FINAL

PublicLEADING WITH CONVICTION AND INTEGRITYGUIDE TO CONDUCTING
BUSINESS FOR THIRDPARTIES OF CME GROUPCME Group Policy Document No. andVersion No.:
Policy Document Issued By:
Contact Information:
Date Policy Document Originally Issued:
Date Policy Document Last Revised:

0008
Version 9.0
Global Corporate Compliance & Ethics
Team
Corporate Compliance
September 2013
May 2023

PURPOSE AND STATEMENT OF GUIDEThe CME Group organization, including those entities where CME Group is not
the sole owner but has control of the entity including its subsidiaries (collectively, “CME
Group” or the “Company”) is committed to firmly adhering to ethical business practices indealing with its clients, vendors, regulators, business partners, shareholders and others.
For a “culture of compliance and ethics” to work, every person who assists us with ourbusiness must act ethically and ensure his or her actions are consistent with the law andrelevant CME Group policies. This means understanding our principles and the policies
we’ve put in place to help implement those principles. It also means when a question or
problem occurs, people respond with care rather than ignoring the issue or simply guessing.
This Guide is designed to help any third party working with us or on our behalf, such as our
external consultants, agents, vendors and strategic partners, to have a basic understandingof CME Group’s standards for business conduct. It shows how our policies translate into our
conduct and explains what we aim for to comply with these policies.
CME Group understands that many companies have their own code of conduct that
addresses the topics in this Guide. Our expectation is not that our vendors replace their codewith this Guide, but rather than our vendors ensure that they have consistent treatment intheir code, address any CME Group-specific issues and requirements with their staff insupporting CME Group, and meet the reporting expectations in this Guide. Compliance withthis Guide will be considered in decisions regarding continuing service with a vendor andalso decisions regarding whether a particular individual can continue to provide services for
CME Group.
Nothing in this Guide is meant to supersede any specific contractual arrangements between
CME Group and any third party. In the event of conflict between the terms of a specificcontract and this Guide, the contract terms will prevail.
The failure or omission of CME Group to insist upon strict performance and compliance withany of the provisions of this Guide at any time shall in no way constitute a waiver of its rights.

APPLICABILITY AND SCOPE
We expect all third parties assisting us with our business to conduct business on our behalf
responsibly and in compliance with global laws and regulations and to report any concerns
to us and make sure that suspect behavior does not go unchallenged. When conducting
business on our behalf, you are expected to demonstrate your commitment to the standards
set forth in this Guide. You must promptly inform your CME Group contact or a member of
CME Group management or Corporate Procurement when any situation develops thatcauses you to operate in violation of this Guide.
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DUE DILIGENCE
Where appropriate, CME Group conducts risk-based due diligence on third parties as part ofassessing its relationship with third parties and any associated risks from such engagement.
CME Group expects third parties to provide complete and accurate information to facilitate
these due diligence efforts undertaken by CME Group, where requested.

CONFLICTS OF INTEREST
Certain types of relationships can present potential or actual conflicts of interest. All third
parties working on behalf of CME Group must avoid entering into an arrangement thatconflicts with your responsibilities to CME Group. A conflict of interest arises when you havea personal or financial relationship or other interest that could interfere with your obligation toact in the best interests of CME Group, or when your outside business activities interferewith your ability to perform your services to CME Group.
Any potential conflicts of interest must be discussed with Corporate Procurement and theapplicable business owner in consultation with Corporate Compliance, as necessary, as partof the engagement process. To the extent a conflict of interest arises during the course ofyour services, you must promptly inform your CME Group contact or a member of CME
Group management or Corporate Procurement.

PROTECTING CME GROUP INTELLECTUAL PROPERTYCME Group’s intellectual property is among its most valuable assets, and includes without
any limitation copyrights, patents, trademarks, trade secrets, logos, photos/videos, otherintangible industrial and commercial property or other proprietary rights.
To the extent permitted by law, and where you agreed as a condition of your engagement toprovide services to the Company, CME Group has the rights to all intellectual property you
create while providing services to the Company that relates to CME Group business; and/or
results from you carrying out your duties or services; or relates to CME Group’s actual
demonstratively anticipated research or development. This is true regardless of whether theintellectual property is patentable or protectable by copyright, trade secret or trademark.
We also respect all third-party intellectual property rights and other intangible commercial
rights belonging to others. You should never knowingly infringe upon those rights. 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.

PROTECTING AND PREVENTING THE MISUSE OF CME GROUPCONFIDENTIAL AND MATERIAL, NON-PUBLIC INFORMATION
All third parties requiring access to CME Group Confidential and Highly Sensitive Information(as defined in the Confidentiality and Data Protection Policy), including our clients, must
execute an appropriate confidentiality agreement and/or receive approval from CME Group’s
legal counsel prior to accepting or gaining access to such information.
You must always take appropriate precautions to ensure that CME Group Confidential andHighly Sensitive Information, whether proprietary to us, our clients or another company, iscommunicated on a confidential basis only to those individuals who have a need to knowsuch information to perform their job responsibilities. Insofar as you agreed as a condition of2

your service to CME Group, you must follow all Company policies and procedures relating to
the protection of CME Group information as well as project-specific security or privacy
requirements as described in the Confidentiality and Data Protection Policy. Copies ofother policies referenced therein should be provided to you in connection with yourengagement by Corporate Procurement.

DATA PROTECTION
CME Group expects its third parties to respect and safeguard the privacy of CME Group
employees and customers. Third parties are required to take all reasonable and appropriate
steps to safeguard personal data provided in connection with services provided to CMEGroup in accordance with CME Group’s Confidentiality and Data Protection Policy. Third
parties may only collect, process, use, store and retain personal data obtained from CME
Group as necessary and in compliance with applicable privacy / data protection andinformation security laws and regulations.
In the event a third party collects, processes, uses, stores, or retains personal data on CMEGroup’s behalf, such third party must follow all agreed to contractual obligations relating tocompliance with applicable data protection regulations.

ACCESS AND USE OF CME GROUP ELECTRONIC MEDIA
Generally, third parties will use their own laptops or computers to accomplish their work. In
those circumstances where a third party may be given access to CME Group’s electronic
environment (Intranet, email, voicemail or other), third parties will adhere to applicable CMEGroup policies.
You will not knowingly download, view or forward materials of a discriminatory, harassing,threatening, sexual, pornographic, racist, sexist, defamatory or otherwise offensive in natureon the CME Group network, using any CME Group device or to any CME Group colleague.
It is expected that CME Group electronic media is used for business purposes only.
You will communicate protected information (personal, confidential or trade secret) in a waythat recognizes the sensitivity of the information, the possibility of unauthorized access andcompliance with local data protection laws.
You understand that documents, software, emails and other webpages could bringdamaging computer viruses into CME Group’s network. You will not knowingly detach,decompress, run/launch or install any files or programs on CME Group’s systems or open
attachments that have damaging computer viruses. You will also not download ordisseminate any material from the Internet unless the copyright owner has provided consent.
Any third party who provides media storage on behalf of CME Group must also adhere to thetiming and methods for retention and destruction of CME Group data as described in the
Company’s Records and Information Management Policy, copies of which will be
provided as part of such engagement by Corporate Procurement.

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ANTI-BRIBERY AND ANTI-CORRUPTION
Our policy is to comply with all laws in the jurisdictions in which we conductbusiness, including all anti-bribery and anti-corruption laws.
No third party may directly or indirectly offer, promise, grant or authorize the giving of moneyor anything else of value to anyone to obtain an improper advantage for or on behalf of CME
Group. Third parties are also prohibited from requesting, agreeing to receive or accepting
anything of value with the intention of providing or receiving an improper advantage for or on
behalf of CME Group.
Anything of value includes cash or cash equivalents (e.g., gift cards), gifts,
gratuities, goods, entertainment, tickets, meals, drinks, travel, lodging,
charitable contributions, political contributions, training, services, personalfavors, offers of employment or internships, hiring a friend or relative, or
anything else that is valuable to the recipient even if it would not be valuable
to anyone else. Given the broad interpretation, it is important that you
understand our policy.
Improper advantage includes such things as influencing an individual to act
in violation of his or her duty. Even if it was not the intention, any perceptionof impropriety must be avoided.
Corruption can occur when dealing both with commercial partners and government officials.
Although some anti-bribery laws focus on government bribery, our anti-bribery and anticorruption policies apply to both the public and the private sectors.
GIFTS AND ENTERTAINMENT
Vendors, suppliers, external consultants working for us should not provide gifts orentertainment in connection with CME Group business to any third parties unlessspecifically authorized to do so in connection with the engagement.
Gifts and entertainment are often used to establish and foster business relationships,
improve one’s image and better present one’s products and services. They often are
considered a form of courtesy and are common in everyday business in many countries.
However, such activities have the potential to be used as (or may be perceived as) bribes toobtain an improper advantage or otherwise unduly influence a decision. Therefore, it is CME
Group policy to limit gifts and entertainment that may appear to compromise the integrity andjudgment of an individual or may create an apparent or potential conflict of interest.
A gift may include anything of value for which an individual is not required to pay the retail orusual and customary cost. Entertainment may include meals, drinks, business dinners,
tickets to events, sightseeing, golf outings and transportation.
Gifts and entertainment provided to individuals who are “government officials” aresubject to stricter standards. The definition of government official is very broad and may
not always be apparent. It covers anyone working for a government entity at any level, which
can include any state-owned enterprise, government agency or public organization such as
sovereign wealth funds, central banks (World Bank), international organization (United
Nations), state universities, public pension funds, state-owned exchanges (KRX) and stateowned clearing firms (ABN AMRO Clearing Chicago LLC, whose parent company is Dutchstate owned), regulators of CME Group (Commodity Futures Trading Commission (CFTC),
Financial Conduct Authority (FCA), Securities and Exchange Commission (SEC),
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Netherlands Authority for the Financial Markets (AFM)), utilities, certain media, civilians
performing public functions, anyone treated as a government official under local law,candidates for political office, political party officials or anyone associated with a politicalparty, and anyone acting for the benefit of, or in a position of influence to, a government
official, such as a friend or family member. It may also include anyone acting for the benefitof, or in a position of influence to, a government official such as a friend or family member.
Particular concerns arise when gifts or entertainment are in some way connected with apotential transaction, business relationship or regulatory approval. Even when there is no
improper intent, such intent may be inferred from the surrounding circumstance. You may
not offer anything of value to obtain or retain a benefit or advantage for the giver, and you
should not offer anything that might appear to influence, compromise judgment, or obligate a
CME Group colleague. The recipient should not be given the impression they are under anobligation to confer any business advantage or the recipient’s independence will be affected.
This Guide cannot address all the corruption issues raised by local legal requirements, which
may be more restrictive than our global standards. Where necessary, seek additional
guidance from CME Group Corporate Compliance or your local business contact at CME
Group who can consult any of our available compliance resources.
CME Group colleagues may accept gifts and entertainment provided that are in compliancewith the Code of Conduct and the Gifts and Entertainment Policy, copies of which are
made available to such colleagues. Note that, other than meals with an expected valueof US$50 or less per person during which the potential services are discussed, CME Group
employees may not accept gifts or entertainment from vendors or potential vendors whennegotiations are occurring, while a proposal for new business or a renewal of business ispending or when there is a potential bidding process when such individual has the potential
to influence the vendor selection or the contract terms.

HANDLING “INSIDE INFORMATION” APPROPRIATELY AND
LAWFULLY AND PARTICIPATING IN THE MARKETPLACE ON FAIRTERMS
Most jurisdictions where CME Group conducts its business prohibit by law insider trading
and other forms of market abuse.
If you are aware of or have access to material, non-public information relating to CME Groupor to any other company as a result of your services to CME Group, you may not buy or sell,
directly or indirectly through a family member or other person or entity, CME Group or theother company’s securities or give, communicate, or in any way convey such information toanother person.

FAIR COMPETITION AND ANTITRUST
All third parties representing CME Group are expected to comply with all applicable laws andregulations regarding fair competition and antitrust. We place a duty on our third parties toreport any violation that is suspected or discovered, through and of the Available Resources
listed below.

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FINANCIAL CRIME AND MONEY LAUNDERINGCME Group does not tolerate financial crime, including money laundering and terrorist
financing activities.
CME Group defines financial crime as illegal acts carried out for financial or economic gain.
CME Group defines money laundering as the process by which proceeds from illegal
activities are disguised so they appear to be from legitimate sources. This includes
concealing, acquiring, using or possessing such proceeds or facilitating the acquisition, use,retention or control of such proceeds.
Third parties shall not provide any service or enter into any arrangement that facilitates or
may constitute CME Group being involved directly or indirectly in economic crime, including
money laundering activities. Third parties shall not channel any funds to, or support, illegal
activities (e.g., terrorism, tax evasion, fraud).

TRADE COMPLIANCE
Third parties representing CME Group are expected to comply with the letter and spirit of all
applicable import and export controls and trade compliance laws and avoid doing anythingthat would position themselves or CME Group in violation of applicable economic sanctions
and export control laws. We place a duty on our third parties to report any violation that issuspected or discovered, through and of the Available Resources listed below.

COMPLIANCE WITH APPLICABLE TAX LAWS
CME Group is committed to preventing the involvement of those acting on its behalf in the
direct or indirect facilitation of tax evasion. CME Group has a zero tolerance policy for any
third parties who indirectly or directly facilitate tax evasion, or fail to prevent the same. We
place a duty on our third parties to report any incident of tax evasion that is suspected or
discovered, through and of the Available Resources listed below.

LABOR AND HUMAN RIGHTSAt CME Group, we respect human rights and believe our colleagues are entitled to a safeand healthy work environment that is free from discrimination and harassment, threats or
acts of violence or intimidation. At a minimum, all third parties representing CME Group mustcomply with all applicable laws and regulations related to human rights, labor rights, working
conditions, health and safety and environment and obtain all legally required permits,
licences and registrations which they must be able to demonstrate upon request.
Forced Labor
Employment must be freely chosen and voluntary. Involuntary labor includes thetransportation, harbouring, recruitment, transfer, receipt, or employment of persons bymeans of threat, force, coercion, abduction, fraud, or payments to any person having control
over another person for the purpose of exploitation. No third party may employ forced laboror engage in any form of human trafficking whether by force, fraud or coercion. All forms of
involuntary servitude and slavery as well as any forced sex trafficking or the procurement of
any commercial sex act are strictly prohibited by third parties.
All third parties must be able to verify the legal employment eligibility of all persons to workand not use any form of prison, indentured, forced, involuntary, bonded or slave labor.
6Child Labor
Vendors shall not use or support the illegal use of child labor. Vendors shall comply with allapplicable child labor laws and use only workers who meet the minimum legal age of
employment for their locality.

RESPECT, INCLUSION AND NON-DISCRIMINATION
We expect workers of those working on our behalf to be treated with respect and dignity. All
third parties are expected to comply, at a minimum, with all applicable laws regarding
discrimination in hiring and employment practices.

ENVIRONMENTAL SUSTAINABILITY
CME Group recognizes the importance of reducing its carbon footprint and has conducted
an inventory of our greenhouse gas emissions. Conducting and disclosing this inventory is ameaningful step in our efforts to evolve our internal sustainability initiatives. We will continue
to report on these metrics each year and aim to make improvements where possible.
In addition to complying with applicable environmental laws, we encourage suppliers to
adopt sustainability and environmental practices. CME Group expects its suppliers todemonstrate a clear understanding of the environmental risks, responsibilities, and impactsof the products and services they provide. We encourage suppliers to collaborate with us in
supporting our efforts to reduce the impacts of climate change. We expect suppliers toprovide us with information to support our reporting related to environmental sustainability
and supply chain emissions.
CME Group continues to evolve and improve our sustainability efforts as described in ourannual ESG Reports.

SELF-REGULATORY ORGANIZATION AND OTHER REGULATORYOBLIGATIONSAs the operator of multiple self-regulatory organizations as well as other regulated
businesses, CME Group has a heightened and proactive responsibility to protect market
integrity and to ensure we meet all applicable regulatory obligations. These responsibilities
include, but are not limited to, acting to proactively mitigate risks to prevent damage to themarketplace, protecting market participants and public interests and preventing fraud andmanipulation and removing barriers to free and open markets. We expect the third parties
we do business with to assist us in meeting these obligations, including reporting any actual
or constructive notice of potential rule violations or violations of the regulations relating to themarkets we own and operate to our Market Regulation Department.

AVAILABLE RESOURCES AND RAISING CONCERNSAt CME Group, we rely on those working on our behalf to raise issues and concerns so thatsuch matters can be effectively addressed. If you see something that raises a compliance or
ethical question or concern, you have an obligation to report it. Timeliness of reporting isessential.
7If you wish to report questionable behaviour or a possible violation of this Guide or another
CME Group policy, you are encouraged to work with your primary CME Group contact inresolving your concern. You may also utilize the CME Group Helpline. These reports andrequests may be made anonymously, as permitted by local law, and will be treated asconfidential to the extent possible. We do not retaliate against anyone who makes a report ingood faith.
Any questions regarding this Guide should be directed to your CME Group contact or amember of CME Group management or Corporate Procurement.

OVERSIGHT AND REVIEW OF GUIDEThis Guide is subject to the oversight of the Global Corporate Compliance & Ethics Team.
CME Group will periodically audit and monitor compliance with this Guide as necessary andappropriate. This Guide is subject to review on an as needed basis but at least every three(3) years.

PENALTIES AND CONSEQUENCES
Potential violations will be subject to investigation by the Company and/or its agents, andany failure to comply with this Guide may result in termination of services to CME Group.

8Revision History for the Guide to Conducting Business for Third Parties of CME
Group.
Version Date

Revision

Owner(s)9.0

May 2023•

New sections on Due Diligence,
Economic Crime and Compliance,
Environmental Sustainability and SelfRegulatory Organization and other
Regulatory Obligations

Corporate
Compliance

8.0

April 2022•

Updates and clarifications made tosections below, and other minor
administrative updates: Fair Competition
and Antitrust, Trade Compliance, andLabor and Human Rights.

Corporate
Compliance

7.0

January
2021•

Minor updates•

Added Respect, Inclusion and NonDiscrimination section

Corporate
Compliance•

Added an existing point from the Gifts andEntertainment Policy that CME Group
colleagues may not accept gifts orentertainment from vendors or potential
vendors when negotiations are occurring,
exception for a nominal business meal.

6.0

November
2019•

Clarifying changes.

Corporate
Compliance5.0

December
2018•

Added reference to the Confidentiality andData Protection Policy

Corporate
Compliance4.0

October
2017•

Added section on Compliance with
Applicable Tax Laws

Corporate
Compliance3.0

September
2017•

Added section on Data Protection

Corporate
Compliance2.0

April 2017•

Added Labor and Human Rights section

Corporate
Compliance1.0

September
2016•

Added clarifying language regarding gifts•

Update the Helpline to include India

Corporate
ComplianceMatrix of Approvals
Description of Required Approval

Date of Last Approval Relating toCurrent Version (Version 9.0)

Global Corporate Compliance & Ethics Team

March 08, 2023

9