief Executive Officer

2024 CME GROUP CODE OF CONDUCT

3

“

1
WE FOLLOW OUR
CODE OF CONDUCT2024 CME GROUP CODE OF CONDUCT

4

We Follow Our Code of Conduct
Our Code of Conduct builds on our business principle of leading with conviction andintegrity by setting the tone for a culture of compliance, ethical conduct andaccountability, and providing greater detail about the behavior we expect from ourcolleagues. It applies to all companies in the CME Group organization, including thoseentities where CME Group is not the sole owner but has control of the entity(collectively, “CME Group” or the “company”). All CME Group employees, internal
consultants and temporary personnel resources (referred to as “colleagues”) must
follow this Code of Conduct. Other third parties who have access to CME Groupsystems are required to conduct themselves in accordance with the provisions of theCode when doing work for CME Group and must comply with all applicable
information security policies and data protection policies when using CME Groupdevices and systems.
In addition, all people or entities representing the company, including external
consultants, agents and business partners, are expected to adhere to our principles as
set forth in our Guide to Conducting Business for Third Parties of CME Group.

IN PRACTICE, THE CODE REQUIRES YOU TO:

FOSTER A CULTURE OF INTEGRITY• Act with honesty, thoughtfulness andintegrity to protect CME Group’s
reputation. You will be evaluated not
only on what you do but also on how
you do it.
• Avoid conflicts of interest between
work and personal interests andfollow all required disclosure andapproval obligations as described in
the Conflicts of Interest Policy.

• Protect our data and do not enter or
upload it into applications or toolsthat have not been approved for
CME Group business use, such as
personal email or public artificial
intelligence tools.
• Never transfer, such as through email or
uploading, our data in such a way thatit leaves the CME Group environment.
• Be careful in your communications.

• Promptly raise any potential
violations of the Code and its related
policies and seek guidance asnecessary as described in the Speak
Up and Escalation Policy.

• Follow the limitations, documentation
and approval requirements describedin the Travel, Entertainment andExpense Reimbursement Policy.

• Be vigilant in safeguarding CME
Group’s systems; use them only forproper purposes and immediately
report any suspicious activity(including potential cyber activity) to
the Cyber Defense Monitoring teamas described in the Corporate
Information Security Policy.

• Complete your assigned compliancetasks in a timely manner.

• Sustain a culture where ethicalconduct is recognized, valued andexemplified by everyone.

• Ask questions and seek guidanceand support if you are unsure of how
to proceed.

VALUE OUR COLLEAGUES AND CREATE AN ENVIRONMENT OF INCLUSION• Respect differences and welcome
diversity.
• Prevent harassment and bullying – noviolence or intimidation of any kind.
• Promote safety and health. Escalate
any physical safety concerns to the
Global Security Operations Center(+ 1 312 930 3111).

• Protect privacy rights as described in
the Confidentiality and Data
Protection Policy.
• Respect the human rights anddignity of others and comply withapplicable regulations.

2024 CME GROUP CODE OF CONDUCT

5

What We Stand For

What We Prohibit

Integrity

Dishonesty

 e believe in conducting business fairly, with the highest professional standards and in strictWadherence to local legal and regulatory obligations.

We don’t mislead our shareholders, clients, regulators, vendors or each other. We don’t falsify or
misrepresent information in or about our books and records, or engage in unfair competition.

Respect
We are strongly committed to fostering a work environment where everyone feels valued,
respected, understood and supported.
Speaking Up and Escalating Issues
A key element of our Compliance and Ethics Program is being able to address any instances of
misconduct or violation of law. If you have a concern about fraudulent, unethical or illegal
behavior of any kind, which is based on a reasonable belief, CME Group wants you to speak up.
We take all concerns raised seriously, including allegations of retaliation.
Demonstrating Ethical Leadership e are all ambassadors of our Code and conduct ourselves in accordance with the highestW
standards of professional behavior. Through our actions we can inspire and motivate ourcolleagues in furtherance of the success of our company.
Taking Responsibility s stewards of CME Group, we are responsible for meeting our commitments, in how we treat ourAcolleagues and how we protect our information, systems and assets.

Illegal Activity
We don’t violate the law and don’t support others in violating the law either. This includes violatinglaws relating to antitrust, bribery, corruption, human rights, privacy, insider trading, money laundering,market abuse, global trade/sanctions, employment and other laws that apply to our business.
Retaliation
CME Group has zero tolerance for retaliation against anyone who speaks up based on areasonable belief. Retaliation means any kind of unfair treatment, whether subtle or overt. There
are serious consequences for retaliation, up to and including termination.
Conflicts of Interest
We avoid situations that interfere or appear to interfere with our ability to act in the best interestsof CME Group.
Circumventing Established Controls
We do not disable or circumvent controls and processes designed to protect our company andour systems and assets. We comply with requirements regarding recordkeeping. We do not use
personal devices or unapproved software or tools to conduct CME Group business.
Misuse and Theft of Assets
We don’t misuse or misappropriate CME Group assets or information or those of our clients,
colleagues or other third parties or put the security of our information or assets in jeopardy.

2024 CME GROUP CODE OF CONDUCT6PROVIDE EFFECTIVE CLIENT SERVICE AND
COMPETE FAIRLY• Conduct sales and marketing activities with integrity andin compliance with guidance provided by legal andcompliance and local law.
• Respect the gift and entertainment limitations and related
disclosures and approvals as described in the Gifts andEntertainment Policy.
• Avoid any behavior that could be interpreted as a bribeor an attempt to improperly influence anyone as
described in the Anti-Financial Crime Policy and takeadditional precautions when dealing with government
officials.
• Protect the confidentiality of client information as
described in the Confidentiality and Data Protection Policy.

ACHIEVE REGULATORY EXCELLENCE• Be aware of the specific regulatory requirements of thebusiness unit, country or region where you work and that
apply to your business activities; immediately raise any
issues of potential noncompliance to Corporate
Compliance.
• Communicate accurately with our regulators, clients andshareholders as described in the External Communications
Policy.
• Maintain business records in accordance with creation
and retention policies as described in the Records andInformation Management Policy.
• Avoid market abuse, prevent insider trading and do nottrade any futures contracts (regardless of where listed ortraded). Do not trade any other financial instrument when
you have access to inside information as more broadly
defined in the Personal Trading Policy.
• Comply with applicable economic and trade sanctions
and import and export requirements and be mindful of
potential money laundering risks as described in theAnti-Financial Crime Policy.

MAKE GOOD DECISIONS
Not every issue you encounter at CME Groupwill have a clear path to resolution. In these
difficult situations, use this Code as a guideand take advantage of the resources available
to you. When you are unsure of what to do,reach out to Corporate Compliance for help
and consider the following questions:• Obligations under the law — Could it be in
violation of local or global laws or
regulations?
• CME Group business principles andstandards — Could it violate our businessprinciple of leading with conviction andintegrity, this Code or its related policies?
• Obligations to others — Could it breach an
obligation to a client, a regulator or otherbusiness partner (for example, contractual
undertakings, regulatory core principles)?
• Do no harm — Could it cause harm to any
person, CME Group’s reputation or brand,
our financial performance, the integrity of
our markets, our relationships with ourregulators or the trust of our clients? Wouldothers question your decision if it was
publicly disclosed?
• Comfort with the decision — Does theoutcome of your decision make you
uncomfortable or make you feel uneasy?
• Compliance with specific policies andregulatory provisions — This Code of
Conduct is supplemented by the moredetailed policies referenced herein and certain
colleagues are also subject to additional
policies and regulatory requirements. As a
CME Group colleague, you must comply withall of the obligations which apply to you
based on your business and function in theorganization. Could it violate any of theserequirements or obligations?

If you answered “No” to all these questions,chances are you are probably okay toproceed. If you hesitated in answering “No” toany of these questions or you have any
doubts, then it’s best to get a second opinion
and seek guidance from any of the resources
available to you. Business decisions can becomplicated and complex. The right courseof action may not be obvious. Asking for help
is always the safest course of action,
especially for colleagues who support any of
our regulated businesses.
This Code is not a contract guaranteeing youremployment or relationship with the company
or entitling you to any special privileges, rights
or benefits. If you violate this Code or any other
CME Group policy or procedure, you may besubject to a full range of disciplinary sanctions,
up to and including termination of youremployment or relationship with CME Group.
CME Group does not expect to grant waiversof the provisions of the Code. The Board of
Directors of CME Group or its Nominating andGovernance Committee will consider andresolve any question about a potential waiverthat arises for an executive officer of thecompany (the Management Team and theChief Accounting Officer). Disclosure of awaiver for any executive officer, if any, will bemade as mandated by applicable law andregulation, listing standards and the regulationsof the Securities and Exchange Commission.
If a question about a potential waiver arises
for any other colleague, the Global Chief
Compliance Officer or the General Counsel
will consider and resolve that question.
You should never bypass an established CME
Group policy, process or control without an
authorized, documented exception. The
company has an established process toconsider exception requests using Archer.
Exceptions will only be granted after
consideration by the appropriate stakeholders
on the impact to the company’s risk profileand consideration of the mitigating controls.
You will be held personally responsible forany improper or illegal acts you commit
during your employment with or service tothe company. In some instances, you can also
be held responsible for the action (orinaction) of others if you knew or should have
known about their misconduct and failed toreport it to the organization.
Violations of the Code or its related policies
may also be reported to regulators orappropriate law enforcement authorities,
which could result in external investigations.
The penalties for regulatory and criminal
violations can include fines, disqualificationfrom serving in certain capacities, permanent
bar from employment in the financial services
industry and imprisonment.
RESOURCES AVAILABLE TO YOU• The Helpline• Your manager• Human Resources (“HR”)• The Legal Department• The Global Chief Compliance Officer
or compliance team members,
including the compliance officer foryour office or business unit
• Any member of the Global Corporate
Compliance and Ethics Team• The Global Corporate Complianceand Ethics page on OpenExchange

2024 CME GROUP CODE OF CONDUCT

7

We Expect More of Our Leaders,
Including Speaking Up
While all colleagues are responsible for our reputation, leaders have a heightened
responsibility to serve both as a role model and resource for colleagues and tosafeguard and promote a culture of integrity and honesty. We expect our leaders tomodel respectful behavior, act when they see misconduct and ensure there is no
retaliation against anyone who speaks up based on a reasonable belief that
misconduct has occurred. By modeling consistent honest, ethical behaviors to ourcolleagues, our leaders promote, uphold and strengthen a culture of integrity.
Managers must ensure colleagues feel comfortable asking for help and raisingconcerns and must not discourage anyone from speaking up.
Managers are responsible for acting quickly to escalate any violations of the CMEGroup Code, policy or the law. This means that if a colleague reports a suspectedviolation or raises a question or concern, managers must respond by taking
appropriate action, seeking help when needed and escalating the matter to theorganization in accordance with the Speak Up and Escalation Policy.
Managers are also responsible for ensuring that their direct reports timely complete allassigned compliance tasks and training courses.

Our goal is to have an environment where everyone is encouraged to speak up andreport concerns when they have a reasonable belief that misconduct has occurred
without fear of retaliation.
LEADERS CAN FULFILL THESE RESPONSIBILITIES BY:• Being available and letting colleagues
know they can come to you withquestions or concerns.
• Responding to colleagues who raise
concerns in a way that makes themfeel secure and at ease sharing theirissues.
• Demonstrating the highest ethicalstandards and quality in your work
every day and expecting the samefrom the people who report to you.
• Making fair and objective businessbased decisions.
• Being aware that your actions may
influence your colleagues to act in a
way that is contrary to our ethicalstandards — even if that is not yourintent.

• Ensuring colleagues are aware of, andproperly trained on, the relevant laws,
regulations and CME Group policies
that govern their business activities.
• Considering compliance activities
when evaluating and rewarding
employees, such as timely completionof required training and annual policy
acknowledgments.
• Recognizing and rewarding ethicalbehavior.
• Appropriately reporting potential
violations of the Code and its related
policies. (See the Speak Up andEscalation Policy to gain anunderstanding of your responsibility toescalate issues reported to you up
through the organization.)• Understanding and communicatingthat business results are never more
important than ethical conduct andcompliance with this Code and ourpolicies.

2024 CME GROUP CODE OF CONDUCT

8Raising Concerns
Speaking up allows CME Group to identify, prevent and correct
potential issues or harm to CME Group, our colleagues,
customers, suppliers, shareholders and other stakeholders.
If you see something, you must say something — silence is not an
option knowing CME Group does not tolerate retaliation.
SPEAK UP ABOUT DISRESPECTFUL, INAPPROPRIATE, FRAUDULENT, UNETHICALOR ILLEGAL BEHAVIOR
Violations of this Code erode the trust we have built with our employees, clients,
regulators, shareholders and other stakeholders. Additionally, failure to follow the Codecan cause risk to your colleagues and our business. Even companies with the highest
ethical standards occasionally have issues. When we do, we want them reported sothey can be addressed. In accordance with our Speak Up and Escalation Policy, youmust promptly raise any concerns or questions about potential violations of the Code,its related policies or applicable laws or regulations using any of the numerous
resources available to you.
Among the resources to make a report or seek guidance is our independently operated,
Compliance & Ethics Helpline available 24/7 from any global location.
If you are uncomfortable making a report, you may do so anonymously, if permitted byapplicable law, through the Helpline. Additional information on the operation of the
Helpline is available here. If you remain anonymous, please provide sufficient detailabout your concerns so that we may conduct a comprehensive review.
You must cooperate in any company review related to compliance or ethical concerns,
violations of the Code or any company policies. Do not conduct your own investigation.
Failure to report concerns may result in disciplinary action.

COMPLIANCE AND ETHICS HELPLINE AVAILABLE TO YOU INCLUDE:

www.ethicspoint.com

CME GROUP TAKES ALL REPORTS OF ALLEGEDMISCONDUCT SERIOUSLYCME GROUP HAS ZERO TOLERANCE FORRETALIATION

We review all issues raised to our attention. The
company takes all reports seriously and will never draw
assumptions without reviewing a matter. The way wereview a matter depends on its nature and severity. This
may involve discussions with relevant colleagues, HR,and may require a formal investigation. Regardless of
how a concern is raised, we always seek to ensure it ishandled by the most appropriate people in theorganization. We ensure a fair process is followed in thecase of an investigation, respecting the principles ofconfidentiality to the greatest extent possible andpresumption of innocence. Information only will beshared with those persons who have a legitimate reason
to know. Any investigation will comply with applicablelegislation, especially regarding due process. There may,
however, be times when we have a legal duty to inform
third parties, including regulators, and provide
information about reported issues.

Anyone who seeks advice, raises a concern, reports
suspected misconduct based on a reasonable belief that
misconduct has occurred or participates in an
investigation is doing the right thing. Reporting based ona reasonable belief does not mean that you must be
right when you raise a concern, only that you believe theinformation you are providing is accurate. Anyone who
engages in retaliatory action will face disciplinary action,
which may include termination, and may face criminalor civil penalties.

The review and resolution of each case is unique. Basedon the facts, management may need to enhance ourcontrol environment or take disciplinary action (up to
and including dismissal) against anyone found to havebroken the law or violated the Code or other related
policies or guidelines.

If you suspect that you or someone you know has been
the subject of retaliation, immediately contact the
Global Chief Compliance Officer, HR, the Helpline or
your local compliance officer, if applicable.

While we will not discuss case specifics and/or disciplinary
action with anyone other than the individual involved, tothe extent permitted, and where contact information isprovided, we will also provide an update to theindividual who raised the concern.

Retaliation is not just contrary to our core values — italso undermines an environment of openness and trust.
Any threat of retaliation can prevent concerns frombeing raised. Retaliation can take many forms and issometimes subtle. It means any kind of unfair treatment,
whether subtle or overt. It violates CME Group policy,
and in many instances, it is also illegal and can result in
dismissal.

We also comply with all local requirements relating to
the protection of employees raising concerns, such as
the United Kingdom Public Interest Disclosure Act 1998.

Although we prefer that you raise concerns internally,
this Code is not intended to limit any rights you may
have in connection with reporting any legal, compliance,
ethical or other issues to any regulatory, administrativeor other governmental or self-regulatory bodies.
All allegations are overseen by the Global Corporate
Compliance and Ethics Team and the Board.

From the US and Canada 877.338.4545
From the United Kingdom 0808.234.1701
From India 000.800.100.1703
For other countries, check OpenExchange for local numbers
2024 CME GROUP CODE OF CONDUCT

9

Speak Up

Who Can I Talk To?

CONCERNED ABOUT MISCONDUCT?
BELOW ARE EXAMPLES OF ITEMS TO REPORTNO CONCERN IS TOO SMALL TO RAISEYOUR MANAGER IS A GOOD
PLACE TO STARTI am worried a giftprovided to a client
by a colleague is
too expensive

I suspect expenses
are not being
properly recorded

I suspect acolleague isinappropriately
using GenAI tools
to do their job
YOU CAN ALSO RAISE AN ISSUE OR SEEKADVICE FROM:• Your manager’s supervisor or any other member ofmanagement, including the head of your department
or division• Corporate Compliance

I suspect someone
is misusing ourbrand and trade
name

I feel I’ve
experienced
discrimination orharassment

I suspect acolleague ismisusing clientdata• Any member of the Global Corporate Compliance &Ethics Team, including the Global Chief Compliance
Officer• Your local or business compliance officer, if any• The Human Resources Division, including Employee
Relations or your Human Resource Division Partner

If you see something that raises an ethical or compliancequestion or concern, you have an obligation to speak up. Do
not conduct your own investigation.
No concern is too small to raise. Misconduct affects us all.
We understand it is not always easy to raise concerns about
possible misconduct, which is why we provide multiple
reporting channels, including the CME Group Helpline. If you
choose to remain anonymous, as permitted by applicablelaw, please provide sufficient detail of your concerns andrevisit the CME Group Compliance & Ethics Helpline for any
follow-up questions we may have posted so that we may
conduct a thorough investigation. You may raise concerns
based on reasonable grounds for concern without fear of
retaliation, even if your concerns or allegations of potential
misconduct turn out to be mistaken.
Allegation: All allegations are reviewed. If an investigation isneeded, an authorized investigator is assigned.
Investigate: The authorized investigator conducts a factfinding review and may review documents and interview
employees and others.
Recommendations: Findings and recommendations are
made and appropriate actions are implemented.
WHAT HAPPENS TO MY REPORT?

I think a colleague
may have a conflictof interest

I suspect that acolleague is trading
based on inside
information

I suspect bribes or
kickbacks are being
paid

YOU CAN ALSO USE THE CME GROUPCOMPLIANCE & ETHICS HELPLINE• Scan the QR code for the mobile version• Phone numbers available on
OpenExchange

We take all reports seriously. We do not assume a person tobe “guilty” based on a report without further investigating
the matter. All allegations are reviewed and investigated andreported to the Global Corporate Compliance & Ethics Teamand the appropriate Committee of the Board.
Anyone who seeks advice, raises a concern, reports
suspected misconduct based on a reasonable belief orparticipates in an investigation in good faith is doing theright thing. CME Group will not tolerate retaliation.

2024 CME GROUP CODE OF CONDUCT10Disclosure Obligations Relating to Certain
Civil and Criminal Matters

Investigations andRegulatory Inquiries
We maintain a cooperative, candid and proactive relationship with government,
regulatory and administrative authorities.
We have established groups, such as the Legal Department, Government Relations,Market Regulation and compliance functions for our regulated businesses, as well asother members of senior management who are responsible for our interactions withthese authorities. Unless you are a member of these groups, if you are contacted directly
by any of these authorities, you should contact the General Counsel or the Global Chief
Compliance Officer for assistance.

You are required to notify Legal and Compliance by submitting a Civil/Criminal
disclosure in the Compliance Reporting System if you:

Are arrested andcharged or indicted
in a criminal matter(excluding minor
traffic violations,but including
driving under the
influence;

Become the subjectof or target of any
regulatory inquiry,
investigation orproceeding;

Become involved inany civil litigationor arbitration(excluding personal
claims or family law
matters that do not
relate to CMEGroup’s business orthe industry ingeneral); or

Receive a subpoena,
inquiry or requestfrom agovernmental,
regulatory or
administrative
agency, or aclaimant, plaintiff oroutside attorneyrequesting a
response orinformation fromCME Group.

During litigation, internal investigations or governmental, regulatory or administrativeinquiries or examinations involving CME Group, we may ask you to provide information(including documents, statements or testimony) or to meet with members of the Legal
Department, our outside counsel, auditors or other authorities. You are expected tocooperate fully and provide truthful and complete information in connection with any
such request.
We may provide information about you to these authorities or in response tosubpoenas or civil discovery requests.
We must never alter or destroy documents requested for a government investigationor legal proceeding, or documents that might be relevant to an expected litigation,
investigation or proceeding. We comply with all legal holds and other obligations tomaintain information. CME Group has adopted procedures and requirements toensure the preservation of information in connection with, and in response to, any
threatened, imminent or pending lawsuit, claim, government or regulatory
investigation, or the receipt or anticipation of the receipt of any third-party subpoena
or any other request by an appropriate person or entity. See the Records andInformation Management Policy.
Nothing in the Code of Conduct or any other CME Group Policy prohibits you from
communicating directly with any governmental authority or making a report in goodfaith and with a reasonable belief of any violations of law or regulation to agovernmental authority or from filing, testifying or participating in a legal proceeding
relating to such violations, including making other disclosures protected or requiredby any whistleblower law or regulation to the Securities and Exchange Commission,
the Commodity Futures Trading Commission, the Department of Labor, or any otherappropriate government authority.
NOTIFY LEGAL DEPARTMENT
If you receive a subpoena, inquiry or request from a governmental, regulatory or
administrative agency, or a claimant, plaintiff or outside attorney requesting a response
or information from CME Group, contact a litigation attorney in the Legal Department.
2024 CME GROUP CODE OF CONDUCT112WE PROTECT OUR COMPANY
AND ITS ASSETS

2024 CME GROUP CODE OF CONDUCT

12Information Security
We are all expected to use CME Group’s assets (e.g., computerequipment, mobile devices, communications platforms, software, etc.)
appropriately during our work for the company and in accordancewith the Corporate Information Security Policy. What we expect of you:
• Exercise good judgment to maintain and protect the security of data,
information and devices entrusted to your care.
• Always secure your passwords; use a CME Group approved password
manager (e.g., LastPass) – never share your password.
• Classify your information (Public, CME Group Internal, CME Group
Confidential, CME Group Highly Sensitive), properly label yourdocuments and apply the required protective measures based on
their sensitivity.
• Only use CME Group approved software and only for its approved
purpose.
• Do not use an external/personal account to conduct CME Groupbusiness or log in to an external/personal account (e.g., Gmail,
Hotmail) on CME Group assets.
• Do not copy, upload or place any CME Group information, including
client information, personal data or source code, into generative AI
technology or tools that are not CME Group approved applications.
• Do not install software or modify configurations that compromise ourtechnology’s security.
• Think twice before opening unexpected or unfamiliar emails, clicking
on a link, opening an attachment in an email or responding to out of
the ordinary information requests. Send any suspected phishingemail or social engineering matter to *Virus Watch.
Certain locations have higher risks relating to information security or
physical security. The company has adopted additional procedures forwhen you are traveling to or working in such locations as described in
the Corporate Information Security Policy.

CONFIDENTIALITY, DATA PRIVACY AND ACCEPTABLE USE
In our business, we often receive or have access to confidential
information, both about CME Group and about others, including
our clients. We take confidentiality seriously. As set forth in the
Confidentiality and Data Protection Policy, we follow globally
recognized privacy principles and have implemented reasonable
and appropriate practices in our collection, use and sharing ofconfidential and personal information about individuals, including
our clients.
You have a responsibility to protect the confidentiality, integrity andavailability of information generated, accessed, modified,transmitted, stored or used by the company, irrespective of themedium on which the data resides and regardless of format (suchas electronic, hard copy or other physical form). This is especially
important given our role in the global economy. We collect, process
and store only relevant, accurate information needed or appropriate

for business purposes, and do so only by lawful and fair means. We
limit access to such information and comply with all applicable laws
regarding the maintenance and disclosure of personal data.
We do not improperly use confidential information and have
implemented controls designed to prevent inappropriate disclosureof confidential information to third parties.
Even with our colleagues across the company, we shareconfidential information only with those who have a legitimate
need to know such information for internal purposes or to provide
services to our clients. Any compromise or inappropriate use ofconfidential information will have a negative impact on ourbusiness and reputation. Regulatory Data, as defined in the
Confidentiality and Data Protection Policy, is subject to additionaluse and access restrictions.

RIGHT TO MONITORCME Group has implemented several policies and proceduresconsistent with applicable law to protect the confidentiality, integrity
and availability of CME Group’s information resources (as defined in
the Corporate Information Security Policy). To support these efforts,
CME Group reserves the right to take possession, access, review,monitor, intercept or conduct surveillance on any content ormaterials located on any CME Group information resource or CME
Group facility, including personal possessions (e.g., a backpack andits contents or a personal mobile device) that may contain CMEGroup information, in accordance with applicable law.
The CME Group information assets (as defined in the Corporate
Information Security Policy) you use or to which you have accessare the property of CME Group and are provided for official CME
Group business use. CME Group information resources should only
be used for CME Group business-related purposes. Personal use
of a CME Group information resource is prohibited in Israel andshould be limited to incidental use in all other locations.
Any communication conducted on our assets and systems is notyour personal or private property, and CME Group reserves theright to view that communication at any time.
Use of CME Group’s information resources for conducting any
outside business activities is strictly prohibited.

There may be times when authorized CME Group personnel accessor monitor workspaces – including information stored on CME Group
information resources and usage of your CME Group computer – forthe safety of others or when otherwise deemed appropriate in the
judgment of management.
For more information, please see your local Employee Handbook
and business-specific policies relating to privacy or dataprotection, including the Colleague Privacy Notice.
CME Group may record certain telephone conversations, including
phone lines in the Global Command Center, in accordance withapplicable law. Consent to such recording and monitoring ispresumed by the use of the recorded phone lines.
In accordance with applicable law, CME Group may provide
information obtained during its monitoring activities to designated
CME Group officials, law enforcement officials, regulators or otherpersons when appropriate.
All security and privacy incidents must be reported to the Cyber
Defense Monitoring team as soon as possible. Security andprivacy incidents include any possible or actual violations of ourprivacy and security practices, such as inadvertently emailing
confidential information to an unauthorized person, losing a pieceof confidential information or leaving a laptop unlocked andunattended in public.
2024 CME GROUP CODE OF CONDUCT

13

FINANCIAL REPORTING AND CONTROLSTRAVEL AND EXPENSES

AUTHORITY TO ACT ON BEHALF OF CME GROUP

Our investors, creditors and regulators, as well as others
have an interest in the accuracy and reliability of our
financial and accounting information. We are responsible
for ensuring all CME Group books, records and financial
statements are accurate and truthful, and fairly reflect thecompany’s transactions and dispositions of our assets.

Expenses should be reasonable, directly related to company business andsupported by appropriate documentation

Only authorized individuals may make commitments onbehalf of CME Group. The Commitment and Signing
Authority Policy sets forth certain delegations and approvalauthorizations.

Financial activities must be recorded in compliance withall applicable laws and accounting practices. Neverintentionally delay recording transactions or events orcreate a false or misleading report. Never make apayment or establish an account on behalf of CME
Group with the understanding that any part of thepayment or account is to be used for a purpose otherthan as described by the supporting documents.
It is your responsibility to report any unrecorded funds or
assets or false or artificial entries in the books andrecords of CME Group if you become aware of them. If
you learn of or suspect accounting fraud, report it
immediately. See the Speak Up and Escalation Policy for
information on reporting issues.
Also, certain of our regulated businesses have specificcontinuous financial reporting obligations.

RECORDS AND INFORMATION MANAGEMENTElectronic and hard copy records and information
created or received during the normal course of business
are CME Group assets. This includes documents, email,spreadsheets, notebooks, reports and messaging,regardless of whether they are in electronic or hard copy.
We manage, retain and dispose of all CME Group records
and information in accordance with our Records andInformation Management Policy and the Records
Retention Schedule.
If you have any reason to believe that any of our records
or information have been compromised, you must report
it immediately through one of the available reporting
channels, which includes the Helpline.

If you travel or incur business-related expenses, you must be familiar with therequirements of the Travel, Entertainment and Expense Policy. When submitting
expenses, make sure you have included the required documentation, you have clearly
described the business reason for the expense, you have included the names andaffiliations for all those who attended and have appropriately categorized theexpense type. If you’re uncertain about whether something would be an appropriate
expense, reach out to your manager. Managers are responsible for all money spent andexpenses incurred by their direct reports and should carefully review all expenditures
before providing their approval.

INTELLECTUAL PROPERTY
Our intellectual property is among our most valuable assets, and includes copyrights,
patents, trademarks, trade secrets, source code, logos, photos/videos and otherintangible industrial and commercial property. We must protect and, whenappropriate, enforce our rights in this property. To the extent permitted by law andas agreed as a condition of employment or in connection with your engagement toprovide services to the company, CME Group has the rights to all intellectual
property created that relates to our business and/or results from us carrying out ourduties. This is true regardless of whether the intellectual property is patentable orprotectable by copyright, trade secret or trademark.
Do not make unauthorized disclosure of trade secrets or other sensitive information
belonging to CME Group, our clients, vendors or suppliers either during or after
employment or service with CME Group, including through AI usage. When sharing
company information with others, we ensure appropriate controls are in place toprotect our interests and follow the provisions of the Confidentiality and Data
Protection Policy.
We also respect all third-party intellectual property rights and other intangible
commercial rights belonging to others. We should never knowingly infringe upon thoserights. Our duty to respect such rights applies to any business activities we conduct
including the creation of any internal or external communications or marketing materials.

LEGAL AGREEMENTS

All legal agreements, except for certain form agreements thathave already received legal approval, must be reviewed andapproved by the Legal Department prior to execution inaccordance with the Commitment and Signing Authority Policy.
Keep in mind that agreeing to certain provisions even inemail, such as exclusive relationships and agreements not tocompete, can impact our business, which is why they mustbe fully vetted by a member of the Legal Department. There
are also limitations as to who may bind our legal entities
based upon the legal structure and geographic location as
described in the Commitment and Signing Authority Policy.
If you have any questions, contact a member of theTransactions and Commercial Relationships Group.

ENGAGEMENT OF SUPPLIERS AND VENDORS
When we have identified the need for a supplier, consultant
or other organization to help us achieve our goals andoperate our business, we take appropriate steps to know who
we’re working with. Our Third Party Risk Management teamtakes a risk-based approach in vetting our suppliers, vendors
and other third parties to ensure they are involved inlegitimate activities, they have the necessary resources andprocesses to meet our business needs and they have a solid
reputation. We expect our vendors and suppliers to adhere
to our principles as set forth in our Guide to Conducting
Business for Third Parties of CME Group.
Before engaging any third party, reach out to Corporate
Procurement in compliance with the Procedures for Securing
Goods, Services and Third Parties. All purchasing decisions
must be in the best interests of CME Group and not basedon any personal considerations. See the Conflicts of Interest
Policy for more information regarding personal relationships
with vendors.

2024 CME GROUP CODE OF CONDUCT

143WE CONDUCT OUR
BUSINESS WITH INTEGRITY AND
DO WHAT IS RIGHT

2024 CME GROUP CODE OF CONDUCT

15

Always make business decisions based on what isbest for CME Group and our clients andshareholders, never what is best for you personally.

Conflicts of Interest
While working at CME Group, you have an obligation to always dowhat’s best for the company and our clients. When you are in asituation in which competing loyalties could cause you to pursue a
personal benefit for you, your friends or your family at the expenseof CME Group or one of our clients, you may be faced with aconflict of interest. All CME Group business decisions must be madewith integrity and not influenced by a conflict of interest. Thismeans you are responsible for ensuring that your business decisions
are based on how those decisions will benefit CME Group, NOT on
how they might benefit you personally. At CME Group, we avoid theactivity that is a conflict of interest or implement appropriate
controls to address the conflict. When there is the potential for a
conflict of interest, we disclose such activity so that it may beevaluated and appropriately addressed.

 hile we cannot list every situation that can present a conflict, there are a few instances where conflicts
Wtypically arise within the company:
PERSONAL RELATIONSHIPSOUTSIDE ACTIVITIESLOANS• Directly or indirectly supervising aclose personal friend, family member
or someone with whom you have aromantic relationship.

• Having a second job or providing
services to another organization,
including service on a board of
directors or serving as an associate,
advisor or consultant for anotherorganization. Such activities need tobe disclosed regardless of theirrelationship to CME Group andevaluated to ensure they do notpresent a conflict with your CME
Group responsibilities or CME Group’s
regulatory obligations.

• Providing an investment or loan toanother employee or an investment inor a loan to any third party with whom
you interact as part of your role at thecompany.

• Referring company business to acompany owned or controlled by you,your family or a person with whom you
have a close personal relationship.
• Allowing a member of your family or apersonal friend to receive improper
personal benefits because of yourposition with the company.

When faced with a potential conflict of interest, ask yourself:• Having a family member or close
personal friend participate in ourmarkets when you have a role relating
directly or indirectly to such business.

• Would this activity create an incentive for me, or be perceived byothers to create an incentive for me, to benefit myself, my friends or
my family, or an associated business at the expense of CME Group?

• Having a close personal relationshipwith a regulator that may directly or
indirectly oversee the company.

• Investing in a company that does or
potentially could do business with orthat could compete with CME Group,
including strategic partners.

• Would this activity interfere with the work I do for CME Group?

• Influencing directly or indirectly any
hiring decision for a close personal
friend, family member, or someone
with whom you have a romantic
relationship, including for any intern,
contract or consulting position.

• Having a direct or indirect financial
interest in a vendor when you havedecision making authority relating totheir engagement or oversight
responsibility for their performance.

• Would this activity harm my reputation, negatively impact myability to do my job at CME Group or potentially harm CME
Group or any of our clients or the marketplace?
• Would this activity result in the use or the potential use of CME
Group information or assets or create a potential conflict in theownership of any intellectual property?
• Would this activity embarrass CME Group or me if it showed up
in a newspaper or a social media post?
If the answer is “yes,” the action you’re considering is likely tocreate a conflict of interest situation. If there is a potential of aconflict or the appearance of a conflict, you will need to disclose
the situation and obtain approval(s) from your manager andCompliance as described in the Conflicts of Interest Policy.

IP DEVELOPMENT• Engaging in activities that may create
intellectual property. These activities(e.g., software development) need tobe evaluated to ensure that they don’t
involve IP that should otherwise be theproperty of CME Group.

FINANCIAL INTERESTS• Having a private investment in an entity(including but not limited to real estate
ventures, limited and general partnerships,
start-up ventures, and privately heldcompanies) of which you actively
participate in the management and where
there are potential links to CME Group’sbusiness or the industry or involves asignificant amount of your time.

BUSINESS OPPORTUNITIES• Taking an opportunity you learned
about through your work at CME Groupfor yourself or starting a business thatcompetes with our company.

MISUSE OF CORPORATE ASSETS• Using the company’s time, contacts orresources to promote your personal
interests or the interests of a third
party.

PERSONAL INTERESTS THATCONFLICT WITH THE INTERESTS OF
A CLIENT• Client-facing individuals must also
consider whether there is the potential
for a conflict of interest that could
negatively impact a client. For example,
when a CME Group colleague has afinancial or other incentive to favor theinterest of one client or group of clientsover another. See the Conflicts ofInterest Policy for more detail.

2024 CME GROUP CODE OF CONDUCT

16Compliance with Anti-Financial Crime Laws
All colleagues are expected to act within the bounds of applicable laws, rules and regulationsof the countries where we do business as described below and in more detail in the AntiFinancial Crime Policy. The application of these laws can be complex and is very factdependent. If you encounter any of the following, review the Anti-Financial Crime Policy,
resources on OpenExchange and seek guidance from Corporate Compliance.

INTERNATIONAL TRADE AND SANCTIONSANTI-BRIBERY LAWS AND REGULATIONS

As a global company, we are subject to several trade compliance laws. We
comply with applicable trade and sanctions laws, including those thatprohibit us from dealing with certain persons, entities or countries, or that
restrict the ability to import and export goods or technical data. If you havequestions about whether a person, entity or country is subject to sanctions,please contact Corporate Compliance. If you are involved in sending
software, equipment or other technical data from one country to another,seek out guidance on the requirements from Corporate Compliance.

CME Group earns its business based on merit and will notoffer, provide or receive improper or corrupt payments. Thismeans we comply with anticorruption laws including the U.S.
Foreign Corrupt Practices Act and the UK Bribery Act without
exception, regardless of local business culture or practice.

ANTI-BOYCOTTThe U.S. anti-boycott laws prohibit CME Group from participating in foreign
boycotts the U.S. does not support (such as the Arab League Boycott ofIsrael) and require us to report certain information relating to boycott
requests. Please contact Corporate Compliance immediately if you are awareof new relationships with a country that may support boycotts or any request
to comply with an international boycott.

In dealing with our clients, vendors, public officials, business
partners and others, we will not seek to improperly influence
their decision making, either directly or indirectly, by providing
anything of value to them. This includes payments which are
made to speed up the performance of a routine action. Whatcan be considered an improper payment isn’t limited to acash bribe and may include discounts, services, gifts,
charitable or political contributions, employment or consulting
engagements, travel, and excessive meals or entertainment.
If a client, vendor or other individual tries to imply that a bribe
is just the way business is done in his or her country, theanswer is simple: We don’t do it.

We also do not engage in transactions with third parties who
might directly or indirectly pass on any inappropriate or illegal
payments or other inappropriate benefits in connection withour business. We will only engage reputable business agentsand other third parties who share the same values and only
after completing an appropriate level of due diligence.
Contributions to charities must never be a condition for — ormade to influence — any business or governmental action ordecision relating to CME Group business. To ensurecompliance, all charitable and civic donations made withCME Group funds are made by representatives of theCommunity Relations Department in accordance with thecharitable mission of CME Group and in accordance withCME Group’s budget policy. You may not submit charitable
expenses through your own expense report.
You should never promise or infer that charitable funds will be
used to gain business and should not commit to any support
until it has been approved by Community Relations.

2024 CME GROUP CODE OF CONDUCT

17

Compliance with Anti-Financial Crime Laws (cont.)

FAIR COMPETITION AND ANTITRUST LAWS

ANTI-MONEY LAUNDERING LAWS

At CME Group, we compete hard, but fairly and in accordance with allapplicable antitrust and competition laws. Most countries regulate theactivities of companies in the marketplace through competition or“antitrust” laws, which prohibit agreements or understandings among
competitors that might undermine competition or result in an unfair
advantage in the marketplace. These laws are often complex and varyconsiderably from country to country. Take care when dealing withcompetitors and gathering information about competitors.

Money laundering, which is the practice of disguising the origins of illegally-obtained
money, is prohibited by law. The methods by which money may be laundered are varied
and can range in sophistication from simple to complex.

Do not engage in any conduct that gives even the appearance of
unfair competition, such as making agreements about prices, agreeing
to boycott a supplier or customer or agreeing to allocate customers ormarkets. Trade associations have an increased risk for antitrust
infringements. CME Group colleagues involved in any such associations
should reach out to Corporate Compliance for guidance.

Any involvement in a transaction that works to conceal or disguise the nature, location,
source, ownership or control of proceeds derived from criminal activity may constitutemoney laundering.
It is the policy of CME Group to take all reasonable and appropriate steps to prevent
persons engaged in money laundering, fraud, or other financial crime, including thefinancing of terrorists or terrorist operations, from utilizing CME Group products andservices. We escalate any red flags and we report suspicious activity as required. To
meet these obligations, certain areas of the company are subject to specific antimoney laundering and Know Your Customer policies, procedures, reporting obligations
and training. Please refer to the Anti-Money Laundering Compliance Officer, whose
details can be found on OpenExchange.

LOBBYING AND CAMPAIGN
FINANCE LAWS
CME Group encourages personalparticipation in the political process
in a manner consistent with all
relevant laws and company
guidelines.
Although we respect yourinvolvement in political activities, you
should ensure they remain separate
from your work at CME Group. You
may not use CME Group resources or
seek reimbursement for your personal
political activities. Only authorizedindividuals may engage in lobbying
activities on behalf of the company.

2024 CME GROUP CODE OF CONDUCT18

GIFTS, ENTERTAINMENT AND HOSPITALITY

REPRESENTING THE COMPANY

We protect our reputation by ensuring that gifts,
entertainment and hospitality are legal,
appropriate and reasonable

entertainment and travel can create theappearance of a conflict and worse, truly excessive
offerings risk the appearance of a bribe.

We understand that developing relationships withour clients, vendors and other stakeholders is an
important part of business. The propriety of giving
and receiving gifts and entertainment depends
upon its value and the intent of the giver. Gifts andentertainment should only be provided to create
goodwill or strengthen business relationships, andcan never be given or received with a corrupt
intent. Keep in mind that inappropriate gifts, meals,

CME Group’s Gifts and Entertainment Policy
provides guidance on when it is appropriate foryou to give and receive gifts, entertainment or any
other business courtesy. Before accepting orproviding any gift or entertainment, make sure you
are familiar with the prohibitions and the reporting
and approval requirements as set forth in the Gifts
and Entertainment Policy.

INSIDER TRADING AND MARKET ABUSE
Our personal trading activities do not undermine
the fairness of the marketplace
Most jurisdictions where CME Group operates
prohibit insider trading and other forms of market
abuse. Given our status in the economy as a highly
regulated, publicly traded company, it is importantthat your personal trading activities are conductedin accordance with all applicable laws. You shouldfamiliarize yourself with CME Group’s Personal
Trading Policy. It describes company-wide policies
that address the risks of insider trading, market
abuse and other trading restrictions based on
applicable regulations, including the following:• Do not trade in CME Group securities or the
securities of any other company, either directly or
indirectly through a family member or otherpersons or entities, when you have access to“material” and “nonpublic” information, referred toas “inside information,” about the company or are
subject to a trading restriction period. “Material”
information means information that could affectthe price of the security or that a reasonable
investor would consider important when deciding

whether to make an investment. Do not make any
recommendations or suggest that anyone makean investment in a company when you have suchinformation.
• Do not disclose any inside information to anyone
who does not have a legitimate reason forneeding to know such information.
• Appropriately protect inside information bylimiting access and using secure methods whensharing with those who have need to access it.
• Do not engage in hedging transactions in CMEGroup stock, including options.
• Do not trade any futures contracts (regardless of
where listed or traded). Do not trade any otherfinancial instrument when you have access to
inside information (as more broadly defined in the
Personal Trading Policy).
• Follow all applicable pre-clearance and reporting
requirements.

Everything we communicate about our company
can have an impact on our reputation,
shareholders, colleagues and brand. Seek
guidance from Information Governance to ensurethat all business records and communications(including emails and instant messages) areprofessional, clear, accurate and in accordancewith our brand Remember, everything is on therecord, and your business communications may beshared or become public through litigation or
regulatory examinations or investigations.
All business-related communications, including
mobile communications, text messages and instantmessages should only take place on a CME Groupissued device, using VDI, or a CME Groupapproved application or tool. Certain regulated
businesses have specifications for the type ofdevice or applications that may be used. Failure toabide by such regulatory requirements will subject
you to disciplinary action and may result insignificant fines to the company.
We are committed to providing timely, consistentand credible information to our shareholders,clients regulators and the general public, which is
why only certain people are authorized to speak
on behalf of CME Group or to respond to requests
for information on behalf of CME Group as
described in the External Communications Policy.
Individuals who have not been designated as
authorized spokespersons must refer all inquiries
from the financial community (such as analysts,
institutional investors and market professionals),shareholders, media and regulators to a person
authorized to speak on behalf of CME Group.

We have adopted the External Communications
Policy to ensure that:• Full disclosure is made to everyone without
preference or favoritism to any individual or groupof individuals.
• Our responses to public inquiries – including
through news media, governments or others – areprompt and correct.
• Only authorized individuals may speak on behalfof the company, including the expression ofpolitical opinions.
• Our external communications with our clients are
fair, clear and not misleading.
• Our promotional materials, defined broadly as all
written and electronic communications discussing
our products and services, including but notlimited to written marketing brochures, panelpresentations, social media posts, advertisements,press releases, scripts, website content andclient-targeted communications, are appropriately
reviewed and approved in accordance withapplicable regulatory requirements.
• Employee speaking arrangements, including
associated presentation materials are submitted
and reviewed by a representative of Corporate
Communications via the Global Event andSpeakers Bureau Request Form.
• Colleagues use good judgment when using social
media tools, including respecting the privacy ofothers, and only publicly available information isdisclosed.

Refer anyone seeking information regarding CME
Group pursuant to any investigation or other legal
proceeding to a litigation attorney in the Legal
Department. This doesn’t apply to regulatory
requests received in the ordinary course of business.

2024 CME GROUP CODE OF CONDUCT194WE RESPECT OUR
COMMITMENTS AS AN
EMPLOYER OF CHOICE

2024 CME GROUP CODE OF CONDUCT20MAINTAINING A RESPECTFUL AND SAFE WORKPLACE
CME Group’s success depends on our talented teams and thecontributions they make every day to move our business forward. We
embrace our diverse experiences, cultures and skills, working to ensurethat all perspectives are acknowledged and valued.

NO HARASSMENT OR DISCRIMINATION
Employment at CME Group is based upon individual merit andqualifications directly related to professional competence. We will not
tolerate discrimination against anyone on the basis of any
characteristic protected by applicable law in recruiting, hiring,placement, compensation, training, career development, promotion,
discipline, grievances or redundancy and dismissal/termination.
We expect all colleagues, regardless of career level or role, to treat
everyone with professional courtesy.
Employees are not prohibited from entering into romantic relationships
with other employees at CME Group, provided the relationship isconsensual. When the relationship involves direct or indirect reportinglines it must be disclosed as a potential conflict of interest in accordancewith the Conflicts of Interest Policy. Additionally, given the potential for
influence and a real or perceived power imbalance, all employees at theManaging Director level and above must disclose any romantic
relationship with another CME Group employee to a senior employee in
HR regardless of whether it involves reporting lines.
Further guidance on our policy concerning nondiscrimination and equal
employment opportunity is set forth in your local Employee Handbook,if any, which can be obtained from HR or on OpenExchange.

PHYSICAL SECURITY, BUSINESS CONTINUITY AND HEALTH AND
SAFETYCME Group implements rigorous plans designed to ensure the security ofour people and resiliency of our operations globally. These plans include
processes for identifying, monitoring and protecting against the risks
posed by man-made or natural incidents that affect our people, facilities
and information technology assets and systems.
You should be an active participant in our business continuity and crisis
management, workplace violence prevention and other safety drills.
For further guidance regarding health, safety, drug and alcohol use,
consult your local Employee Handbook and employer-specific manuals/
policies applicable to your work location, copies of which may beobtained from HR or on OpenExchange.
RESPECTING OUR POLITICAL DIFFERENCESCME Group is committed to fostering a professional, collaborative,
inclusive and welcoming work environment. Colleagues should be awarethat CME Group’s employees are diverse and hold a variety ofviewpoints and should take this into consideration when expressing
opinions of a political nature, especially in communications or throughany other manifestations relating to a political party, candidate, social
movement or issue during work or at the workplace. Colleagues should
not use company equipment and resources (including, for example,
message boards, copy machines, computers, mobile devices, email
accounts, virtual backgrounds, profile pictures) to advocate for oragainst a particular political party, candidate, or proposition they
support or oppose. The company will not tolerate intimidation, threats,or any attempt to impede the voting activities of our colleagues. We
recognize there are local differences in regulations and laws and nothing
in this policy is intended to curtail local statutory rights as they exist in
any of the company’s locations.

GLOBAL SECURITY OPERATIONS CENTER
Any issues related to physical safety should be directed to the Global Security Operations Center or +1 312 930 3111.

2024 CME GROUP CODE OF CONDUCT215WE VALUE BEING A GOOD
CORPORATE CITIZEN

2024 CME GROUP CODE OF CONDUCT22

COMMUNITY INVOLVEMENT AND CORPORATE CITIZENSHIPWe believe that it is both a responsibility and a privilege to give back to the community.
Through our charitable programs, we are focused on building brighter futures. We support
important philanthropic causes around the globe. We empower our employees to make apositive difference in our communities by sponsoring volunteer opportunities during work
hours, as well as through our paid time off for volunteering program.
CORPORATE SUSTAINABILITY

ESG AT CME GROUP

As a leader in our industry, we value the role we play in being a good steward of theenvironment and creating an efficient workplace. We are committed to putting change into
motion that will positively impact the environment of tomorrow. As part of that commitment,
we work across our global offices to implement sustainability initiatives, including recycling
and utilizing energy-efficient technologies at our facilities.

At CME Group, we believe inadvancing policies that strengthen the
integrity of our global company – fromworkforce empowerment, to corporate
stewardship, to community
commitment and sustainable solutions.
cmegroup.com/company/corporatecitizenship/esg.html.

HUMAN RIGHTSCME Group respects human rights and believes our colleagues are entitled to a safe andhealthy work environment that is free from discrimination and harassment, threats or actsof violence or intimidation. CME Group is committed to essential ethical standards andmandates compliance with the laws and regulations in the jurisdictions where we operate.
Additionally, CME Group respects the human rights of others and values our business
partners who do the same, including laws that promote safe working conditions andindividual security; laws prohibiting forced labor; prohibitions on the employment ofunderage children and prohibitions on human trafficking. The company is committed to
identifying, preventing and mitigating human rights violations resulting from or caused byour business activities through a due diligence process as described in our Modern Slavery& Human Trafficking Statement.

2024 CME GROUP CODE OF CONDUCT 23

6
WE FOLLOW ALL APPLICABLEREGULATORY REQUIREMENTS

2024 CME GROUP CODE OF CONDUCT24

Additional Provisions Relating to Colleagues in Certain Regulated Businesses
Colleagues who support our regulated businesses are subject to additional requirements, which require the escalation of violations of the Codeand its related policies to their appointed compliance officer. A list of the compliance officers is available on OpenExchange.

BrokerTec, EBS and Benchmarks

CME Group Global Repository Services

Clearing HouseAny violations of the policies referenced herein, or potential
red flags, must also be communicated to and investigated by
the Regulatory Compliance Officer of the relevant regulated
entity providing the EBS or BrokerTec services, or our regulated
Benchmark entity. In addition to the referenced CME Group
policies, additional policies and manuals apply to theseregulated businesses. If a conflict occurs amongst policies, themore stringent policy must be followed. The list of applicable
Regulatory Compliance Officers is available on
OpenExchange.

To the extent matters relating to the responsibilities described in thisCode relate to CME Group’s global repository services, including any
disclosures or evaluation of suspected violations of the Code, suchmatters shall be disclosed to the Global Repository Services Chief
Compliance Officer, who will then further escalate the matter to thesenior officer of the repository, the board of directors of the repositoryor the appropriate committee of the board and/or the Global Chief
Compliance Officer, as appropriate. Disclosures made by the chiefcompliance officer of the repository shall be evaluated by its board of
directors or a committee thereof, as appropriate.

Any violations of this Code or related policies relating to ourclearing business, must also be communicated to andinvestigated by the Chief Compliance Officer of the Clearing
House who will then further escalate the matter to the senior
officer of the Clearing House, the Clearing House OversightCommittee and the Market Regulation Oversight Committee,
as appropriate.

2024 CME GROUP CODE OF CONDUCT

25

cmegroup.com© 2024 CME Group Inc. All rights reserved.

CC22_EC001/0724

2024 CME GROUP CODE OF CONDUCT

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