2022

Sustainability
ReportReimagining a
More Sustainable
Tomorrow1

Nasdaq 2022 Sustainability Report

Table of Contents

Introduction

Environmental

22

SocialSolidify Our BusinessResilience and Drive
Sustainale Growth

Governance61

ESG Solutions

Environmental: Solidifying Our
Commitment

62

ESG Solutions:Supporting Our Clients

24

Decarbonization andClimate Strategy

63

ESG Products and Services

33

Natural Resource Management64

Supporting the
Corporate Community

34

Social: Solidifying
Progress for All

67

Supporting the Investment
Community72

Supporting Clients throughResearch and Education

A Letter from the Chair & CEO

4

About Nasdaq

35

Diversity, Equity and Inclusion

72022 in Review

36

Workforce

8

Our ESG Journey38

Human Capital Management

9

ESG Ratings

10

ESG Governance11

Our ESG Reporting

12

ESG Materiality Assessment

1542

Employee Engagement
and Satisfaction

45

Supplier Diversity

46

Governance: Solidifying
Corporate Excellence

Our Strategic Approach to Sustainability

47

Corporate Governance18

Our Support of the United Nations
Sustainable Development Goals

49

Corporate Behavior

21

Sustainability-Linked FinanceAppendix

Support Our Clientsand Enable Positive
Outcomes

23

3

Community Engagement

73

Community Engagement:
Enabling Positive Outcomes

74

Nasdaq Purpose

74

The Nasdaq Foundation

75

Nasdaq Entrepreneurial Center

76

Appendix

77

Environmental Data

84

Social Data

92

Governance Data93

Our Support of the United
Nations Sustainable
Development Goals

94

Assurance Statement

95

Additional Resources

95

ESG Material Topics Glossary2

A Letter from the Chair & CEO
At Nasdaq, our position at the intersection of capital markets
and technology allows us to approach environmental, social,and governance issues from a unique vantage point. It also
provides us with an important role to support our clients’success across the global economy, acting as a bridge
between key market constituents — from asset owners tocorporates — as they navigate the complexity of an evolving
ESG landscape.
Nasdaq’s own corporate sustainability strategy is designed
to solidify our business resilience. We are committed toadvancing meaningful sustainability efforts to reverse
the negative effects of climate change by minimizing
our environmental footprint and delivering market-based
innovations that support a net-zero future. We are also
committed to deepening our culture of diversity, equity, andinclusion as we solidify our position as a destination for theworld’s leading talent, as well as continuing to lead with bestpractice governance policies.

Adena Friedman
Chair & CEO, Nasdaq

Our efforts are producing tangible results. In 2022, weachieved carbon neutrality for the fifth year in a row, and our
net-zero emissions targets were approved by the Science
Based Targets initiative. We were also recognized by several
third-party validators for our sustainability efforts andinclusive workplace policies. We expanded our community
impact around the globe through the Nasdaq Foundation,
establishing thoughtful partnerships aimed at diversifying
entrepreneurship and creating accessible pathways to thewealth capital markets can create. Each of these efforts
reflects our renewed corporate purpose: to advanceeconomic progress for all.

The new organizational structure we implemented at the endof 2022 further strengthens our ability to create even greater
impact. Our new divisional structure aligns our businessmore closely with the foundational shifts that will shape theglobal financial system over the decade ahead, including themodernization of markets, the development of a complex
ESG ecosystem facing corporates and investors, and theincreasing need within the financial system for advanced
anti-financial crime technology.
We are investing in market infrastructure innovations toensure that capital markets are resilient and can continue
to power opportunity around the world. We are empowering
our clients to navigate the capital markets and their own
sustainability journeys more effectively. Additionally, weare driving the global fight against financial crime with acomprehensive suite of solutions designed to help us getahead — and stay ahead — of those who seek to abuse thefinancial system for their own gain.
The pages that follow tell a more complete story about ourachievements in 2022. But I am most inspired about whatcomes next. The most successful sustainability initiatives
are those that can be upheld for the long-term, and thegroundwork we laid in recent years will help us do just that.
I am confident that we will continue to build on our momentum
in 2023 and beyond — letting our past achievements fuelfuture successes and delivering even greater impact for ourclients and for communities around the world.
Adena Friedman, Chair & CEO, Nasdaq

GRI 2-22
WEF Core 1

3

Nasdaq 2022 Sustainability Report

Introduction

About Nasdaq
Core Purpose
Long-Term
VisionWe will be the trusted
fabric of the global
financial system

We advance economic progress for all

Value Proposition
We deliver world-leading
platforms that improve theliquidity, transparency andintegrity of the global economy

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Nasdaq, Inc. is a global technology company
serving the capital markets and other industries.
Our diverse offerings of data, analytics, softwareand services enable clients to optimize andexecute their business vision with confidence.
In 2022, we announced and implemented
a new organizational structure thataligns our businesses more closely tofoundational shifts that are driving theevolution of the global financial system. In
order to amplify our strategy, we aligned
the Company more closely with evolving
client needs. As a result, we have identified
three new reporting segments: Market
Platforms, Capital Access Platforms andAnti-Financial Crime, which align to our
new divisional structure. By aligning ourbusiness segments against these seculartrends, including the development of theEnvironmental, Social and Governance(ESG) ecosystem, we aim to deliver more
for our clients and increase growth acrossour key pillars of liquidity, transparency
and integrity.

Appendix

3.6B$

Annual Net Revenues in 2022
“Net Revenues” are defined as revenues
less transaction-based expenses

Aligning to Secular Trends

MarketModernization

Development of
ESG Ecosystem

Anti-Financial
Crime

Modernizing markets
and their underlying
infrastructure toamplify liquidity

Enhancing transparency
by connecting corporates
and investors

Maintaining a comprehensive
Anti-Financial Crime Suite

GRI 2 | GRI 2-1
WEF Core 1

4

Nasdaq 2022 Sustainability Report

Nasdaq operates in 26 countries
across the world. We havesignificant operations (which
we define as more than 200
employees in a location) in the

Introduction

Environmental

U.S., Canada, Sweden, Lithuania,
India, Philippines, Australia andthe United Kingdom. These eightlocations comprise over 95% of
our total employee population.

SocialGovernance26

Nasdaq operates in

ESG Solutions

Community Engagement

Appendix

Headcount increased to 6,377 employees asof December 31, 2022, from 5,814 employees
as of December 31, 2021 primarily due to thegrowth of our businesses.

countries around the world

6,377

Headcount as ofDecember 31, 2022

5,814

Headcount as ofDecember 31, 2021

4,830

Headcount as ofDecember 31, 2020

GRI 2-1

5

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialInnovation and Technology
We are a company of landmark beginnings, from launching
the first electronic exchange in 1971 to migrating the firstexchange to the cloud last year. We continue to reimagine
technology to better serve global markets and ourcontinued success relies on our commitment to embracing
inclusive growth, driving innovation and empowering our
employees. In order to rewrite the future, we must rewrite
the way we work. We are confident in our new corporate
structure and are incredibly energized by what lies ahead.

at scale. We drive compelling value directly to clients while
creating broad positive externalities. In December 2021,
we announced a multi-year partnership with Amazon
Web Services to accelerate Nasdaq’s cloud journey, andevolve our innovative technology to a modern, cloudnative blueprint and standardize the infrastructure of theworld’s markets. See 'Market Platforms' on page 17 for more
information on the first market migration of Nasdaq MRX
which went live in 2022.

“Driving Innovation” is one of our foundational corporate
values and one we encourage employees to live andbreathe every day. We regularly conduct internal
hackathons, ideathons and other crowdsourcing events
to foster the growth of innovative ideas within our own
organization. Our culture of innovation and technology
leadership align to support progress for our stakeholders

At the same time, we humbly recognize the contributionsof the technology, business and regulatory partners that
help make this possible. We are proud that our efforts haveearned us recognition as one of 2023’s “Most Innovative
Companies” by Fast Company and are committed to leading
the shift to more sustainable and inclusive capital markets.

“Driving Innovation” is one of our
foundational corporate values andone we encourage employees to live
and breathe every day.

Governance

ESG Solutions

10K+
Corporate Clients

Community Engagement

250+
Data Distribution
Partners

75+ 100M+

Exchange Platform
Infrastructure
Installations

Retail Investors Served

Appendix

1K+

Institutional
Investors Served

80

Carbon Removal
Partners

Recognized as one of 2023’s“Most Innovative Companies”
Fast Company

6Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance2022 in Review

5years of carbon neutrality

Net Zero

The Science Based Targets
initiative (SBTi) verified andpublished our science-basedtargets to achieve net zero by 2050

2

diverse Members added to the
Nasdaq Listing and Hearing
Review Council

8

additional LEED
certifications forour offices

ESG Solutions

Community Engagement

Appendix

ESG Awards and Recognition
We are proud that our continued commitment to advancing our ESG
objectives and initiatives has earned us recognition from leading ESG
organizations. Select 2022-2023 ESG-related recognitions include:

6.8%

4

11%

growth in the number ofsustainable debt instruments
listed on Nasdaq Sustainable
Debt Market

100%

213,932

2.3

of addressable
U.S. spend fromdiverse-owned
suppliers

percentage point
increase in underrepresented minority
representation at the
managerial level

Nominated for Best ESG Reporting

7th consecutive year

AcquiredA Nasdaq Company

diverse Directors
added to Nasdaq’s
Exchange Boardof our executive
team participated in“Inclusive Leadership”
training

CORCs issued
by Puro.earth onbehalf of suppliersa SaaS based ESG reporting andanalytics platform

2,730
#

1

8 Green Business
Certifications

Corporate Inclusion Index

hours of employee
Conscious
Inclusion training“Best Proxy Statement
2022 (Large Cap) "“B est Proxy Statement (Large
Cap)” in Corporate Secretary
Magazine’s 2022 Corporate
Governance Awards“Best Companies for
Women to Advance”

Fast Company"Most Innovative
Companies 2023"

7

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Our ESG Journey

2022
2021

1994

2012

Established Nasdaq
Foundation

Became a founding
partner of UN
Sustainable Stock
Exchange (SSE)
initiative
Joined UN Global
Compact

Appendix2015
Launched Nasdaq
Sustainable Debt
Market2017
Publishedinaugural
Sustainability
Report2018
Joined Climate
Bonds Initiative’sPartner Program
Achieved carbon
neutrality for the
first time
Formed Corporate
ESG Steering
Committee

2019

2020
Launched Nasdaq
ESG Hub

Launched Nasdaq
ESG Advisory, Nasdaq
Sustainable Bond
Network and Nasdaq
ESG Footprint
Signed "The Business
Roundtable Statementon the Purpose of
a Corporation"

Acquired OneReport,
an ESG data
management,
reporting, audit
trail and disclosure
softwareeVestment launched
ESG questionnaire
Produced inaugural
Task Force on
Climate-Related
Financial Disclosures(TCFD) report

Acquired majority stake in
Puro.earth
Launched Green Equity
Designation program
Board Diversity Rule
approved by SEC
Established ESG Strategy
and Reporting Team
Published inaugural
SASB Index
Established mandatory
diversity training for all
managers
eVestment launched D&I
questionnaire
Became UN PRI signatory
Reported against WEF's
Stakeholder Capitalism
Metrics for the first time

Near-and long-termscience-based targets
approved by SBTi
Acquired Metrio, a SaaS
based ESG analytics andreporting platform
Implemented
Environmental
Management System
Mapped alignment ofcorporate objectives toseven UN Sustainable
Development Goals (SDGs)
Named to CDP Climate
Change A List and CDP
Supplier Engagement
Leaderboard
Launched the Nasdaq
Center for Board
Excellence
Became Taskforce on
Nature-Related Financial
Disclosure (TNFD)
Forum Member8Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

ESG Ratings
Nasdaq’s ESG scores improved across multiple rating agencies in 2022, reflecting our continued commitment to advancing ESG best practices and providing stakeholders with timely and transparent ESG reporting.

AgencyScore Category

Current Score

Previous Score

Highlights

Score Range

Overall Score

AA

BBB

Highest scoring range for Corporate Governance, placing us in the Leader category and indicatingthat our corporate governance practices are well aligned with shareholder interests

AAA - DDD

1

An Environmental QualityScore of 1 indicates a high level of environmental disclosure

1-10 (1=lowest risk)

1

A Social QualityScore of 1 indicates a high level of social disclosure

1-10 (1=lowest risk)

1

A Governance QualityScore of 1 indicates a strong governance framework and low governance risk

1-10 (1=lowest risk)

Environmental
SocialGovernance

Overall Score

1
1
1
60

96th percentile
50

Overall Score

A

B

Overall Score

70 (Gold)

64 (Silver)

Included in the Dow Jones Sustainability North America Index (DJSI) for the seventh
consecutive year
Score is based on the comprehensiveness of disclosure, awareness and management ofenvironmental risks and demonstration of environmental leadership
CDP Climate Change A List — recognized for leadership in corporate transparency and performanceon climate change
95th percentile
Awarded EcoVadis Gold Medal

0–100 (100 = best)

Range: A–D(A=Leadership)

0–100 (100 = best)

Note: MSCI, ISS, CSA, CDP and EcoVadis ESG ratings are as of April 1, 2023. The use by Nasdaq of any MSCI ESG Research LLC or its affiliates (“MSCI”) data and the use of the MSCI logos trademarks, service marks, or index names herein, do not constitute a sponsorship, endorsement, recommendation, or
promotion of Nasdaq by MSCI. MSCI services and data are the property of MSCI or its information providers and are provided ’as-is’ and without warranty. MSCI names and logos are trademarks or service marks of MSCI.

9

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Governance
Our Board is committed to overseeing Nasdaq’s integrationof ESG principles and practices throughout the enterprise.
Thirty-six percent of our Board nominees have experience
with environmental and social matters (including humancapital management), which strengthens our Board’s review
and oversight of our sustainability initiatives. The Board's
Nominating & ESG Committee has formal responsibility andoversight for ESG policies and programs and receives regular
reporting on key ESG-related matters.
Our internal Corporate ESG Steering Committee is co-chairedby executive leaders and is comprised of geographicallydiverse representatives from multiple business units. The
Corporate ESG Steering Committee serves as the central
coordinating body for our ESG strategy, and regularly reportsthat strategy to the Nominating and ESG Committee.
The Corporate ESG Strategy and Reporting Team, which
ultimately reports to the Chief Financial Officer (CFO), is
responsible for execution of our sustainability strategy;
communicating our performance, metrics and ambitions
through our annual Sustainability Report, TCFD Report andrelated ESG indexes filings and surveys and collaboratingwith various stakeholders across the organization to ensure atimely and accurate data gathering process.

36 %of our Board nominees
have experience withenvironmental andsocial matters

ESG Solutions

Community Engagement

Appendix

Our ESG Oversight Structure
NOMINATING & ESG COMMITTEE (COMPRISED OF INDEPENDENT DIRECTORS)CORPORATE ESG STEERING COMMITTEE (COMPRISED OF SENIOR LEADERS AND CO-CHAIRED BY CFO AND CMO)CORPORATE ESG STRATEGY AND REPORTING TEAMCORPORATE BUSINESS UNITS AND EXPERT FUNCTIONSFINANCECORPORATE GOVERNANCE, LEGAL AND COMPLIANCE

MARKETING AND COMMUNICATIONSGROUP RISKDIVERSITY, EQUITY & INCLUSIONINVESTOR RELATIONSPROCUREMENT, SOURCING & REAL ESTATEINFORMATION SECURITYPEOPLE MANAGEMENTCORPORATE SOCIAL RESPONSIBILITYGRI 2 | GRI 2-9 | GRI 2-12
WEF Core 2

10Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Our ESG Reporting
Throughout 2022, Nasdaq continued its commitment toadvance our sustainability disclosures through enhanced andannualized ESG reporting. This commitment was reflected inscore upgrades by several leading ESG rating agencies (pg. 9).
Accurate and transparent disclosure is a cornerstone of
our ESG strategy. The data included in this report is asof December 31, 2022, unless otherwise noted. The data
gathering process requires stakeholder engagement andvalidation across the organization. Where data was based on
estimation or assumption, additional disclosure is provided as
to conclusions reached.
Select environmental and social data disclosed in this report isexternally verified to a limited level of assurance. See our 2022
Assurance Statement (pg. 94) for more details.

We report against the Global Reporting Initiative (GRI)
framework and the Sustainability Accounting Standards Board(SASB) standard and the World Economic Forum’s (WEF)
Stakeholder Capitalism Metrics. In addition, we publish a
United Nations Global Compact Communication on Progress(UNGC CoP) annually.
We have published our third Task Force on Climate-related
Financial Disclosures (TCFD) report. As part of that effort,
we conducted a climate scenario analysis to evaluate
climate-related risks and opportunities and their impact on
our business over time. This analysis helped us assess ourresiliency to climate-related risks, prioritize our mitigation
strategies and enhance our identified transition opportunities.
Furthermore, in 2022 we joined the Task Force on Naturerelated Financial Disclosure (TNFD) Forum to support thedevelopment of the TNFD’s new disclosure framework focusedon nature- and biodiversity-related risks and opportunities.

Explore our 2022 ESG reports and indexes:
Summary Sustainability Report Microsite

ESG Memberships
Nasdaq’s representation and participation in a selectgroup of ESG-related organizations supports our goal of
consistent and transparent ESG reporting and leadership.
Our association memberships represent a range of values
that closely align with the values we deem essential. Someof our key memberships are on the right.

2022 GRI Index

2022 TCFD Report

2022 SASB Index

2022 WEF Index

ESG Resource Center

GRI 2-2 | GRI 2-3 | GRI 2-28
WEF Core 8
SDG 1711

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialESG Materiality Assessment
We are committed to continuously advancing our longerterm ESG strategy, advocacy and oversight. We engage
with internal and external stakeholders at all levels on ESG
matters on an ongoing basis.
During 2022, we deepened our corporate and community
ESG efforts, furthering our commitment to greater
sustainability and climate change awareness. In addition toproviding frequent and robust reporting on our ESG efforts
and continuously working to identify emerging ESG trends,
we encouraged our employees to participate in our ESG
initiatives and engaged with our clients and stakeholders
to pursue ESG-related opportunities and support the ESG
progress of corporate issuers.
1

Nasdaq periodically conducts ESG materiality
assessments1 to identify and prioritize ESG topics thatare influential on our business and important to ourstakeholders. In 2022, facilitated by Nasdaq’s ESG
Advisory team, we commenced an organization-wide
assessment of Nasdaq’s priority ESG topics to inform oursustainability strategy and approach to ESG governanceand reporting. This assessment weighed the potential
relevance of a wide universe of topics identified as
potentially impactful by leading ESG reporting frameworks,
ratings and assessments, benchmarking exercises, surveys
and interviews with internal and external stakeholders.

Identity ESG Materiality Topics
Review leading ESG reporting frameworks,
rating agencies and consider our industry to
identify high-priority ESG topics

ESG Solutions

Community Engagement

Appendix

Twenty-one ESG-related topics were identified by the assessment to be
relevant to Nasdaq’s business. The assessment determined that the 13
topics below are Nasdaq’s highest priority ESG-related topics:• Data Privacy & Cybersecurity• Risk Management• Board Composition & Governance• Business Ethics & Integrity• Human Capital Management• Anti-Financial Crime & Anti-Money Laundering• ESG & Sustainable Finance Products• Transparency & Reporting• Employee Engagement & Satisfaction• Diversity, Equity & Inclusion• Customer Relationship Management• Decarbonization & Climate Strategy

References to materiality and similar terms refer to ESG topics that we have found to be relevant to our business based on our recent ESG materiality
assessments. Such references to materiality are different and separate from how materiality is used and understood in the context of securities and other laws of
the United States or as used in the context of financial statements and financial reporting. ESG topics and issues described as material in this report may not be
considered material for other reporting purposes.

Our
Process

Governance• Innovation & Technology

Gather Feedback from Internal andExternal Stakeholders
Interview and survey our internal and external
stakeholders to determine relative importanceof ESG topics

Validate the Results
Reaffirm the high-priority topics that pose thegreatest risk or opportunity to our business

GRI 3 | GRI 3-1 | GRI 3-2 | GRI 3-3
WEF Core 3

12

I M P O R TA N C E T O O U R S TA K E H O L D E R S

I N C R E A S I N G I M P O R TA N C E

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialESG Materiality Matrix

Governance

ESG Solutions

Community Engagement

Appendix

Highest Priority
ESG Topics• Data Privacy & Cybersecurity• Risk Management• Board Composition & GovernanceHigh Priority
ESG Topics• Executive Compensation & Incentives• Employee Health & Wellbeing• Support for Small- & Medium-Sized Enterprises• Policy Influence• Labor Practices & Human Rights

Priority
ESG Topics• Supply Chain Responsibility• Business Ethics & Integrity• Human Capital Management• Anti-Financial Crime & Anti-Money Laundering• ESG & Sustainable Finance Products• Transparency & Reporting• Employee Engagement & Satisfaction• Diversity, Equity & Inclusion• Customer Relationship Management• Decarbonization & Climate Strategy• Innovation & Technology• Community Engagement• Natural Resource Management

INFLUENCE ON OUR BUSINESS SUCCESSI N C R E A S I N G I M P O R TA N C E

13Nasdaq 2022 Sustainability Report

Stakeholder
Engagement
As a signatory to the Business Roundtable
Statement on the Purpose of a Corporationand supporter of the World Economic Forum’s
Stakeholder Capitalism Metrics initiative, Nasdaq
views accountability to our stakeholders as both amark of good governance and a critical componentof our operational success. We seek to manage ourbusiness with the goal of delivering sustainable,
long-term value to a wide array of stakeholders,
including our shareholders.

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Stakeholder Groups

How We Engage

Topics of Interest Related to ESG

Clients and Customers

•
•
•
•
•

Conferences, workshops and meetings
Satisfaction surveys
Educational resources and tools
ESG products and advisory services
Investable indexes

ESG indexes, asset managers’ ESG investing policies and clients'
strategies, board and management ESG oversight, ESG policy and program
development and disclosure guidanceCommunities and
Non-Governmental
Organizations (NGOs)

•
•
•
•

Nasdaq Purpose
Nasdaq Foundation
Nasdaq GoodWorks
Nasdaq Entrepreneurial Center

Community outreach, employee volunteering and giving and resources
for women and under-represented minority entrepreneurs and diverse
investors

Employees and Leadership

•
•
•
•
•
•
•

Company intranet, meetings and town halls
Engagement surveys
Employee networks and focus groups
Training and development programs
Performance reviews
SpeakUp! Line (whistleblower)
Internal newsletters

People and culture (including the alignment of our culture with our
corporate strategy), effort to shape our corporate culture, succession
planning, talent development, diversity, equity and inclusion initiatives andthe future of work

Executive Leadership• Corporate ESG Steering Committee (executive leaders)• Nominating & ESG Committee (Board members)• Management Compensation Committee (Board members)

Ongoing discussions and decision-making related to all ESG topics,
including Nasdaq’s human capital management, Nasdaq’s key environmental
policies, programs and strategies and Nasdaq’s ESG strategy and reporting

Government and Regulators• Public policy debates• Active education and engagement with elected leaders• Engagement through associations

Nasdaq’s advocacy focuses on policies affecting the capital markets

Market Participants

•
•
•
•

Investable indexes
Webinars, meetings and events
ESG data and analytics
Marketing

ESG indexes, asset managers’ ESG investing policies and strategies, ESG
investing trends and ESG risk and portfolio impact for asset owners

Group calls, meetings and presentations
Investor roadshows and conferences
Annual Meeting of Shareholders
Engagement with investment stewardship teams
Investor perception study

Investor ESG priorities, ESG policy and program development, ESG
disclosure and people and culture

Shareholders

•
•
•
•
•

Throughout the year, we engage with a diverse setof stakeholders across a variety of ESG topics.

GRI 2 | GRI 2-29
WEF Core 3

14

Nasdaq 2022 Sustainability Report

Introduction
Introduction

Environmental
Innovating for Environmental
SocialSustainability
GovernanceDiversityESG Solutions

Advancing GovernanceCommunity Engagement
Excellence

Appendix
Appendix

Our Strategic Approach to Sustainability
Nasdaq’s approach to ESG is focused both internally and externally. Internally, we manage our businesses’ ESG-related risks and opportunities and thecorresponding impact we have as an organization across our own operations. Externally, we focus on the impact we have on the world through our ESG-related
products and services that support our clients’ objectives, as well as the wider economic and societal impact across other parts of our business and operations.

Corporate Sustainability

Solidify

SupportEnableExternal Impact

Solidify

SupportEnableSolidify business resilience and drive
sustainable growth by effectively
managing and reducing long-term risks
and advancing ESG practices across ourentire organization

Support our clients by providing relevant
insights and innovative technology
designed to help them effectively
navigate the evolving ESG ecosystem
and minimize complexity and friction

Enable positive outcomes through theeconomic and societal impact inherent
to the solutions and services of our wider
business operations

Environmental

ESG Products and Services

Reduce our environmental impact byaddressing climate risk and reducing ourenvironmental footprint

Enable clients to effectively navigate the
ESG ecosystem through our marketplace
and technology solutions, reporting tools
and data analytics capabilities

Address complex market and societal
challenges through our comprehensive
suite of solutions aimed at combating
financial crime

SocialCreate a workplace culture of belonging
and inclusion by attracting, training andretaining a diverse workforce

Anti-Financial Crime

Market Platforms

GovernanceModernize markets globally by providing
exchanges, emerging marketplaces andother critical ecosystem participants inthe capital markets with institutionalgrade technology

Maintain robust corporate governancepolicies and practices

PurposeDrive impact across our community
through our purpose-led initiatives todrive economic progress

15

Nasdaq 2022 Sustainability Report

SOLIDIFY Our Resilience
From an organizational perspective,
Nasdaq’s approach to ESG is focused onsolidifying our business resilience anddriving sustainable growth by:• minimizing our environmental footprint
and focusing on market-led innovation
towards a net-zero future;• solidifying our position as a destination
for talent, including through deepening
our culture of diversity, equity andinclusion and building an organizationthat provides its people with the tools
and platform to maximize their impact on
the world; and• continuing to lead in advancing governancebest practices both as they relate to ourown organization as well as supporting
stakeholders across their ecosystems inadvancing their governance practices.

SUPPORT the Ecosystem
ESG Products and Services
Nasdaq’s position at the intersectionof markets and technology provides us
with a unique perspective on how the
ESG ecosystem is evolving. It also offers
compelling opportunities to support
our clients as they navigate their own
sustainability journeys through a suite of
ESG-related solutions designed to minimize
complexity and reduce friction.

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Our ESG-focused capabilities suite
encompasses a wide range of marketplace,technology, data & analytics products andsolutions that clients leverage as they
develop, execute and advance their own
ESG strategies and platforms.

ENABLE Positive Outcomes
PurposeThrough Nasdaq’s Purpose, we drive acomprehensive program that supports ouroverarching corporate purpose of advancing
economic progress for all. As part of thisstrategy, Nasdaq’s Purpose work is focusedon reimagining investor engagement,
diversifying entrepreneurship and fostering
financial education and inclusion.

Nasdaq’s position at theintersection of markets andtechnology provides us witha unique perspective on how
the ESG ecosystem is evolving

16

Nasdaq 2022 Sustainability Report

Introduction

Anti-Financial Crime (AFC)Financial crime is a complex, global challenge that isfundamentally linked to deeper economic and societal
challenges, ranging from poor investor education and limitedbanking options to terrorism financing and human trafficking.
The United Nations estimates that up to $2 trillion — or five
percent of global GDP — is laundered by criminals each year.
Through Nasdaq’s AFC Division and our acquisition of Verafinin 2021, we leverage the most innovative technology andcapabilities to support financial institutions and the wider financial
ecosystem in more effectively detecting and combatting financial
crime. By increasing effectiveness in rooting out financial crime,
our business drives positive economic and societal benefits
associated with uncovering and mitigating the criminal activities
that financial crimes support and finance.
We currently provide AFC solutions globally for more than
50 marketplaces, over 15 regulators and more than 2,300
financial institutions in North America. In 2022, we expanded
the ability of financial institutions to detect financial crime bylaunching new capabilities in crypto and other digital assets.
We also provided group and direct training to regulators andfinancial institutions on emerging behaviors such as fraud andmarket abuse in crypto products.
Market Platforms
Technology is the conduit to financial inclusivity and greater
opportunities for all. In addition to owning and operating 18
exchanges in North America & the Nordics, the Market Platforms
division provides exchanges, emerging marketplaces and othercritical ecosystem participants in capital markets and digital assets
with institutional-grade technology that is based on Nasdaq’s
market expertise and road-tested technology. We modernize
markets globally to drive sustainable and trusted financial networks

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendixthat successfully attract high quality and international liquidity, fueljob growth and advance economic progress.
Our marketplace technology is currently deployed in more than
25 emerging economies.
Through our majority stake ownership in Puro.earth, we leadthe world’s first carbon crediting platform for engineered carbon
removals, which brings suppliers of net-negative technologies
together with companies with residual emissions. Aligned with
our efforts to accelerate carbon markets’ maturity, in 2022 wepartnered with Singapore-based Climate Impact X to provide
trading technology that helps unlock price transparency
and liquidity in the voluntary carbon market, empoweringbuyers to acquire high-quality carbon credits specific to theirrequirements. Furthermore, we initiated a partnership between
Climate Impact X and Puro.earth to increase access to quality
nature- and technology-based carbon removal credits to
support the development of dynamic carbon portfolios andaddress growing demands in the voluntary carbon market.
To further our aim of modernizing infrastructure to meetthe demands of tomorrow’s markets, in December 2021, we
announced a multi-year partnership with Amazon Web Services
to migrate our North American exchanges to the cloud. The
first market migration of Nasdaq MRX went live in 2022, with a
10% performance boost alongside high standards for resiliency,
security and capacity. Nasdaq’s cloud migration will offer clientsa migration blueprint enabling them to combine public cloudand edge computing to modernize their operations, improveagility and adjust to industry dynamics in their countries andregions. This is demonstrated through our support of the Bolsa
Electrónica de Chile’s (Chilean Stock Exchange) upgrade tomove its operations to the cloud via Nasdaq’s SaaS-based
Marketplace Services Platform.

Provide Anti-Financial Crime solutions globally to:50+ 15+ 2,300+
Marketplaces

Regulators

Financial institutions in North America

Our marketplacetechnology is
deployed in 25+
emerging economies

SDG 9 SDG 10

17

Nasdaq 2022 Sustainability Report

Introduction

We are committed to responsibly managing our business andoperations to further advance the United Nations Sustainable
Development Goals (SDGs). We have identified the following
seven goals where we are likely to have the most direct impact
given the nature of our business.

SDG

5

Gender Equality
Achieve gender equality
and empower all womenand girls

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Our Support of the United Nations
Sustainable Development Goals
Nasdaq’s public commitment to sustainable
development and socially responsible
business practices began in 2012 at the
Rio+20 conference, where Nasdaq was
one of five founding signatories to the UN
Sustainable Stock Exchange (SSE) Initiative.
SSE is a peer-to-peer learning platform for
exploring how exchanges, in collaboration
with investors, regulators and companies,
can enhance corporate transparency — andultimately performance — on ESG issues andencourage sustainable investment. Since
2012, Nasdaq has also been a proudparticipant of the United Nations Global
Compact (UNGC), a non-binding pact thatencourages businesses to adopt sustainable
and socially responsible practices, report on
their progress and advance the achievement of
the United Nations Sustainable Development
Goals (SDGs). The SDGs are 17 global goals
and 169 targets adopted by all UN Member
States in 2015 with the aim of achieving abetter and more sustainable future for all. At
Nasdaq, the SDGs help guide our sustainability
strategy and connect our efforts to an
ambitious global agenda.

In 2022, we conducted an assessment to
identify the SDGs where we believe Nasdaq islikely to have the greatest impact. Leveraging
SDG mapping and disclosure guidance from
GRI, SASB, SSE and the UNGC, we assessed thealignment of the SDGs in relation to the highpriority topics identified in our ESG Materiality
Assessment, our corporate ESG objectives
and activities, our products and services andour industry. We identified and prioritized
seven SDGs where we are likely to have themost direct impact. We are reporting ourprogress against our corporate and commercial
objectives that support these seven SDGs.

Nasdaq's ESG Material Topics & Objectives

Nasdaq's SDG-Aligned Initiatives & Activities• Diversity, Equity, & Inclusion• Human Capital Management​• Labor Practices​
Objective: Achieve greater balance of gender in our workforce (SDG Target 5.5)

Diversity, Equity & Inclusion​• Increased percentage of women in the workforce• Launched “Accelerate(Her)”, a program designed to develop female talent at Nasdaq• Community Engagement
Objective: Address systemic barriers faced by under-represented communities in their efforts to g
​ enerateand sustain wealth (SDG Target 5.5)​

The Nasdaq Foundation ​• The New Investor Initiative is a portfolio of programs focused on tackling overlooked barriers for people of color,
particularly women of color, to participate in the capital markets ​• The Quarterly Grant Program provides a wide range of support for Black, Latino and Indigenous founders andentrepreneurs, with a strong focus on women​• Transparency & Reporting
Objective: Support listed companies through their implementation of Nasdaq’s Board Diversity Rule withoutreach and education (SDG Target 5.5)

Board Diversity Support ​• Nasdaq has established relationships with 12 organizations to support Nasdaq-listed companies that choose to meetthe recommended board diversity objective in their search for highly qualified, diverse, board-ready candidates

GRI 2 | GRI 2-22

18

Nasdaq 2022 Sustainability Report

SDG

8

Decent Work and Economic Growth
Promote sustained, inclusive andsustainable economic growth, full andproductive employment and decent
work for alll

9

Industry, Innovation and Infrastructure
Build resilient infrastructure, promote
inclusive and sustainable industrializationand foster innovation

10

Reduced Inequalities
Reduce inequality within andamong countries​

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Nasdaq's ESG Material Topics & Objectives

Nasdaq's SDG-Aligned Initiatives & Activities• Support for Small- & Medium-Sized Enterprises ​Objective: Lead the shift towards more sustainable and inclusive capital markets(SDG Target 8.3)

Capital Access Platforms: Listings (U.S. & Nordics) ​• More than 500 companies currently listed on First North Growth Market in the Nordics​• Encourage growth of small- and medium-sized enterprises through all-inclusive fee structure​• Maintain largest percentage of small cap companies of any U.S. exchange (over 70%)​• Hosted 10 IPO-focused events, both in-person and virtualObjective: Improve inclusion, access, and knowledge in entrepreneurship(SDG Target 8.3)

Appendix

Nasdaq Entrepreneurial Center ​• Provided more than 1,000 hours of education to over 18,000 entrepreneurs• Supported small businesses in more than 80 emerging economies• Innovation & Technology​• Support for Small- & Medium-Sized Enterprises ​Objective: Modernize markets globally to drive sustainable and trusted financial
networks that successfully attract international liquidity, fuel job growth andadvance economic progress (SDG Targets 9.3 and 9.a)Market Platforms: Marketplace Technology | European & North American Trading Services​• Modernize infrastructure to meet the demands of tomorrow’s markets​• Accelerate carbon markets’ maturity• Diversity, Equity, & Inclusion• Human Capital Management ​Objective: Achieve greater balance of gender, race and other underrepresented
groups in our workforce composition at all levels (SDG Target 10.2)

Diversity, Equity & Inclusion​• Increased percentage of underrepresented groups in our workforce• Graduated second cohort of the Emerging Leaders Program• Diversity, Equity, & Inclusion
Objective: Become a partner of choice for diverse suppliers (SDG Target 10.2)

Supplier Diversity• Achieved our goal of increasing the percent of addressable spend1 from U.S.-based diverse-owned suppliers• Added Sustainability-linked amendment to credit facility, reinforcing commitment to supplier diversity• Community Engagement• Support for Small & Medium Sized Enterprises​
Objective: Improve inclusion, access and knowledge in entrepreneurship(SDG Target 10.2)

Nasdaq Entrepreneurial Center• Served over 18,000 entrepreneurs – 70% minority founders and 69% female founders​• Diversity, Equity, & Inclusion ​Objective: Support diversity and inclusion transparency across the institutional asset
management landscape (SDG Target 10.2)

eVestment ​• Launched the Diversity & Inclusion (D&I) questionnaire which gives asset managers an opportunity to provide narrative
commentary on their firms’ D&I initiatives and, for those that permit such reporting, D&I statistics on their portfolio team• Anti-Financial Crime & Anti-Money Laundering ​Objective: Build a safer ecosystem that protects investors, communities andinstitutions from nefarious activity, helps fuel confidence in the system and creates
equitable opportunities across a broader set of investors (SDG Target 10.5)

Anti-Financial Crime​• Improve the monitoring of global financial markets and institutions by providing advanced AFC solutions in fraud,
AML, market abuse, detection and prevention​• Drive education of regulation and monitoring best practices for financial institutions and investors

1 “Addressable Spend” refers to Nasdaq’s spending in which we have the discretion to directly select the provider of the goods and services and/or benefit from a sourcing event, including, for the
avoidance of doubt, money that is directly spent by Nasdaq as well as money that is spent by one of Nasdaq’s suppliers in relation to a contract or work authorization with or for Nasdaq.

19Nasdaq 2022 Sustainability Report

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Environmental

SocialGovernance

ESG Solutions

Community Engagement

SDG

Nasdaq's ESG Material Topics & Objectives

Nasdaq's SDG-Aligned Initiatives & Activities

12• ESG & Sustainable Finance Products​
Objective: Support our clients as they manage
climate risks, stakeholder engagement, andtransparent reporting and disclosure(SDG Target 12.6)

Capital Access Platforms: Corporate ESG Solutions​• Nasdaq Listings (IPO) package, approved by SEC in 2021, provides newly public companies in the Nasdaq Global Selectand the Nasdaq Global markets with complimentary sustainability reporting support• Launched the ESG Solutions Resource Center• Decarbonization & Climate Strategy​
Objective: Support carbon neutrality and carbon
net-zero programs (SDG Target 13.2)

Decarbonization & Climate Strategy ​• Science-based targets were reviewed and approved by SBTi ​• Implemented Environmental Management System (EMS)​

Responsible Consumption and Production
Ensure sustainable consumption and production patterns

Objective: Encourage Nasdaq’s suppliers to reduce
their GHG emissions through CDP disclosure andsetting science-based targets (SDG Target 13.2)

13

Climate Action
Take urgent action to combat climate change and its impacts• ESG & Sustainable Finance Products​
Objective: Accelerating maturity of carbon andsustainability-related initiatives (SDG Target 13.3)

Objective: Lead the shift towards more sustainable
and inclusive capital markets (SDG Target 13.3)

17

Partnerships for the Goals
Strengthen the means of implementation and revitalize
the Global Partnership for Sustainable Development• Community Engagement ​Objective: Participate in, and represent Nasdaq
with, key associations and partnerships to continue
the effort on advancing ​our sustainability strategy,
as well as for consistent and transparent ESG
reporting (SDG Target 17.16)

Appendix​ valuating & Engaging our Supply Chain
E• Engaged top suppliers to disclose their environmental data through CDP's Climate Change Survey, resulting in recognition andinclusion in CDP's Supplier Engagement Leaderboard• Added Sustainability-linked amendment to our credit facility, reinforcing commitment to supplier-focused science-based target
Market Platforms: European Trading Services​• Puro.earth, the world’s first carbon crediting platform for engineered carbon removals​• Green Equity Designations aims to enable visibility and transparency for investors with two voluntary designations​• Nasdaq Sustainable Bond Network Investor Portal connects issuers of environmental, social and sustainable bonds with investors• Nasdaq Sustainable Debt Markets highlights sustainable investment opportunities to investors with a green,social or sustainable investment agenda​​

Capital Access Platforms: Investment Intelligence​• ESG Indexes integrates ESG criteria into the index methodology, with some indexes designed purely
as ESG and others designed with ESG criteria as an overlay to a broader investment thesis​• Nasdaq’s ESG Data Hub offers investors and other stakeholders easy access to a wide range of unique and comprehensive ESG
data sets
ESG Memberships• Business Roundtable (BRT) “Purpose of a Corporation”• CDP Supply Chain Global Sustainability Standards Board (GSSB)• Science Based Targets initiative (SBTi)• Task Force on Nature-Related Financial Disclosures (TNFD) Forum• United Nations Global Compact (UNGC)• United Nations Principles for Responsible Investment (PRI)• United Nations Sustainable Stock Exchange (SSE) Initiative• United Nations Sustainable Stock Exchange (SSE) Advisory Group on Carbon Markets• World Federation of Exchanges (WFE) – Sustainability Working Group20

Nasdaq 2022 Sustainability Report

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Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Sustainability-Linked
Finance
On March 29, 2023, Nasdaq completed asustainability-linked amendment to our $1.25 billion
revolving credit facility. The sustainability-linked
credit facility amendment ties certain fees on thecredit facility to Nasdaq’s performance against two
ESG-related key performance indicators (KPIs) – oneenvironmental and one social. Our borrowing costs
may be increased, or decreased, depending on ourachievement of each of the KPIs. Our environmental
KPI reinforces Nasdaq’s commitment to SDG 13,“Climate Action” by encouraging our suppliers to set
their own Science-based Targets to help address
the global, existential issue of climate change.
Our commitment to addressing SDG 10, “Reduced
Inequalities”, was reinforced through our social
KPI which focuses on increasing the percentage
of our U.S. spend with diverse-owned suppliers toeconomically empower people of all backgrounds
and support the communities we represent.

Social KPI

Environmental KPI

KPI: Percent of Addressable Spend from
U.S.-Based, Diverse-Owned Suppliers

KPI: Percent of Addressable Spend with Supplierswith Science-Based Targets

Description: Percent of Nasdaq’s U.S. suppliersby spend covering purchased goods and services
and capital goods from certified diverse-owned
businesses

Description: Percent of Nasdaq’s suppliers byspend covering purchased goods and services andcapital goods that set or commit to set sciencebased targets

Sustainability Performance Target: Increase
U.S.-based addressable spend from U.S.-based,diverse-owned suppliers by 0.5 percentage points
annually for five years from a 2022 baseline of 6.8%

Sustainability Performance Target: 70% of
suppliers by spend covering purchased goods andservices and capital goods will set or commit tosetting science-based targets by 2027
21

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Appendix

Solidify Our BusinessResilience and Drive
Sustainable GrowthNasdaq 2022 Sustainability Report

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Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Environmental: Solidifying Our Commitment

2022 Highlights

At Nasdaq, we are committed to advancing
progress toward a net-zero future. In 2022, weachieved carbon neutrality for the fifth year ina row and our net-zero emissions targets wereverified and approved by the Science Based
Targets initiative, setting the roadmap for our nearand long-term emissions reduction strategy.
Our corporate sustainability strategy is driven byminimizing our climate impact and exposure toorganizational climate risk. We remain focusedon looking across our business to identify
ways to bring measurable change to ourclimate impact. As we look ahead to 2023 andbeyond, we are reaffirming our commitment
to minimizing our environmental footprint andsolidifying our business against long-termclimate risks.
Ann Dennison
Chief Financial Officer, Nasdaq

884%additional offices achieved
green certification

Completed the implementation of arecognized international EMS for Nasdaq
Real Estate & Data Centerof our global energy
consumption is procured
through pre-negotiatedrenewable power contracts

37.9%

Net Zero

The SBTi verified and published our sciencebased targets to achieve net zero by 2050

of our suppliers had set orcommitted to set science-basedtargets by the end of 2022

Achieved CDP climate A List andrecognized by CDP for supplierengagement leadership
Became a TNFD Forum member
23Nasdaq 2022 Sustainability Report

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SocialGovernance

ESG Solutions

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Appendix

Decarbonization and Climate Strategy
Nasdaq’s climate strategy endeavors to reduce
our greenhouse gas (GHG) emissions, mitigate
our corporate climate and biodiversity risk
exposure and promote awareness throughout our
supply chain. This strategy is driven by our two
separate but linked environmental programs:• Carbon neutrality program: By calculating ourannual carbon footprint, procuring renewable
power and investing in high-quality carbon
offsets, Nasdaq has achieved carbon neutrality
for the fifth consecutive year.
• Carbon net-zero program: By driving initiatives
that are designed to optimize and reduce
emissions across Nasdaq’s entire business
operations and supply chain, we aim toachieve our short-term and long-term netzero science-based targets, which have beenverified and approved by the Science Based
Targets initiative (SBTi).
In executing these programs, our focus is on:• Solidifying our climate metrics and targets• Reducing and neutralizing our GHG emissions• Aligning corporate strategies to support
reaching our net-zero targets• Prioritizing natural resource management• Evaluating and engaging our supply chain

Solidifying Our Climate Metrics
and Targets
The reduction of energy consumption, energy
demand and corresponding GHG emissions
throughout our business operations and supply
chain is a high priority for Nasdaq. GHG emissions,which are related to energy consumption
throughout the global organization, is an area that
Nasdaq can control and impact through changes inoperations, strategy and policies.
For the fifth consecutive year, Nasdaq has
calculated its GHG emissions in line with theGreenhouse Gas Protocol Corporate Accounting
and Reporting Standard. A comprehensive
review of Scope 1, Scope 2 and applicable
upstream and downstream Scope 3 emissions
has been performed and addressed. We continue
to navigate and manage the evolving climate
disclosure requirements and standards andcontinue to improve the quality of our data
to be less reliant on assumptions.
The key priorities of our carbon neutrality andnet-zero programs are to:• engage our value chain to report their relevantmaterial GHG emissions and to set their own
science-based targets;• proactively procure renewable energy for ouroffice space and data center portfolio;• purchase Renewable Energy Certificates(RECs) from projects that are less than five
years old and feed power into the sameenergy distribution network as our operations
to replace any fossil fuel electricity power
consumed (indirectly mitigating the release of
GHG into the atmosphere); and• purchase high-quality, nature-based Carbon
Offsets from projects that focus on carbon
removal or biodiversity to neutralize theassociated GHG emissions related to our Scope 1
and Scope 3 categories (indirectly mitigating therelease of GHG into the atmosphere) to achievecarbon neutrality.
In a continuous effort to drive our emissions
down and contribute to a more sustainable
world, Nasdaq has executed the initiatives on
the following pages.

• reduce the energy consumption, corresponding
GHG emissions and waste generation of
our global operations through thoughtful
sustainable initiatives and strategies;

GRI 305
SDG 1324

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Appendix

Science-Based Targets
In 2022, our near- and long-term sciencebased emission reduction targets wereapproved by SBTi. In addition, SBTi verified
and published our 2050 net-zero sciencebased target.
Our validated science-based targets are
the focus of our net-zero program. We are

implementing multiple programs that will
drive down our GHG emissions as we workto achieve these ambitious targets. This
program works in parallel with our carbon
neutrality program. As we reduce our overall
GHG emissions, we also aim to neutralize
the remaining emissions as we work
towards becoming a net-zero company.

Our Climate Strategy
2021
Our Baseline

Absolute market-based GHG emissions
78,876
0.5
Scope 1 + 2
1

Scope 3

1

Total:
78,877 MT CO2e

2027

2030

70%

100% 50% 100%of our suppliers byspend will set theirown science-basedtargets by 2027

reduction of ourabsolute Scope 1 andScope 2 emissions

2050

reduction of ourabsolute Scope 3
emissionsrenewable
electricity
through 2030

GRI 305
WEF Core 8

100%

100%

maintain a minimumof 100% absolute
Scope 1 and 2
emissions reduction

2021 GHG emissions were recalculated to add Category 3 and Category 8 in order
to align to our SBTi-approved base year.

Continue to procure 100% renewable electricity

Net Zero95%

reduction of ourabsolute Scope 3
emissions

Suppliers that have set or committed to set science-based targets

37.9%

70%
2022

2027

25

Nasdaq 2022 Sustainability Report

Introduction

Our GHG Emissions

Environmental

Social• Scope 1: moved corporate card gasoline purchases fromScope 3 to Scope 1

ESG Solutions

Market-based GHG Emissions by Scope (MT CO2e)1

2022
1

2021

Community Engagement

2021

2020

Scope 1

52.5

0.5

2.7

Scope 2

149--

Scope 386,65878,8764

55,570

Scope 3
Percentage ofTotal GHG Emissions

Total

88,86078,87755,57399.76%

2020

According to GHG Protocol Scope 2 Guidance, market-based method quantifies Scope 2 GHG emissions based on GHG emissions emitted by thegenerators from which the reporter contractually purchases electricity bundled with instruments, or unbundled instruments on their own.

Percentage of total market-based
GHG emissions

Location-based GHG Emissions by Scope (MT CO2e)2• Scope 2: included steam and district heating, resulting in
an increase in market-based emissions

1. Purchased Goods & Services• Scope 3: included acquisitional operational data from
Verafin (acquired 2021) and Metrio (acquired 2022)

2022

2021

Scope 152.5

0.5

Scope 2
Scope 3
Total

2020

2022

WEF Core 7

2021

68.17%

2. Capital Goods

7.25%

3. Fuel- & Energy-Related Activities

2.32%

2.7

5. Waste Generated in Operations

0.21%

17,094

18,813

3

21,665

6. Business Travel

16.49%

86,65878,8764

55,5707. Employee Commuting

1.52%

77,238

8. Upstream Leased Assets

0.26%

13. Downstream Leased Assets

0.17%

103,805

97,69015. Investments
2020

2

According to GHG Protocol Scope 2 Guidance, location-based method quantifies Scope 2 GHG emissions based on average energy generation emission
factors for defined locations, including local, subnational or national boundaries.

3

Our 2021 Scope 2 location-based emissions were recalculated from our prior reported 2021 Scope 2 emissions. For our 2022 and recalculated 2021 Scope 2
location-based emissions, we implemented a new, updated emissions methodology using location-specific emission factors for each of our U.S. locations, rather
than a U.S. average emission factor.

42021 GHG emissions were recalculated to add Category 3 and Category 8 in order to align to our SBTi-approved base year.

GRI 305 | GRI 305-1 | GRI 305-2 | GRI 305-3 | GRI 305-5

Appendix

Breakdown of Scope 3 GHG Emissions(MT CO2e)2022

The charts on the right summarize the global data for
Nasdaq’s office space, data centers, onsite combustion,
upstream goods and services, capital goods, fuel and energy
related activities, waste generation and recycling/compost
diversion, business travel, employee commuting, upstream
and downstream leased assets and investments for thereporting period January 1, 2022 through December 31, 2022.
The charts on the right also reflect a further breakdown by
category of our Scope 1, Scope 2 and Scope 3 emissions,with the following methodology enhancements from our2021 report, due to improved transparency of data:

Governance

Scope 3 Sub-Total

3.37%
99.76%

26

Nasdaq 2022 Sustainability Report

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ESG Solutions

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Appendix

Reducing and Neutralizing
Our GHG Emissions
Procuring Energy from Renewable Sources
We conduct an annual review of our energy
consumption and emissions to evaluate how ourenergy reduction and sustainability initiatives aretracking against our internal goals and our new
science-based targets.
Nasdaq has procured 100% renewable electricity
for our office space and data center portfolios
since 2018. Sourcing renewable electricity is amajor focus for Nasdaq and is an integral feature in
our site selection process for new office and data
center locations, lease negotiations and electricity
contracts. For 2022, our pre-negotiated renewableenergy contracts accounted for over 84% of ourannual global consumption, of which virtual powerpurchasing agreements account for 48% of our
total consumption.

For the remaining 16% of electricity that is notacquired through pre-negotiated renewable energy
contracts, Nasdaq purchases RECs that meet ourquality requirements, which include:• having corresponding requisite attestations andverifications;• providing new renewable energy to the grid thathas been consumed by each Nasdaq office; and• being less than five years old with high priority
given to those projects in operation for less than
one year, to stimulate demand for new renewableenergy projects in the local power grid.
This resulted in Nasdaq reducing our market-based
Scope 2 GHG emissions (excluding steam anddistrict heating) to zero on an annual basis in 2022.
Our total energy consumption in 2022 decreased bynearly 14% from 2021, due to our optimized leasing
strategy and improved data quality.

100
Nasdaq has procured%

renewable electricity for our office space anddata center portfolios since 2018

GRI 302 | GRI 302-4 | GRI 305 | GRI 305-527

Nasdaq 2022 Sustainability Report

Introduction

The chart below reflects a summary of how
we neutralize our Scope 1, Scope 2 andScope 3 emissions.

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Scope 1 + 2

Our energy consumption data was collected by thefollowing methods (listed in priority):

Scope 3

1. Full year actual data for the Nasdaq space consumption.

Pre-purchased Renewable Power (MT CO2e)​

2. Full year actual data for the entire building in which the
Nasdaq space is located. Nasdaq’s proportionate shareof the consumption was then calculated using occupied
square footage within the building.

Renewable Energy Credits (RECs) and Offset Purchases (MT CO2e)​3. Where data was unavailable, estimates were calculatedusing assumptions on the office location, amenities within
the space, square footage and headcount.

2022

2021

2020

Scope 2 Electricity Consumption (in MWh)

86,65864,20078,8764

70,787
9%59,90055,570

Our location-based
GHG emissions​1

Net emissions ​
0 (MT
CO e)

21,66818,8143

17,147

54,10460,77749,2722

2(13,611)(3,536)(17,159)(14,840)(3,974)(17,147)(4,509)(18,814)3(21,668)

Our mitigations(55,570)

10,096

10,01010,628

2022

2021

2020

Nasdaq purchased RECs

(78,876)4Pre-negotiated Renewable Energy contracts(86,658)
In the charts above:
Note: Scope 2 and Scope 3 Category 8 Upstream Leased Assets emission data for 2020 & 2021 is restated, as we moved our indirect natural gas and diesel related emissions to Scope 3 to align to best practices.

•

Percentage of total operational spending on energy (most recent reportingyear): more than 5% less than 10%.

1

Gross emissions before landlord & data center operator renewable energy supply factors are applied.

•

No energy was sold in the reporting periods.

2

Net emissions after landlord & data center operator renewable energy supply factors and Nasdaq REC & CO purchases are applied.

•3

Our 2021 Scope 2 location-based emissions were recalculated from our prior reported 2021 Scope 2 emissions. For our 2022 and recalculated 2021 Scope 2 location-based emissions, we implemented a new, updated emissions methodology using locationspecific emission factors for each of our U.S. locations, rather than a U.S. average emission factor.

Source of Conversion factors used: https://www.eia.gov/energyexplained/unitsand-calculators/energy-conversion-calculators.php•

42021 GHG emissions were recalculated to add Category 3 and Category 8 in order to align to our SBTi-approved base year.

Whenever possible, Nasdaq’s actual energy consumption was included in thecalculation; otherwise, a proportional share was determined using occupied
square footage. If energy data was completely unavailable, estimates werebased on office location, amenities, square footage and headcount.

GRI 302 | GRI 302-1 | GRI 302-2 | GRI 302-3 | GRI 305 | GRI 305-528

Nasdaq 2022 Sustainability Report

Introduction

Reducing Energy Intensity

SocialGovernance

Project

2022

2021

2020

Absolute energy consumption (MWh)(Scope 1 & 2)1

64,88275,14362,364

Number of full-time employees2

6,377

5,814

4,830

Energy intensity(per full-time employee)3

10.2

12.9

12.9

1

Includes fuel, electricity, heating and cooling.

2

Employee headcount as of December 31, 2022, 2021 and 2020.

3

Energy intensity is calculated as a ratio between Nasdaq's absolute energy
consumption and the number of full-time employees.

Despite an increase in employees in 2022, our energy intensity
declined due to a reduction in energy consumption.

Aperam
BioEnerbia
BiocharKatingan
PeatlandRestoration
andConservation
Project

Standard

Location
BrazilIndonesia

Our Carbon Offset Strategy
Our focus is to reduce our GHG emissions to reach our science-basedtargets, but we also strive to ensure that we are neutralizing our residual
emissions as we transition to becoming net-zero. As part of our carbon
neutrality program, we plan to:• establish a long-term strategy for our estimated net-zero residual
emissions and build a portfolio of high-quality engineered carbon
dioxide removal projects with proven permanence that have beencertified by the ICROA-endorsed Puro standard; and• offset Nasdaq’s remaining emissions as we move towards achieving
our science-based net-zero target, utilizing a combination ofhigh-quality nature-based carbon offset projects that preserve or
enhance carbon storage and strengthen the biodiversity of ourglobal forest networks verified by ICROA-endorsed standards.
GRI 302 | GRI 302-3 | GRI 305

ESG Solutions

Community Engagement

Appendix

In 2022, we purchased carbon offsets to neutralize our 2022 residual GHG emissions from projects as summarized below:

The following table shows our energy intensity as the absoluteenergy consumption per full-time employee.
Energy Intensity Ratio

Environmental

Project Type

Description
The project uses biomass residue to sequester carbon
dioxide in biochar for use in soil amendment in forest
crops and it runs a charcoal operation with emissions
control in the northeast region of Minas Gerais, Brazil.
The addition of biochar helps improve soil properties andwater retention in the soil. The project also supports social
development programs for local farmers.
The project aims to tackle climate change by restoring andprotecting peatland ecosystems, enhancing biodiversity
and offering local people sustainable sources of income.
In addition to peatlands preservation, this project aims
to reforest through three programs: community-led
agroforestry, fire break implementation and intensive
reforestation. The team will grow saplings in on-site
nurseries and conduct regular maintenance to improve therate of tree survival.

Degraded
Grassland
Afforestation
Project

Colombia

The project aims to recover degraded grasslands in
Vichada, Colombia, through afforestation activities. The
project plans to promote connectivity between ecosystems
by improving soil quality, enhancing biodiversity andreducing freshwater withdrawal. The project generates
benefits for the local population by providing employment
opportunities and education.

TambopataBahuaja
Biodiversity
ReservePeru

The project aims to conserve high biomass density tropicalforest against deforestation in Tambopata National Reserve(RNTAMB) and the sector of Bahuaja-Sonene National
Park (PNBS) located in Madre de Dios region. The project
is located in a key biodiversity area and endemic bird area,with high ecological and sociocultural significance.

Wetland Restoration andConservation (WRC)

Reduced Emissions from
Deforestation and Degradation (REDD)

Afforestation, Reforestation
and Revegetation (ARR)

Biochar29

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Aligning Corporate Strategies to
Support Reaching Net Zero
Reducing Nasdaq’s GHG emissions andmeeting our ambitious short- and long-termscience-based targets will require initiatives
that reach across all of our businesses andoperations. We are therefore reviewing
Nasdaq’s corporate strategies in an effort toalign our existing processes and policies tosupport our environmental ambitions.

Environmental Management System(EMS)
Nasdaq is committed to prioritizing
environmental efforts and ensuring
sustainability is considered in our major
operations. To help drive this progress
towards a more sustainable future, wehave implemented an EMS to govern ourReal Estate and Facilities (REF) and Data
Center (DC) portfolios, which are major
contributors to Nasdaq’s carbon footprint.
Our EMS follows the structure informed
by ISO14001, commonly recognized as
the leading EMS international standard.
The purpose of our EMS is to provide aframework to assist Nasdaq in achieving
our environmental goals through consistentreview, evaluation and improvement of ourenvironmental performance.
Key processes covered by the EMS include:• Environmental requirements during site
selection for new offices/data centers,
including access to renewable energy,
access to mass transit, locations withgreen/energy/ISO certifications• Green leasing clauses• Global standards for design andperformance• Operational and maintenance proceduresand policies• Sustainable procurement and energy
efficiency• GHG standards for suppliers

Green Certifications
As part of our sustainability strategy,
Nasdaq is committed to the wellbeing of ouremployees and the communities in which
we operate. In 2022 we achieved:• LEED Gold Interiors D + C (Design andConstruction) Certification in one of ouroffice spaces.
• LEED Gold O + M (Operations andMaintenance) Certification in seven of ouroffice spaces.
As of 2022, 55% of Nasdaq global officespace by square foot (12 office locations)is now in a Green Certified office. This is a
37 percentage point increase over 2021. We
aim to have all key offices green certified
by 2030.

Sustainable Leasing Strategy
Optimizing efficiency and overallsustainability of our real estate portfolio
continues to be a key focus. In 2022, we
continued our sustainable leasing strategy
which assesses factors such as easy accessto mass transit, guaranteed certifiable
renewable energy supply and thoughtful
rightsizing of the portfolio.

GRI 305

30

Nasdaq 2022 Sustainability Report

Business Travel
Business travel is a significant contributor to
Nasdaq’s GHG emissions. In 2022, business
operations returned to pre-pandemic levels
and we experienced an increase in businesstravel, approaching levels similar to those of
2019. In 2023, we continue to engage with
our travel partners and explore strategies
and opportunities to reduce our businesstravel GHG emissions.
The Scope 3, Category 6 business travelincludes emissions from planes, trains,
hired vehicles, taxis and car services andhotel stays.

Employee Commuting
Nasdaq’s strategy to encourage employees
to return to the office has also resulted in
an increase in employee commuting GHG
emissions. Nasdaq is continuing to mitigate
these emissions through our hybrid work
program and sustainable leasing strategy
to lease space near public transport andto provide employees benefits designed toencourage the use of public transport. We
also continue to improve and mature thecarbon footprint data sources and processesof Nasdaq’s carbon footprint analysis.
Through innovative technologies, we seek abetter understanding of our emissions andcorresponding data sources in an effort to
reduce the reliance on assumptions. We

Introduction

Environmental

continue to evolve by staying up to datewith the latest resources and best practices,and having our entire Scope 1, Scope 2 andScope 3 GHG emissions third party verified
via limited assurance.

Waste
Waste reduction, recycling and compost
diversion are key priorities for Nasdaq in theoperation and management of its facilities.
Throughout our office space lifecycle, wehave built processes that focus on reducing
waste, reusing products and the sustainableprocurement of products required tomaintain our facilities and employees.
These processes include green leasing
terms for landlord waste management,
office construction/renovations, productprocurement, maintenance and cleaning andoffice decommissioning.
We have also implemented several
programs to reduce our waste and improvethe data accuracy for our landfill anddiversion rates. These include:• continuing to achieve green certificationin our office spaces, which includes
implementing policies around sustainableproduct procurement, reusing products
and recycling waste;

SocialGovernance

ESG Solutions

Community Engagement

Appendix• implementing our EMS to ensure that
we focus on sustainable operationalpurchasing strategies, construction andoffice decommissioning; and• conducting waste audits in our key
offices to gain greater detail into howmuch waste we generate and divert fromlandfills.
Refer to page 83 for data regarding ourwaste consumption.

Nasdaq’s Green TeamOur Global Green Team brings together
Nasdaq employees who are passionate
about the environment, publishes regularknowledge-based resources and works
to drive sustainable initiatives throughour local offices and communities.
The Green Team aims to instill a cultureof environmental advocacy and action
through educational sessions that focus onsustainable practices, informative webinars
and community outreach. Nasdaq supports
the Green Team’s commitment to creating
positive change throughout the Company
and our neighboring communities as we driveto achieve our longer-term net-zero goals.

Our Global Green Team brings
together Nasdaq employees
who are passionate about theenvironment, publishes regularknowledge-based resources
and works to drive sustainable
initiatives through our local
offices and communities.

GRI 305 | GRI 306 | GRI 306-2 | GRI 306-3 | GRI 306-4 | GRI 306-5

31Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Evaluating and Engaging Our Supply Chain
Nasdaq’s supply chain is the main
contributor to our carbon footprint,
accounting for over 60% of our total 2022
GHG emissions. Evaluating and engaging
with our key suppliers and entire value chain
is key to reaching our net-zero targets. In
2022, GHG emissions from our suppliers
decreased by nine percent from 2021, duelargely to improved data quality. As ourprocesses mature and acquired companies
transition on to Nasdaq systems, we expect
to rely less on assumptions.
Nasdaq also encourages its suppliers to
adopt sustainability and environmental
practices in line with our published
Environmental Practices Statement and the
Nasdaq Supplier Code of Ethics (SupplierCode). In 2022, Nasdaq asked new
suppliers and existing top suppliers to attest
to our Supplier Code, confirming they havepolicies and practices consistent with the
Supplier Code or, to the extent they do not,will adhere to the applicable standards in
the Supplier Code.
To the extent practical and feasible,
we expect suppliers to provide us withinformation to support our reporting andtransparency commitments related tosustainability and environmental impacts.
In 2022, Nasdaq became a CDP Supply
Chain corporate member and began
requesting that our top suppliers disclose
their environmental data through CDP’s
Climate Change survey. For our efforts,
we were recognized by CDP as a Supplier
Engagement Leader in 2022, placing usamong the top eight percent of companies
for taking action to measure and reduceclimate risk within our supply chain. We set
a target to request even more suppliers
to respond to the survey, including our
top 150 suppliers in 2023 and top 200
suppliers in 2024.
As part of our near-term science-based
emissions reduction targets approved by
the SBTi in 2022, we pledged that 70% of
our suppliers by spend, covering purchased
goods and services and capital goods, will
set science-based targets by 2027. As of
year-end 2022, 37.9% of our suppliers had
set or committed to set science-basedtargets. As we request more suppliers to
respond the CDP Climate Change survey,
we will encourage them to set sciencebased targets of their own.

8%

Among the topof companies for taking
action to measure andreduce climate risk within
our supply chain

We commit that 70% of our
suppliers by spend, coveringpurchased goods and services
and capital goods, will set
science-based targets by 2027.

37.9%
of our suppliers had set orcommitted to set sciencebased targets as of yearend 2022

GRI 204 | GRI 305 | GRI 308 | GRI 308-1 | GRI 308-2
SDG 1332

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Natural Resource Management
We undertook a company-wide
engagement to assess the nature-relatedrisks and opportunities for Nasdaq,
evaluating where business responsibility
sits within the organization and analyzing
our impacts and dependencies on nature.
Though our office spaces are leased, weare looking to reduce our natural resource
consumption and the wider externalities
generated through our operations.
Currently, this is undertaken through:• the tracking of commercial water andwaste usage and outputs, which haveresulted in conservation initiatives;• sustainability certifications for Nasdaq’s
buildings, which incorporate restrictions
around greenfield sites, waste andrecycling; and• renewable energy procurement and wider
emissions reduction activities.

Water
Nasdaq consumes water in our officespace that is leased from commercial
office buildings and data centers. We
therefore do not have a significant
impact on water systems.
Water conservation initiatives are pursued
to align with Nasdaq’s ESG goals, which
aim to reduce consumption across all
resource categories. This is achievedby obtaining green certifications that
install water efficient infrastructure andreduce wastewater. We also reduce water
consumption via sustainable leasing
strategies that reduce the reliance on older,less water efficient equipment and byconsidering factors in our supply chain andsourcing decisions.

Taskforce on Nature-related Financial
Disclosure (TNFD)
In 2021, 40 organizations came together
to establish the TNFD. The TNFD is built
on the pillars and principles of the TCFD,
following the structure of governance,
strategy, risk management and metrics
and targets. In 2022, we joined the TNFD
Forum to support the development of the
new disclosure framework focused onnature and biodiversity. Nasdaq supports
TNFD’s market-led approach to developing
a framework that is “scientifically rigorousand easy to adopt for both businesses andfinancial institutions.”

24%

decrease in water consumption in 2022
due to water conservation initiatives

Due to these initiatives, in 2022 Nasdaq
decreased our water consumption by 24%
compared to 2021.
Refer to page 83 for additional details
regarding our water consumption.

GRI 303 | GRI 303-1 | GRI 303-5 | GRI 304
WEF Core 9 | WEF Core 10

33

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

AppendixSocial: Solidifying Progress for All

2022 Highlights

Our people are foundational to Nasdaq’s success.
We focus our efforts to build a leading global employer
brand that attracts, hires and retains the very besttalent, allowing us to serve the market’s current needs
while evolving to meet new ones.
In 2022, we launched our Culture Book, which tells
the unique story of what it’s like to work and grow at
Nasdaq. It shares Nasdaq’s mission, vision, values andunwavering purpose — to advance economic progressfor all. Whether we’re working in the office or from
home, these guiding principles align and inspire us
every day. The Culture Book offers current and future
employees a roadmap to learn how they can makea difference, achieve their goals and advance theircareers with us.
At Nasdaq, we remain dedicated to fostering an
inclusive, equitable environment where our colleagues
can bring their true selves, do meaningful work andthrive in a supportive, vibrant community.
Bryan Smith
Chief People Officer, Nasdaq

Established an executive
Diversity Steering Committee

Launched our newly designed
career website

4.3%
2021

6.8%
2022

Tied a component of our seniorleadership team’s executive
compensation to our DE&I goals

Launched Conscious Inclusion
and Inclusive Leadership trainingclasses for all employees

Increased the percent inaddressable spend with U.S.-based
diverse-owned suppliers from 4.3%
in 2021 to 6.8% in 2022

Introduced the Accelerate(Her)program, designed to develop female
talent at Nasdaq

100

%

113

executive team participation in our“Inclusive Leadership” training

new diverse suppliers added
through our supplier diversity
initiatives, which represents over$1.4 million in supplier spend

34

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Diversity, Equity and Inclusion
Nasdaq’s People Team is responsible for
ensuring equitable employment and careerdevelopment practices across the company,
as well as fostering a culture of inclusion
and belonging for all.
During 2022, we focused on educating our
employees on diversity topics, including
optional diversity training for all employees
and required inclusive leadership training
for all managers. In 2021, global managers
completed our “Conscious Inclusion” training,a training focused on learned best practices
and tactics to create a more inclusive
environment. In 2022, we expanded thistraining to the non-manager population,
where general employees completed
over 2,700 hours of Conscious Inclusion
training. Our managers completed over 820
hours of training in “Inclusive Leadership,”a course designed to drive awarenessaround opportunities for inclusion, allyshipand advocacy. One hundred percent of our
executive team participated in the “Inclusive
Leadership” training.
In 2022, we saw close to a one
percentage point increase in both our
female population (globally) and ourBlack, Hispanic/Latinx and multi-cultural

employees (in the U.S.). In 2023, we willagain strive to gain at least one percentage
point in representation of female andunderrepresented employees. Additionally,
Nasdaq has established an executive
Diversity Steering Committee to focus ondiversity at the executive level.

for all VP and above roles. In addition, we
surpassed our 2022 goal of a 10 percentage
point increase in diverse executive
succession candidates, increasing diversity
in succession candidates by 11 percentage
points. We plan to continue these initiatives
in 2023.

In 2022, we committed to holding our seniorleadership responsible for their business’s
participation in diversity development
efforts. We will continue this endeavor
in 2023, tying a component of executive
compensation to achieving our Company’s
diversity, equity and inclusion goals. These
goals include: driving a culture of inclusion
by ensuring women and employees ofdiverse backgrounds are participating in
our formal mentoring program; fostering
diversity for all externally posted Vice
President (VP) and higher roles byinterviewing diverse slates of candidates;
and continuing to focus on increasing
diversity in executive succession plans.

We have also adopted new initiatives
to increase a culture of inclusion in theworkplace, including broadening ourmentoring programs and introducing arenewed focus on sponsorship. In 2022,
we examined key people processes(e.g., hiring, development, performance
management, advancement) to ensure
they are equitable and allow all Nasdaq
employees similar access to develop
professionally and advance in theircareers. In response to this examination,
we launched our new Accelerate(Her)program, specifically designed to develop
high-potential female talent at Nasdaq by
matching small cohorts of participants to
Nasdaq’s most senior executive women forcareer coaching and sponsorship.

As part of our Company’s commitment toachieve greater diversity in our workforce
over time, we reached our 2022 goal
to present at least one qualified female
candidate as part of the candidate slate

GRI 405 | GRI 406
SDG 5 SDG 10

35

Nasdaq 2022 Sustainability Report

Workforce
Employee Networks at Nasdaq

Introduction

Environmental

Social¡Adelante Nasdaq!
¡Adelante Nasdaq! is our global employee
network dedicated to employees who have aninterest in Hispanic/Latino culture and heritage.

Asian Professionals at Nasdaq (APAN)
Nasdaq’s Employee Networks are a key componentof our diversity strategy. They provide a forum
for our employees to come together on shared
topics and interests and are open to everyone who
wishes to participate. Our Employee Networks
celebrate our diversity and foster a sense ofinclusion and belonging that strengthens ourculture. The networks aim to empower employees
to succeed with initiatives that promote professional
advancement, provide networking opportunities
and build mentorship, advocacy and support to ourcommunities. Participants in Nasdaq’s 11 networks
represent approximately 37% of our employee
population. Our employee networks are supportedby the executive leadership team and each
employee network has an executive sponsor.

Governance

ESG Solutions

Nasdaq Administrative Professionals
Network
This network enables administrative
professionals across all geographies anddemographics to collaborate with each other onshared topics, best practices and interests.

APAN is a platform to support and empower ourcommunity of members through professional
development and social engagements.

The Out Proud Employees of Nasdaq (TheOPEN)

Global Green TeamThe OPEN represents the LGBTQ+ employees,
their families and allies.

Global Green Team brings together Nasdaq
employees who are passionate aboutsustainability and making a positive impact on
the environment and planet.

Global Link of Black Employees (GLOBE)
GLOBE provides a platform for connection andcollaboration for employees who have an affinity
or interest in Black, African, African American andWest Indian culture at Nasdaq.

Nasdaq Accessibility Network
Nasdaq Accessibility Network is for Nasdaq
employees who have disabilities themselves,
who have family members with disabilities or who
have an interest in accessibility topics.

Parents and Caregivers
This network, which is for Nasdaq employees
who identify themselves as parents or caregivers,
aims to foster a workplace where employees feel
confident that they can have a rewarding career
while being fully committed to their family.

Community Engagement

Appendix

Veterans@Nasdaq
This network brings together those employees
who have served or are currently serving in the
military, who are part of military families and theirsupporters.

Women in Nasdaq (WIN)WIN brings women and their allies at Nasdaq
together to provide community, growth andlearning opportunities, networking and visibility
that supports the advancement of women at
Nasdaq personally and professionally.
For more information, visit our Diversity, Equity,
and Culture webpage.

Software Engineer Employee Network(SEEN)
This network is for Nasdaq colleagues who are
enthusiastic about Software Engineering. The
group seeks to bring like-minded individuals
together by fostering a sense of community
for software professionals in a fast-paced
technology environment.

GRI 405 | GRI 406

36

Nasdaq 2022 Sustainability Report

Introduction

Environmental

Global Workforce
We continue to provide transparent disclosure of
our global workforce as well as further disclosure ofethnicity where available.

GlobalWorkforce(excluding
Verafin)Nasdaq is committed to equitable pay for all peoplein our workforce. That commitment is embedded
within our multifaceted compensation program. As
part of that program:Total Numberof Employees1

SASB TC-SI330a.3
WEF Core 11 | WEF Core 12 | WEF Core 13

Community Engagement

GlobalWorkforce(including
Verafin,acquired in
2021)

2021

Male

Male

63.3%

63.9%

64.9%

FemaleFemaleFemale

36.4%

35.9%

34.9%

Undisclosed

Undisclosed

Undisclosed

0.3%

0.1%

0.2%

Non-Binary

Non-Binary

Non-Binary

-%

-%

-%

5,448

5,038

4,830

White

Hispanic

Asian

Two or MoreBlack

Pacific
Islander

64.6%

2020

Male

Total Numberof Employees1

2022

Appendix

U.S. Workforce by Racial Ethnicity

16.1%
7.9%

2.8%

Asian

Two or MoreBlack

Pacific
Islander16.5%

NativeAmerican

0.1%

Undisclosed

2.6%

0.3%

Hispanic

65.4%
2021

5.7%

White

7.5%

• When appropriate, we take action based on thesesystems and annual process.

GRI 2-7 | GRI 202-1 | GRI 405-1 | GRI 405-2

2022

ESG Solutions

2022

Gender Pay Gap Analysis• We have an annual process in place to run a
regression analysis on gender (globally) andrace/ethnicity (in the United States), assessing
employee base pay and total compensation (base+ bonus + equity).

Governance

Global Workforce by Gender

Unless otherwise indicated, social data tables inthis report exclude employees of non-wholly owned
consolidated subsidiaries.

• We have systems in place to establish and review
pay upon hire, promotion and role changes within
the Company.

Social5.8%
2.1%

NativeAmerican

0.2%

Undisclosed

2.4%

0.2%

2021

Male

Male

63.7%

64.6%

FemaleFemale

36.0%

35.3%

Undisclosed

Undisclosed

0.3%

0.1%

Non-Binary

Non-Binary

-%

-%

6,377

5,814

1 Total includes employees of non-wholly owned consolidated subsidiaries excluded from percentage calculations.

White

Hispanic

Asian

Two or MoreBlack

Pacific
Islander

66.6%
2020

16.2%
7.4%

5.1%

2.0%

NativeAmerican

0.1%

Undisclosed

2.3%

0.1%

Note: The U.S. reporting on Race and Ethnicity follows the U.S. Department of Labor’s EEO-1 reporting
standards. The races and ethnicities reported are American Indian or Alaska Native, Asian, Black or African
American, Hispanic or Latino, Native Hawaiian or Other Pacific Islander, Two or More Races and White.
Please note that totals may not add up to 100% due to rounding to the closest tenth decimal point.

37

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Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Human Capital Management
Our people are the primary driver of our
success. Nasdaq is committed to attracting
top talent and retaining, developing andmotivating our employees. Throughout
2022, we added new professional
development opportunities, as well as new
platforms leveraging artificial intelligence(AI), to bring internal job opportunities andshort-term developmental projects directly
to employees.

the outcomes included in each manager’s
year-end performance evaluation.

During 2022, we launched the Career Hub(part of our enterprise Human Resources
technology platform) to provide AIenabled, customized career development
recommendations and planning resources
for every employee. The Career Hub
provides recommendations for training
programs, mentors, informal networking
and short-term gigs via the TalentMarketplace where employees can findproject opportunities outside of their dayto-day roles to develop their skills directly
and encourage mobility through visibility ofinternal open job requisitions.

In 2022, we continued to assess thecurrent state of our talent, define the skills
needed to achieve our strategic goals,
set performance objectives to measureindividual growth, provide opportunities forskills development and utilize the process toadvance talent equitably.

Performance objectives were created foreach of our managers that measured them interms of their managerial effectiveness, with

Talent Development
Nasdaq supports the development of
employees through each importanttransition in their careers – as new
entrants to the organization, as developing
professionals, as managers of teams and assenior leaders of our global organization.

To identify our talent needs, Nasdaq makes
extensive use of people analytics data in
the following areas: measuring employee
performance, strategic workforce planning,
identifying flight risks in critical roles anduncovering individual and organizational
skills gaps.
Nasdaq’s Performance Management
program was established to enhance

the job performance and professional
growth of each employee. Under thisprogram, every employee is asked tocreate a professional development planfor themselves each year in concert with
their manager and record this plan in our
performance management software.
In addition to providing mechanisms forongoing feedback throughout the year,
managers informally assess their employees
in writing during the mid-year period andcomplete a formal year-end performance
review by the end of each calendar year. In
2022, we introduced a five-point manager
assessment regarding each employee’s
behavior relative to our Core Values as partof the year-end review to reinforce theimportance of our culture.
Both parties meet to discuss thewritten assessment, which is recordedinternally. These performance evaluations
become part of the employee’s formal
personnel record and serve as a factor forconsideration in internal job transfers andadvancement decisions.

GRI 401 | GRI 404-3

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SocialGovernance

ESG Solutions

Community Engagement

Appendix

The goal and purpose of the performance review program is to:• ensure each employee has a clear understanding of what is expected by their manager;• align the activities of each employee to their respective Business Unit goals and to Nasdaq’s annual goals;• discuss the employee’s job performance with respect to individual performance objectives and skills development; and• inform each employee of the knowledge and skills they must acquire or improve to grow in the present job, move into a lateral role oradvance at Nasdaq.
All employees received a performance rating. The table below indicates the percentage of employees who received both a performance
rating and written comments on their performance for the 2022 reporting period.

20221

1

2021

2020

Employee Performance
Ratings with Written
Comments, by Gender

Male

Female

Total

Male

Female

Total

Male

FemaleTotal

Workforce

90%

90%

90%

93%

94%

93%

86%

86%

86%

Calculation includes full-time, regular employees hired prior to October 1, 2022; excludes Verafin and Metrio employees.

Note: Review is optional for VP level employee and above.

Nasdaq conducts an annual executive succession planning and advancement exercise to help us align senior employees with the rightopportunities across the Company, as well as mitigate risk for the Company in the event of unexpected turnover. The output is reviewed
by the Board. In 2022, we piloted a wider talent review process for our employee population below the executive level. All direct reportsof every VP and above were rated on performance and potential to identify our high potential, high performing talent, their development
needs and our plan to close any gaps to achieve Nasdaq’s strategic goals. We also introduced a global framework to make the promotion
process more consistent and transparent at the AVP level and above.

GRI 404-3

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Nasdaq 2022 Sustainability Report

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Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Career Development
For individual career development, we
operate under the philosophy of the70/20/10 Learning Principle, whereroughly 70% of professional development
happens through learning on the job; 20%
through developmental relationships likecoaching and mentoring; and 10% throughformal training. Nasdaq offers a variety ofprofessional development experiences via
multiple channels and modes that support
diverse learning styles.
We have invested heavily in professional
development for our employees, creating
a dedicated Career Development internal
website that serves as a central point
for dozens of career resources. These
resources include offering access to morethan 26,000 professional in-person andonline employee development programs
and job-specific training, providing
tuition assistance to employees enrolled
in degree-granting academic programs,
holding internal career fairs and career
networking programs and providing oneon-one mentoring.

As a technology organization, we recognizethat building critical, cutting edge technicaland financial skills is paramount and as such
we have relationships with institutions ofhigher education, such as Massachusetts
Institute of Technology (MIT), as well as
corporate institutions such as the Amazon
Web Services (AWS) Skills Guild, Microsoft’s
AI Business School and the Council on
Foreign Relations.
Recognizing the critical role our people
managers play in developing and retaining
our talent, in 2022 Nasdaq offered overa dozen leadership and management
development programs for every level ofleader in the firm. In 2022, we also launched
the Nasdaq Manager Forum. With our CEO
as the facilitator, the Nasdaq Manager
Forum is a series of webcasts that provides
practical advice from leaders at every levelacross the organization on a wide range of
people management topics.

leadership roles through a curriculum basedon building business acumen, leadershipskills, peer networking and senior leader job
shadowing opportunities.
In 2022, we provided Conscious Inclusion
training for all employees and an Inclusive
Leadership program for our managers. We
customized our developmental program
for underrepresented talent, including
executive mentoring and accelerated
leadership development programs. In 2022,
we also graduated the second cohort ofour Emerging Leaders Program, whichcurrently serves members of our Black andAfrican American community. Our Emerging
Leaders Program will be expanded in 2023
to serve additional members of historicallyunderrepresented communities in theirprofessional development.

The table below highlights the average number of training hours
for full-time employees for 2022.
Training1

2022

2021

2020

Average number of training hours

19.4

17.2

15.3

Average amount per employee spent on training

$320

$320

$280

103,083

86,423

72,950Total hours of employee training
1

Includes full-time regular employees; excludes Verafin and Metrio employees.

In 2023, we launched our flagship High
Potential program, LEAD, which will focus
on preparing mid-level managers for future

GRI 404 | GRI 404-1 | GRI 404-2
WEF Core 16

40

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Attracting and Retaining Talent
To attract, recruit and retain talent, Nasdaq has continued to invest in building a best-in-class employer brand and candidate experience.
In September of 2022, we launched our newly designed career website to provide a much better candidate experience. As a result of thisinitiative, we experienced a one percent increase in conversions (number of website visitors applying to a role at Nasdaq) versus 2021, a
27% increase in site traffic and a 51% increase in time spent on our career website in the fourth quarter of 2022 as compared to the fourth
quarter of 2021.
As part of our People Promise candidate experience campaign, we have introduced four pillars: Unparalleled Support, Work That Shapes
Tomorrow, Diversity & Equity, and Making a Change for Good. Our People Promise pillars help Nasdaq differentiate itself from our talent
competitors. It explains what we offer our employees and presents a compelling reason why people should join us.
As part of our awareness-building efforts and to diversify our candidate pool, Nasdaq attended AfroTech 2022, the largest conference forBlack people in technology with over 15,000 attendees. In partnership with the National Society of Black Engineers (NSBE) and the Societyof Hispanic Engineers (SHPE), we hosted 12 events and reached over 500 Black and Hispanic students at Georgia Institute of Technology,
Howard University, University of Maryland, University of Toronto, Columbia University, the Colorado School of Mines and Massachusetts
Institute of Technology – educating students about our internship program and career opportunities.
In 2022, we reached our goal to minimize diverse employee attrition by keeping our under-represented minority (URM) voluntary attrition
rate in the U.S. under 10%, an effort we plan to continue through 2023. As part of our 2023 talent attraction and recruitment efforts, we are
increasing our partnerships with diversity organizations, minority search firms and schools to ensure we continue to increase diverse slatesof qualified candidates.
Through senior leadership engagement and amplifying our voice both internally and externally, in 2023 Nasdaq plans to expand our efforts
to create content that tells our unique story, creates brand awareness and attracts talent.
Employee Turnover

2022

2022

2021

2021

2020

2020

NumberRate2

NumberRate

NumberRate3

Total Workforce – employee turnover1

575

11.0%

568

11.5%

464

7.0%

Total Workforce – new hires

1,061

1

Voluntary attrition.

22022 percentage calculations exclude 907 Verafin employees due to internal timing of data integration.

3

Turnover was unusually low in 2020 due to the COVID-19 Pandemic.

1,082

856

GRI 401-1
WEF Core 17

41

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

Employee Engagement and Satisfaction
Through Nasdaq’s diversity, equity andinclusion work, our resources are aligned
to support our culture and engagement
strategy. During 2022, Nasdaq continued
to conduct employee sentiment surveys
bi-annually. We realized significant
improvements across many categories,
including leadership, management andculture, compared to average scores overthe past four years.
Nasdaq seeks to drive progress in
employee engagement in a multitude ofways, but especially by focusing on therole of the manager. Each manager at
Nasdaq with four or more direct reports
receives a custom engagement reportfor their team containing the anonymous,
aggregated responses of their teammembers, how their team compares to
Nasdaq as a whole and industry averages
and where their team may be higher orlower than the average. Nasdaq’s People
Team partners with our managers and

GRI 401
SASB TC-SI-330a.2

Business Unit leaders to identify areas ofopportunity and to develop action plans, forinstance a focus on career development,
communication and/ or recognition.
Nasdaq maintains several employee
recognition programs, including a peer-topeer recognition reward, where peers or
managers can award recognition points thatcan be exchanged for goods or services.
These awards are published to the entire
company by means of a social feed so thatthe recognition can be amplified.
Nasdaq continues to build knowledge of ourculture focused on economic growth andprosperity for all. In 2022, we crystallized
our culture by publishing our first Culture
Book, an inside look at what it’s like to workat Nasdaq so employees can thrive as theywork towards our Company’s goals.
We renewed our Humans@Nasdaq videoseries in 2023 to highlight internal talentat Nasdaq. This storytelling series featuresindividuals from across Nasdaq, showcasing
and cultivating our corporate culture.
The series also serves as a tool to reachpotential talent outside our Company.
In 2022, over 90% of our employees
participated in our engagement survey. Our
engagement scores demonstrate Nasdaq’s
high level of employee engagement and weare continuously reviewing our initiatives
to identify opportunities to improve. In our
employee engagement survey, questions
have a five-point scale in which Nasdaq
employees can choose which option bestaligns with their feedback. We also offer
a comments section and encourage freeform responses to any question where
the employee wishes to provide more
context. These comments are all reviewed,
aggregated and shared (anonymously)
where applicable.

ESG Solutions

Community Engagement

Appendix

Out of the 92% of our employees who
participated in our engagement survey:*92

are proud to work for Nasdaq

90%

would recommend Nasdaq
as a great place to work

81

feel they belong at Nasdaq

%

%

87

believe Nasdaq is advancing
Diversity, Inclusion and Belonging

85%

believe people from all backgrounds haveequal opportunities to succeed at Nasdaq%*October 2022 Employee Survey

42Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Promoting Health and Wellbeing
At Nasdaq, we recognize and value theimportance of health and wellbeing.
We understand the impact health andwellbeing has on productivity andemployee engagement. We also recognize
the important role that our leaders playin creating a culture of wellbeing andbelonging. As part of our employee
engagement survey, we measure “mymanager genuinely cares about mywellbeing” and we have seen favorable
scores of over 90% over the past 12 months.
We also recognize the importance ofinvesting in our people. Our employees,
their families and their communities areimportant to us. We offer a holistic suite ofprograms, benefits and resources, known
as You&Q, to meet our employees where
they are – in their lives and career journeys.
Whether our employees are focused onprioritizing their health, building theirwealth, caring for their family, growing theircareer or connecting with their community,
our You&Q program has something to help
them prioritize and focus on their wellbeing.

• Prioritize Your Health: Everyone has
different healthcare needs which is
why we offer a diverse set of benefits
and wellbeing programs to optimize
health including medical, dental, vision
coverage, health care flexible spending
accounts, Employee Assistance Program(EAP), the Calm app, membership to
Peloton and access to Sleepio, a digital
sleep improvement program.
• Build Your Wealth: In addition to basesalary and incentive plans, we arecommitted to rewarding our employees’
contributions and helping them have aprosperous future through the following
programs: employee stock purchaseplan, short-term and long-term disability,
401(k) match, student loan program andvarious other employee perks.
• Caring for Your Family: We recognize
and value that employees have a life
outside of Nasdaq and offer the following
programs to support our employees’
family life: fertility coverage, paid parental
leave, adoption/surrogacy assistance andoptional pet insurance.
• Grow Your Career: Our robust learning
opportunities and tuition reimbursement
enable our employees to advance theircapabilities and grow in their career.

• Connect with Your Community: We
encourage our employees to engage,
support and empower their local
community through our robust networkof employee resource groups, charitablematching program and paid time off tovolunteer.
You&Q is designed to be both inclusive
and representative of the diverse needs of
our employees, with the ability to evolve tomeet the changing needs of Nasdaq andour workforce. As an example, in responseto the pandemic, enhancements suchas caregiver support, back-up childcare,hybrid work schedules and flex days wereintroduced. Flex days (currently six peryear) are dedicated days for employees
to care specifically for their own mental
health and wellbeing. These programs are
now here to stay as a result of the positive
feedback from our employees.
In 2023 and beyond, we are continuing tofocus on enhancing a culture of belonging
and wellbeing at Nasdaq.
For more information about our employee
benefits, visit our Career website.

GRI 201 | GRI 201-3 | GRI 401 | GRI 401-2
WEF Core 15

43Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Nasdaq Employee Testimonials

Making an impact anddoing purposeful work
Director, Software Engineer

An innovative anddynamic work
environment

It’s really cool to work on projects

Senior Director, Technical Writerthat have such an immense global

When I think about what makes
Nasdaq unique compared to otherWellbeing at Nasdaq

Manager, Surveillance

employers, it’s that we get to work at

Senior Director, Project Manager

When I talk about Nasdaq with

the intersection between software

Being a mother of two andfriends and family I usually discussdevelopment and finance. We getraising my boys almost entirely

the great opportunities that we haveto learn both parts and we needwithin my time here in thewithin the organization. We have big

to understand the business of ourorganization, I can truly speak

market tech operations, a huge legal

customers deeply to make sure weto the awesome work-life

presence, we have people in sales

develop the functions they need tobalance that Nasdaq makes

and other critical systems that we’rebe successful. The other part is thatpossible. Our teams have a

responsible for. There is definitely

the financial industry is moving so“family first” mentality andsomething here for everyone.

quickly so it keeps us on our toes

benefits like flex days andand it’s never boring at Nasdaq.

hybrid working make it easier to

impact. Knowing that your efforts

A world of opportunities

are changing things around theworld is motivating. It’s also great
to work on diverse teams with folksfrom around the world and travel tothose places to see the products inaction. Seeing users actively engage
in what you produce creates a
deeper level of commitment.

focus on priorities both at home
and at work.
44

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Supplier Diversity
We recognize that increasing the use ofdiverse suppliers enables us to create
value across our business. A diverse
supply chain strengthens our operations,
supports our communities and enhances
our client experience. Nasdaq’s Supplier
Diversity Program is a crucial componentof our commitment to equity, diversity
and inclusion. We work with qualified
businesses owned by diverse individuals
or groups, members of the LGBTQ+
community, people with disabilities, womenand veterans. Nasdaq encourages its
suppliers to not only promote a diverse andinclusive workplace, but also engage withdiverse-owned businesses.
Nasdaq’s Supplier Code of Ethics reflects
our extended commitment to growing
diversity in our supply chain. In 2022,
Nasdaq engaged new suppliers and existing
top suppliers to attest to our Supplier Codeof Ethics, confirming they have policies
and practices consistent with ours and to
the extent they do not, will adhere to theapplicable standards in our Supplier Codeof Ethics.

In 2022, we set multi-year supplier diversity
goals, in terms of both spend amount andnumber of diverse suppliers, to demonstrate
our dedication to building long-term,
sustainable growth in the program.
Nasdaq set a goal to increase the percent
in addressable spend from U.S.-based
diverse-owned suppliers from 4.3% in 2021
to 5.3% in 2022 – a goal we out-performed– achieving 6.8% in diverse supplier spend.
We did so by working with supplier diversity
organizations, exercising policies in ourcontingent worker program and leveraging
configurations on our retail purchases
platform to promote diverse suppliers.
Through these initiatives and others, we
added 113 new diverse suppliers, which
represents over $1.4 million in supplierspend in 2022. To further demonstrate ourdedication to grow our Supplier Diversity
Program in 2023, Nasdaq has a goal to:• increase the percent of addressable
spend with diverse-owned businesses by
0.5 percentage points to at least 7.3% and113

new diverse suppliers added, which
represents over $1.4 million in supplierspend in 2022

• increase the number of addressable
diverse-owned suppliers by 6% from the2021 baseline of 121 to 128.

GRI 204 | GRI 414 | GRI 414-1 | GRI 414-2
SDG 1045

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Governance: Solidifying Corporate Excellence

2022 Highlights

Nasdaq’s sound corporate governance structure is key
to how we help create stronger economies, encourage
more equitable opportunities and contribute to a moresustainable world to help our stakeholders reach theirfull potential.
Our commitment to governance excellence starts atthe top with Nasdaq’s Board of Directors. The Board
continues to lead with a strong governance frameworkand is motivated to implement best practices in linewith achieving strategic objectives, communicating
effectively and overseeing a culture of compliance andrisk management.
We believe that our long-standing and recognizedtradition of principled, ethical and forward-looking
governance practices, transparent disclosures andoverall Board effectiveness benefits our stakeholders,
including our shareholders, employees, clients and thecommunities around us.
John A. Zecca
Chief Legal, Regulatory & Risk Officer, Nasdaq

1#"Best Proxy Statement – Large Cap" in
Corporate Secretary Magazine’s 2022
Corporate Governance Awards

35+

ESG-focused Investor Engagements

Developed our first formal climate risk
assessment utilizing guidance from leading
reporting frameworks

2

diverse members added
to the Nasdaq Listing andHearing Review Council

4

diverse directors added to
Nasdaq’s Exchange Board

46

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Corporate GovernanceOur governance framework focuses on theinterests of our shareholders. It is designed
to promote governance transparency
and ensure our Board has the necessary
tools to review and evaluate our business
operations and make decisions that are
independent of management and in the bestinterests of our shareholders. Our goal is toalign the interests of shareholders, directors
and management while complying with, or
exceeding, the requirements of The Nasdaq
Stock Market and applicable law.
This governance framework establishes thepractices our Board follows with respect tooversight of:• corporate sustainability, including our
ESG program and environmental andsocial initiatives;• our corporate strategy for long-termvalue creation;• capital allocation;• risk management, including risks relating
to information security and the protectionof our market systems;• our human capital management program,
corporate culture initiatives and ethics
program;• our corporate governance structures,principles, and practices;• Board refreshment and executive
succession planning;• executive compensation; and• compliance with local regulations andlaws across our business lines andgeographic regions.
In 2022, we hosted over 35 investor
engagements, exceeding our year-overyear goal of increasing ESG investor
engagement. In addition, we maintained
a low-risk rating on governance from themost significant rating agencies, included
targeted disclosure on ESG in our 2023
Proxy Statement to further emphasize
our commitment to transparency andprioritization of ESG-related topics, andcontinued our program of director education
on ESG topics. We aim to continue these
efforts in 2023.

35+

ESG-focused Investor
Engagements

GRI 2 | GRI 2-9 | GRI 2-1247

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialBoard Diversity

Board Diversity Matrix

10
FemaleMale

Non-Binary

Undisclosed

4

6

-

-

African American or Black

1

1

-

-

Alaskan Native or Native American

-

-

-

-

Asian

-

-

-

-

Hispanic or Latinx

-

-

-

-

Native Hawaiian or Pacific Islander

-

-

-

-

White

3

5

-

-

Two or More Races or Ethnicities

-

-

-

-

LGBTQ+----

Did Not Disclose Demographic Background

-

-

-

-

Directors

Community Engagement36%(As of April 28, 2023)

Part I: Gender Identity

ESG Solutions

Appendix

Director Nominee Highlights

The Board values diversity in evaluating new candidates and seeks to incorporate a wide range of
attributes across the Board of Directors and on each of our Committees. The following matrix is provided inaccordance with applicable Nasdaq listing requirements and includes all directors as of April 28, 2023.

Total Number of Directors

Governance4 out of 11
are women

Part II: Demographic Background36%

4 out of 11 are Racially/
Ethnically Diverse%

10 out of 11 are
Independent91

GRI 2-9 | GRI 405 | GRI 405-1
WEF Core 248

Nasdaq 2022 Sustainability Report

Introduction

Corporate Behavior
Given their relevance to our business, our industry andassociated risks, we provide a brief description of ourapproach and policies for the following:• Ethics and Compliance• Anti-Corruption• Labor Practices and Human Rights• Anti-Financial Crime & Anti-Money Laundering• Cybersecurity, Information Security and Privacy• Public Policy• Risk Management

Nasdaq leaders strive
to create an ethicalculture in which
employees understandour commitment tointegrity as foundational
to our Purpose, Vision,
Mission and Values andfeel comfortable raising
issues or concerns.

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Ethics and Compliance
The Nasdaq Ethics and Compliance Program is designed tomeet or exceed applicable standards, including guidelines
published by U.S. and European regulators. Nasdaq
embraces good governance by striving to hold ourselvesto the highest ethical standards in all interactions. Our
Global Ethics Program supports and promotes meaningful
implementation of the Code of Ethics throughout ourbusiness. In 2022, we furthered the use of automation
and analytics in supporting compliance programs to drive
effectiveness and reduce risk, completed updates of ourCode of Ethics and related policies to make them moreengaging to our employees and address evolutions inour business and enhanced employee training programs
through additional focus on targeted topics.
Our Global Ethics program is based on industry-leading
practices and led by our Chief Legal, Regulatory &Risk Officer and is supported by a cross-functional,
geographically diverse team, with oversight by our Audit& Risk Committee. External compliance experts are also
regularly consulted. The Nasdaq Ethics Program provides
values-based guidance, heightens compliance risk
awareness, strengthens decision-making and drives soundbusiness performance through its five pillars: Executive and
Board Leadership; Policies and Controls; Risk Assessment;
Outreach and Training; and Monitoring, Audit and Response.

The Nasdaq Code of Ethics, or the Code, in conjunction
with other policies, procedures, standards and handbooks,
outlines the responsibilities expected of Nasdaq officers,
directors and employees in conducting business inaccordance with the highest standards of ethics andcompliance. The Code is applicable to the Board, all fulltime and part-time employees, (including the principal
executive officer, the principal financial officer and thecontroller and principal accounting officer), contract
workers and others who conduct work on behalf of Nasdaq.
There is also a separate Nasdaq Code of Conduct for the
Board, which contains supplemental provisions specificallyapplicable to directors.
Ethical values are reinforced through employee training
and communication, including town halls and topic
specific webinars. Nasdaq also embeds its commitment togovernance, transparency, integrity and ethical businesspractices in a series of robust policy documents, all freely
available for download on our ESG Resource Center.

49

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Employee Training and Certifications
All employees are required to complete
trainings and certifications on an annual
basis and as part of their initial on-boarding.
Training topics include:• Ethics, Integrity and Conflicts of Interest• Cybersecurity Awareness and Privacy• Anti-Financial Crime & Anti-Money
Laundering• Economic Sanctions and Trade Controls• Insider Trading• Nasdaq’s SpeakUp! Program• Anti-Corruption, Gifts and BusinessEntertainment
Employees are required, at the time of hire
and annually during a set period thereafter,
to complete certifications:• Attesting to the accuracy of their financial
and conflict of interest disclosures (which
are required to be maintained current on
an ongoing basis)• To comply with Nasdaq’s Code of Ethics• To comply with Nasdaq’s compliance,
information security and privacy policies,
including, but not limited to, Nasdaq’s
policy regarding insider trading/personal
securities trading (the Global Trading

Policy) and policies related to anticorruption, sanctions and trade controls
Nasdaq provides specialized Anti-Money
Laundering (AML) training for the newly
hired employees of Nasdaq Central
Securities Depository Stock Exchanges(CSD) covering the services offered by
Nasdaq CSD, which are under the scopeof applicable AML law (in Latvia and in
Estonia). The training provides an overview
of the goals of AML regulation, describes
the rationale of the services being underAML requirements and explains themeasures applied and the policies andinstructions adopted by Nasdaq CSD
to ensure that the services are offeredin compliance with AML requirements.
Nasdaq's broker dealer group provides
annual AML training for all registeredrepresentatives of our broker dealer
subsidiaries. The training provides an
overview of the three stages of anti-money
laundering, describes the regulatory
framework for U.S. AML requirements andoutlines key aspects of the AML program
including guidance for identifying red flags
and reporting suspicious activity.
Additionally, all newly hired employees are
required to complete ethics and compliancetraining as part of initial on-boarding andtown hall events and webinars provide
detailed training to all employees on aquarterly basis. In 2022, with the lifting of
pandemic travel restrictions and increased
in-office attendance, these trainings wereaugmented with in-person training events.

Whistleblower Program andProtections
A cornerstone of our ethics program is our
SpeakUp! Program. Under our SpeakUp!
Program, employees, contractors andthird parties doing business with Nasdaq
have multiple channels for raising ethics
and compliance concerns or allegations of
misconduct. These channels include directly
contacting our Global Ethics Team throughdedicated communications channels
and reporting through our SpeakUp!
Line, a whistleblower hotline that allows
individuals to make anonymous reports. The
SpeakUp! Line is operated by a third-party
hotline provider that enables Nasdaq tocommunicate with an individual reporting an
issue on an anonymous basis. This Program
includes specific investigation procedures
for notifying appropriate business
management (including, where appropriate,
Internal Audit and SOX compliancefunctions), conducting investigations,resolving matters and closing out matters

All employees are required to complete
trainings and certifications on an annual
basis and as part of their initial onboarding. Training topics include:• Ethics, Integrity and Conflicts of Interest• Cybersecurity Awareness and Privacy• Anti-Money Laundering• Economic Sanctions and Trade Controls• Insider Trading• Nasdaq’s SpeakUp! Program• Anti-Corruption, Gifts and Business Entertainment

GRI 2 | GRI 2-23 | GRI 2-24 | GRI 2-25 | GRI 2-26 | GRI 205-2 | GRI 404
WEF Core 4 | WEF Core 5 | WEF Core 14

50

Nasdaq 2022 Sustainability Report

Introduction

with the individual reporting the concern. In
addition to the SpeakUp! Program, individuals
can directly and confidentially contact our Audit& Risk Committee Chair via email or physicalmail.

and regulations for individuals reporting alleged
misconduct or violations of the law.

To foster an ethical culture where employees
are supported in reporting unethical behavior,
Nasdaq provides multiple channels fordisclosing misconduct under our SpeakUp!
Program. One element of this program —our SpeakUp! Line — enables anonymous
whistleblowing as required by applicable laws
and regulations. The SpeakUp! Line is operated
by a third party that is strictly required
to protect the anonymity of the reporting
individual when requested by the individual,
and the Audit & Risk Committee receives
regular reports on activity on the SpeakUp!
Line. Nasdaq supports employees by allowing
the disclosure of trade secrets in confidence torelevant government authorities without fear of
retaliation, regardless of the confidentiality or
intellectual property agreements the employee
has signed with Nasdaq.
Employees can contact the appropriate
regulator, law enforcement, other government
authorities or others as authorized by applicablelaw without notifying Nasdaq in advance or first
pursuing internal reporting channels. Nasdaq
does not tolerate retaliation and provides alllegal protections afforded under applicable laws

Environmental

Anti-Corruption
Nasdaq’s anti-corruption program is
implemented at an enterprise, global levelacross all Business Units in a risk-basedmanner. The anti-corruption program includes
policies, procedures, monitoring and periodic
risk assessments aligned to leading practices
and standards, including those publishedby the U.S. Department of Justice and The
Organization for Economic Co-operation andDevelopment (OECD). As set forth in Nasdaq’s
Code of Ethics and relevant policies, we havezero-tolerance for violation of bribery andcorruption laws.
Every year, the Code of Ethics and the Gifts,
Business-Related Events & Anti-Bribery andCorruption Policy is reviewed with updates
approved by executive management andthe Board. The updated documents arecommunicated to all employees and certified
by them on an annual basis.
Nasdaq conducts screening of all vendors
and agents for corruption risk and monitors
all payments, including vendor payments andemployee reimbursed expenses for compliance.
Nasdaq’s Supplier Code outlines our expectations
for Business Partners, including those
expectations related to bribery and corruption.

SocialGovernance

ESG Solutions

Community Engagement

Labor Practices and Human Rights

Operating in Global Communities

Nasdaq believes in the fundamental dignityof every human being and the rights of every
individual to live and work safely and humanely,
without fear of oppression or coercion. Our
Vision, Mission and Values Statements, alongwith our Code of Ethics, Supplier Code of
Ethics and Employee Handbooks emphasize
responsibility, integrity and values-based
decision-making and set forth our standards
for conducting our business ethically andconsistently with our moral principles. These
principles and standards shape our interactions
with fellow employees, clients, suppliers,
communities and markets around the world —and with our community of stakeholders, too.

As a global company with operations in morethan 26 countries, Nasdaq endeavors tomodel our principles wherever we operate,serving as a role model where we dobusiness. Our fundamental respect for humanrights informs client engagements, the work
we perform, the goods and services that wepurchase and how we engage with the local
business community as a corporate citizen.
We also learn from the communities where welive and work and seek new ways to empower
economic and social wellbeing.

They are foundational to our Company andenable our continued success. Reflecting
Nasdaq’s obligations as a global company,
Nasdaq has incorporated within its Code of
Ethics, corporate policies or program-specificrequirements to put these principles into practice:• Equal Employment Opportunity andDiscrimination• Harassment• Non-Retaliation• Diversity & Inclusion• Data Privacy

Appendix

Freedom of Association
A limited number of Nasdaq's employee
population are covered by collective bargaining
agreements, or represented by unions orworks councils. We engage both directlywith our employees and through theseassociations to discuss issues such as healthand safety, remuneration, work hours, training,career development and mentorship, work
time flexibility and equal opportunity. We
communicate information related to freedom of
association through various mediums, including
our employee handbooks and policies, ourintranet, employee network groups, periodic
town hall meetings (virtual and in-person), andthrough emails.

• Health & Safety• Labor Standards

GRI 2-25 | GRI 2-26 | GRI 2-30 | GRI 205 | GRI 205-1 | GRI 205-2 | GRI 402 | GRI 407-1 | GRI 408 | GRI 408-1 | GRI 409 | GRI 409-1
WEF Core 4 | WEF Core 5 | WEF Core 14

51

Nasdaq 2022 Sustainability Report

Human Rights Assessment
In 2021, Nasdaq collaborated with anindependent third-party to initiate a formal
human rights assessment consistent with theUnited Nations Guiding Principles on Businessand Human Rights (UNGP). The assessment
focused on:• outlining current expectations of financial
institutions with regards to human rights;• building internal understanding of humanrights; and• undertaking an initial, high-level gap
analysis of Nasdaq’s current policies
and practices against the UNGP’s, withrecommendation on best practices.
Following the completion of this assessment,
in 2022 we evaluated our level of potential
human rights risk exposure in the highpriority areas identified by the third-party
assessment and confirmed that our risk
exposure is low. However, we understand that
supply chains are complex and continually
evolving and global human rights conditions
change and we will continue our vigilant
human rights due diligence. We are evaluatingprocesses and technologies that could enable
us to enhance our current risk-monitoring
capabilities in the future.

Introduction

Environmental

Anti-Financial Crime &Anti-Money Laundering
As a self-regulatory organization andoperator of regulated financial systems suchas exchanges, a clearinghouse and central
securities depositories, Nasdaq is deeplycommitted to ensuring that markets operate
fairly and do not facilitate financial crime,
including money laundering and terrorism
financing. Nasdaq’s Code of Ethics, Trade
Controls and Sanctions Compliance Policy
and Global Anti-Money Laundering (AML)
Policy, as well as applicable regional policies
require compliance with all AML laws andregulations that apply to our business. For
covered operations, this includes conducting
any required know-your-customer (KYC)
due diligence, monitoring transactions andreporting suspicious activities. Nasdaq
is committed to detecting and deterringmoney laundering and terrorism financing.
Following the onboarding, Nasdaq conducts
continuous screening of our prospects,
customers and suppliers against various
compliance watchlists, including terrorist
and terrorism-financing lists. Nasdaq
retains all records related to third party
due diligence, transactions monitoring andreporting in accordance with our records
retention procedures. Additionally, Nasdaq
mandates all employees reserve all records
and documentation related to an existent or

SocialGovernancea potential investigation into anti-bribery/corruption, sanctions, trade control, AML
or other violation(s) of financial crime laws,
including all emails, voicemails, text messages,
paper documents, records and files, electronic
documents, records and files.
Members of Nasdaq’s exchanges are required
to have in place AML and other diligenceprograms to screen their clients and market
participants in accordance with the applicable
U.S. and EU laws and regulations. In addition
to legal requirements related to AML, Nasdaq
is implementing a risk-based anti-financial
crime framework in key business segments toaugment its compliance programs.
Across our global enterprise, Nasdaq has
implemented comprehensive policies andscreening programs to enable compliance witheconomic sanctions that apply to its business.
This includes screening all customers, vendors
and other business partners against applicablesanctions lists such as those published by theUnited Nations, U.S. Department of Treasury,
Office of Foreign Assets Control, the European
Union and the United Kingdom along withother jurisdictions where Nasdaq operates.
Nasdaq has appointed senior level employees
to oversee its sanctions compliance program
and reviews its sanction compliance policy
annually with its Board of Directors. In 2022,
Nasdaq delivered mandatory high-level

ESG Solutions

Community Engagement

Appendixsanctions and AML compliance training to
all of its employees and, in 2023, is planning
to provide targeted in-depth training for
employees in the Sales and Accounting
functions.
In operating our markets, Nasdaq maintains
robust surveillance teams that monitor ourmarkets for potential suspicious trading
activity and compliance with our market rules.
Our surveillance teams use sophisticatedsoftware that leverages models andanalytics to identify suspected risks, which
are then escalated and reviewed. Nasdaq
cooperates with the Securities and Exchange
Commission, financial supervisory authorities,
Financial Industry Regulatory Authority, The
European Securities and Markets Authority
and other exchanges to address suspectedviolations and to deter, identify and prosecute
unlawful activity affecting the securities
market. Nasdaq also licenses its technology
to regulators and financial firms to help themmonitor their markets and activity.
Nasdaq believes it is important for our
employees to stay informed regarding thelatest developments in anti-financial crimeand money laundering and provides regular
updates and training sessions on this topic.
In 2023, we aim to continue enhancing
information on our public website regardinganti-financial crime and privacy programs.

GRI 402 | GRI 407 | GRI 408 | GRI 408-1 | GRI 409 | GRI 409-1
WEF Core 4 | WEF Core 5 | WEF Core 14

52

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Cybersecurity, Information Security and Privacy
Oversight
Cybersecurity is an integral part of risk
management at Nasdaq. The Information
Security Department is responsible forcoordinating the protection of our corebusiness operations and information
against real-world cyber threats byemploying technology, policy, processes,
education programs and sound design
techniques across the organization.
Nasdaq’s Chief Information Security Officer(CISO) who reports directly to Nasdaq’s
Chief Information Officer within Nasdaq’s
centralized Global Technology organization
manages the Information Security
Department (ISD).
The ISD team is responsible for:• performing and coordinating security
assessments and vulnerability scans of
Nasdaq’s internal, external and thirdparty applications;• implementing and maintaining Nasdaq’s
various information security-related
policies and standards;• middleware and vulnerability
management in addition to special
projects as designated by the CISO;• Nasdaq’s compliance efforts for General
Data Protection Regulation (GDPR) andall supporting data privacy and protection
efforts;• configuring Nasdaq Group infrastructure
and the applications running thereon inaccordance with Nasdaq’s configurations
policies, processes and standards;• development of internal tools andsolutions to drive efficiency and enhancemonitoring and visibility throughoperational metrics and compliance
operating Nasdaq’s Global Security
Operations Center, which monitors
security event logs, 24/7/365, from
Nasdaq networks, systems, applications
and databases and creates log files ofknown and unknown events; and• monitoring threats against Nasdaq,
its technology stack and its peerorganizations and providing
recommendations for securing potentiallyvulnerable populations at Nasdaq in thecontext of emerging threats.
The ISD in collaboration with the Legal,
Regulatory and Risk Group is responsible
for coordinating Nasdaq’s Privacy Program.
This includes compliance efforts related

to the European and UK General Data
Protection Regulation and global privacy
laws and regulations. To support its GDPR
compliance program, Nasdaq has appointed
an independent Data Protection Officer for
its European regulated business entities.
On an annual basis, the Information Security
team reviews and updates its governancedocuments, such as the Information
Security Charter, the Information Security
Policy and the Information Security
Program Plan and then presents the revised
documents to the Audit & Risk Committee
for review and/or approval.

Cybersecurity is an
integral part of risk
management at Nasdaq

Our Audit & Risk Committee receives
quarterly reports, as well as additional
reports as needed, on cybersecurity andinformation security matters from our
CISO. This regular reporting includes acybersecurity dashboard that contains
information on cybersecurity governanceprocesses, the status of projects tostrengthen internal cybersecurity, ongoingprevention and mitigation efforts, security
features of the products and services weprovide our customers, and the resultsof security breach simulations. The Audit& Risk Committee also discusses recent

GRI 410SASB FN-EX-550a.3

53Nasdaq 2022 Sustainability Reportincidents throughout the industry and theemerging threat landscape.
Additionally, during 2022, the Information
Security team continued to execute on
the Cybersecurity Strategic Plan, which
outlines the strategic vision and associatedgoals for the cybersecurity of Nasdaq’s
global operations for the three-year period
from 2020 through the end of 2022. We
completed the projects tied to the 20202022 Strategic Plan and Nasdaq Information
Security is in the process of creating the2023-2025 Strategic Plan, which will bepresented to the Audit & Risk Committee.
The Nasdaq Information Security
Management System (ISMS) that governs
the global enterprise infrastructure andsupports key global information security
processes and includes technology,
personnel, locations and data centers,
conforms to ISO 27001 requirements andis ISO 27001 certified. The processes
in scope for the Nasdaq ISO 27001
certification include: Access Management,
Human Resources, Product Development
Lifecycle (PDLC), Change Management,
Supplier Risk Management, Configuration/
Build Management, Asset Management,
Incident Management, Physical Security,
Security Operations, Risk Assessment,Internal Audit, Disaster Recovery, Scanning,

Introduction

Environmental

Backup/Restore and Application Security.
Nasdaq personnel corporate equipment andconnectivity to the production infrastructure
are also in scope. Additionally, a variety of
Nasdaq products (8+) undergo an annual
SOC 2 Type II audit. The final reports are
made available to customers under nondisclosure agreements.

Information Security Policies,
Procedures and Practices
As set forth in the Nasdaq Code of Ethics
and relevant company policies, Nasdaq
personnel are expected to protect andsecure the confidentiality of non-public
information that they receive access toor create in connection with their work at
the company. This expectation includes
adhering to any laws, regulations andnon-disclosure agreements that restrict
the use of data (including personal data),
require measures to safeguard it and limit
disclosure of information. Nasdaq policies
also require that personnel limit their use of
information technology assets (e.g., laptops,
phones and other devices) to permitted
activities to avoid putting data at risk andthat they promptly report any suspected
improper use or potential disclosure of data.
Nasdaq has numerous policies in place tofurther safeguard our technology and use
thereof, including:SocialGovernance

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Appendix• Acceptable Use Policy;• Data Classification Policy;• Information Security Policy; and• Mobile Device Policy.
We are committed to appropriately securing
non-public data used as part of ourbusiness operations, including informationthat Nasdaq generates in the performanceof its services and data provided to us by
third parties, including customers, vendors,
business partners, employees and otherstakeholders.
This commitment is reflected in our cultureof security, our policies and procedures fordata systems and processing activities, ourmechanisms for monitoring our information
systems and data use, the security
awareness and role-based training that we
provide to staff on data protection and theteam of skilled information security andtechnology professionals who design, protect
and maintain our information systems.

We are committed toappropriately securing
non-public data used as partof our business operations

Employees, contractors and service
providers are required to sign confidentiality
agreements, which prohibit them fromdisclosing any confidential information learned
during the course of their employment or
performance of services for Nasdaq.

GRI 2-24 | GRI 410

54

Nasdaq 2022 Sustainability Report

We provide training on information security
to our employees on a regular basis. This
includes annual mandatory training on
information security awareness and privacy.
We provide tailored information security
training sessions to multiple audiences.

Auditing Compliance
As a publicly traded company, we are
required to adhere to the Listing Rules forour exchange. This includes being auditedby an independent public accountant that isregistered as a public accounting firm with
the Public Company Accounting Oversight
Board, as provided for in Section 102 of the
Sarbanes-Oxley Act of 2002 [15 U.S.C. 7212].
Internal Audit periodically audits against
the Code of Ethics and ethical standards
at the Company.

Internal Audit Methodology
All Nasdaq operations are subject to audit
and are organized into business-based
portfolios of audit entities comprising anaudit universe that is covered on a riskbased rotational basis (i.e., High: annually,
Medium: every 2-3 years and Low: every
3-4 years) to confirm that every entity is
subjected to audit at least once within afour-year period. An annual risk assessment
is performed to identify, categorize andprioritize the business processes andIntroduction

Environmental

risks within Nasdaq, as well as assess theinherent and residual risk for each of thebusiness processes. Additionally, fraud isconsidered in each audit performed.

Incident Response andManagement Policy
Nasdaq’s Incident Management Policy
governs all incidents, including security
incidents, that cause or could potentiallycause an interruption to or reduction in
the quality and/or availability of a Nasdaq
production service. The primary goals of
the policy are to restore normal service
operation as quickly as possible, provide
timely and accurate communication to
relevant stakeholders and minimize theadverse impact of an incident on business
operations and/or the quality of provided
services. Nasdaq employs a multi-layered
team structure to manage incidents
with established roles and escalation
procedures.

Data Privacy
Nasdaq appreciates the special obligations
that apply to processing personal dataand individuals’ rights to privacy andpersonal data protection. Reflecting theunique risks and potential harm posed bymishandling or misuse of personal data,
Nasdaq’s privacy program builds on thefoundation of our information security

SocialGovernanceprogram to apply special governance,
policies, procedures and training on theuse, handling and processing of personal
data and performance of activities that
impact privacy rights (as determined by
the jurisdictions in which we operate).
Nasdaq’s privacy compliance program isdesigned to enable adherence to laws andregulations applicable to personal data thatit processes, including, as applicable, theGDPR and the California Consumer Privacy
Act, as well as its posted Privacy Policy andcontractual commitments to customers,
vendors and other counterparties.

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Appendix

As one of our training requirements, we
require employees to complete annual
privacy training and certify compliance with
our privacy policies; we include privacy aspart of our compliance onboarding training
for new hires. In addition, we provide rolebased privacy training to teams acrossNasdaq. In 2022, this training included
a privacy awareness “roadshow” with
in-person training at each of Nasdaq’s
European and UK offices.
For more information, please read ourInformation Protection & Privacy
Practices document.

To support these principles, Nasdaq
maintains a comprehensive and consistent
set of information security documentation
and requirements intended to protect the
security, reliability, integrity, accuracy,
confidentiality and availability of Nasdaq
information assets. These documents
record the security controls and personnel
responsibilities established to protect
Nasdaq information and information
systems against both accidental andunauthorized access, modification,interference, disclosure and destruction.
These include our Information Security
policies, which apply to personnel (full-timeand part-time employees and contractors)
working for Nasdaq.

GRI 410 | GRI 418

55

Nasdaq 2022 Sustainability Report

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Appendix

Public Policy Advocacy
As part of our duty to shareholders,
employees and the markets, Nasdaq
actively participates in public policy debatesin the United States, Europe and elsewhere.
Oversight of our public policy advocacy
practices follows industry best practices
with an internal Public Policy Committeethat sets priorities and reviews Nasdaq’s
activities in the United States and Europe.
This Committee is convened with active
senior management participation on aquarterly basis. The Government Relations
function and its procedures is managed at
the Vice Chairman level. Nasdaq maintains
a vigorous global employee education
program with respect to the Foreign Corrupt
Practices Act and other jurisdictional
prohibitions on pay-for-play. Nasdaq does
not support any political campaigns, or“Super PACs,” directly with Nasdaq funds.
In the United States, Nasdaq believes it has
the responsibility to use its voice to educate
policymakers and regulators. Nasdaq’s
advocacy focuses on policies affecting
the capital markets. Nasdaq concentrates
its efforts on education and outreach andutilizes a modest Political Action Committee,
or PAC, program known as the Nasdaq PAC.

The Nasdaq PAC is funded entirely throughemployee contributions and supports
only federal campaigns. Nasdaq’s PAC isgoverned by a board of employees who
vote on every disbursement.
With respect to our European operations,
we focus our advocacy programs on
active education and engagement withelected leaders and key policymakers.
Our policies in Europe follow prevailingjurisdictional law and preclude any
monetary contributions to political parties,
candidates or their designees.
Nasdaq maintains memberships in a numberof associations around the globe that serveas important partners for our industry,clients and employees including the World
Federation of Exchanges, Federationof European Securities Exchanges, U.S.
Securities Markets Coalition, Equity
Markets Association, Partnership for New
York City, Business Roundtable, Silicon
Valley Leadership Group, U.S. Chamber ofCommerce, TechNet and others.

GRI 2-28 | GRI 415 | GRI 415-1

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Appendix

Risk Management
Risk Oversight
The Board’s role in risk oversight isconsistent with our leadership structure,with management having day-to-day
responsibility for assessing and managing
the Company’s risk exposure and the Board
having ultimate responsibility for overseeingrisk management with a focus on themost significant risks facing the Company.
The Board is assisted in meeting this
responsibility by several Board Committees.
The Audit & Risk Committee receives regular
reports relating to operational compliancewith the Company’s risk appetite andreviews any deviations.
Additionally, management provided updates
to the Board throughout the year regarding
various risks arising from the COVID-19
pandemic, including with respect tocybersecurity, remote work arrangements,
customer implementations, the operationof our exchanges and other potential
corporate performance issues.
The Board, through the Audit & Risk
Committee, sets the Company’s risk
appetite, which is the boundaries within
which our management operates whileachieving corporate objectives. In addition,
the Board reviews and approves theCompany’s Enterprise Risk Management(ERM) Policy, which mandates ERM
requirements and defines employees’ risk
management roles and responsibilities.

Enterprise Risk Management
Nasdaq’s Group Risk Management (GRM)
Department, which is part of the Legal,
Regulatory and Risk Group, oversees
the ERM framework, supports its
implementation and aggregates and reports
risk information.
Under our ERM Policy, we employ an
ERM approach that manages risk throughobjective and consistent identification,assessment, monitoring and measurementof significant risks across the Company.
We classify risks into the following five
broad categories.
• Strategic and Business Risk: Risk toearnings and capital arising from changes
in the business environment and fromadverse business decisions, improper
implementation of decisions or lackof responsiveness to changes in thebusiness environment.
• Financial Risk: Risk to our financial
position or ability to operate due toinvestment decisions and financial risk

management practices, in particular as
it relates to market, credit, capital andliquidity risks.
• Operational Risk: Risks arising fromour people, processes and systems
and external causes, including (among
other things) risks related to transaction
errors, financial misstatements,
technology, information security(including cybersecurity), engagementof third parties and maintaining business
continuity.
• Legal and Regulatory Risk: Exposure
to civil and criminal consequences— including regulatory penalties,
fines, forfeiture and litigation — while
conducting our business operations;
including (among other things), risks
related to data privacy, intellectual
property, financial crime andemployment law.
• Environmental, Social and GovernanceRisk: Risks arising from perceived or
actual shortcomings in the managementof ESG matters.
Our management has day-to-day
responsibility for managing risk arisingfrom our activities, including making
decisions within stated Board-delegatedauthority; ensuring employees understandtheir responsibilities for managing risk
through a “three lines of risk management“model; and establishing internal controls
as well as guidance and standards toimplement the ERM policy. In the “threelines of risk management “model, the firstline, consisting of the business units andexpert teams (i.e., corporate support units),
executes core processes and controls. The
second line, consisting of the risk, control
and oversight teams, sets policies andestablishes frameworks to manage risks.
The third line, which is the Internal Audit
Department, provides an independent
review of the first and second lines.
Our Global Risk Management Committee,
which includes our Chair and CEO and othersenior executives, assists the Board in its
risk oversight role, ensuring that the ERM
framework is appropriate and functioning
as intended and the level of risk assumed
by the Company is consistent with Nasdaq’s
strategy and risk appetite.
We also have other limited-scope
management risk committees that address
specific risks, geographic areas and/or subsidiaries. These risk management
committees, which include representatives
57

Nasdaq 2022 Sustainability Reportfrom Business Units and subject matter
experts, monitor current and emerging
risks within their purview to ensure an
appropriate level of risk. Together, thevarious risk management committees
facilitate timely escalation of issues to
the Global Risk Management Committee,
which escalates critical issues to theBoard. These risk management committees
include the following:• The Nasdaq Regulatory Capital Committee
oversees the global regulatory capitalframework for our regulated entities andthe level of regulatory capital risk.
• The Compliance Council identifies,
monitors and addresses regulatory andcorporate compliance risks.

Introduction

Environmental

SocialGovernance

BCM Framework is implemented on a local
basis to support the Company’s resilience,
maintain critical operations and minimize
the impact of operational and physicaldisruptions to Nasdaq and its markets,clients, market participants, shareholders,
employees and regulators. Efforts havebeen taken to align the BCM Programwith industry best practices classified in
the National Institute of Standards andTechnology (NIST), the Federal Financial
Institute Examination Council (FFIEC)
Guidelines and ISO 22301 (International
Standard for Business Continuity
Management).

ESG Solutions

Community Engagement

Appendix

Risk Oversight Organizational Structure

Audit & Risk Committee

Internal Audit

Global Risk
Management Committee

Regulatory CapitalCommittee

Technology Risk
Committee

Compliance Council

Business Continuity& Crisis Management
Committee• The Global Technology Risk Committee
oversees technology risks within our
strategic products and applications.
• The Business Continuity and Crisis
Management Committee oversees
business continuity and resiliency
related risks.

Risk, Control and Oversight TeamsManaging Business Continuity
The Business Continuity Management &Disaster Recovery Policy is approved by the
GRMC and outlines the core componentsof the BCM Framework, including business
continuity, disaster recovery and crisis
management programs. The BusinessBusiness Units and Expert Teams58

Nasdaq 2022 Sustainability Report

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ESG Solutions

Community Engagement

Appendix

Sustainability Risk Management
Climate-Related Risk
Nasdaq regularly evaluates climate risks
that may affect our products and services,value chain, operations and investments.
We perform detailed evaluations focused
primarily on the types of risks that arelikely to increase direct costs or interrupt
our primary business functions. While
we have exposure to both physical andtransition drivers, transition drivers
present both the most significant risks
and opportunities for Nasdaq’s business,strategy and financial planning across alltime horizons considered.
In accordance with the TCFD
recommendations, we examined theresiliency of Nasdaq’s current strategy
by conducting climate scenario analyses.
Using this process, we assessed Nasdaq’s
exposure to physical and transition climaterelated risks and opportunities deemedas having the potential to influence ourbusinesses, strategy and financial planning.
In 2022, we updated and enhanced our
climate scenario analysis by:• applying the most recent transition
scenarios from the Network for Greening
the Financial System (NGFS)1, including
two net-zero aligned scenarios;• applying the latest physical scenarios as
per Intergovernmental Panel on Climate
Change’s Sixth Assessment Report(IPCC AR6); 2• including two new climate-related
hazards, water stress and cyclones, inNasdaq’s physical scenario analysis;• updating our analysis for our entire global
portfolio of offices and data centers,
including new sites; and• performing an analysis of the climate
maturity of Nasdaq’s key suppliers andcustomers.
Our 2022 climate scenario analysis
validated that our most significant climate
risks and opportunities stem from transition
risks, such as mandatory climate reporting
requirements and transitioning to lower
emissions technology. Nasdaq’s recently
verified science-based targets are expected

1

For more information, see https://www.ngfs.net/ngfs-scenarios-portal/explore/

2

For more information, see https://www.ipcc.ch/report/ar6/wg3/downloads/report/IPCC_AR6_WGIII_FullReport.pdf

to help mitigate some of these risks. We
aim to further explore the vulnerabilityof our operations to the climate hazards
identified in our TCFD report, to project
possible financial impacts related tobusiness disruption and identify the costs ofmitigation.
As part of Nasdaq’s Bottom-Up Risk
Assessments, in 2022 GRM developed its
first formal climate risk assessment utilizing
guidance from leading reporting frameworks
such as CDP. This assessment solicited
feedback on Nasdaq’s exposure to physicaland transition climate risks from acrossNasdaq’s Business Units and exposure
stemming from Nasdaq’s key vendors. Goingforward, this climate risk assessment willcontinue to be performed annually and will
evolve in alignment with prominent climate
reporting frameworks.

Nasdaq regularly evaluates
climate risks that may affectour products and services,value chain, operations andinvestments.

Our low-carbon transition plan is a key
strategy as part of our efforts to mitigate
our business risks associated withclimate change. This plan is extensive
and includes improving and maturing ourGRI 201-2
WEF Core 6 | WEF Core 859Nasdaq 2022 Sustainability Report

GHG footprint analysis process, aligning corporate
strategies to support reaching our science-basedtargets, implementing identified energy efficiency
strategies, purchasing renewable electricity,
pursuing green building certifications and engaging
with our supply chain.

Supplier Risk Management
Nasdaq’s Supplier Engagement and Management
policy contains the standards, rules and processes
to be followed when engaging a supplier to provide
goods and services to Nasdaq. This includes
policies relating to pre-contract supplier due
diligence, as well as ongoing monitoring of existing
supplier relationships. Nasdaq has instituted a riskbased approach for performing due diligence onprospective suppliers. Due diligence procedures
include public records screening and evaluation
by relevant Nasdaq subject matter experts.
Periodic assessments are performed on our third
parties, particularly those that are deemed toprovide critical goods and services to Nasdaq. The
assessments include evaluation of the third-party’s
controls relevant to the services they provide, which
include, but are not limited to, their controls relating
to information systems and security. Furthermore,
the periodic supplier risk assessment now includes
an ESG risk domain, to address environmental
risks, modern slavery and diversity. Nasdaq’s
Office of the General Counsel administers Nasdaq’s

Introduction

Environmental

Contract Review & Approval Policy, which details
the legal review process for contracts entered intoby Nasdaq Group companies. In accordance with
Nasdaq internal processes, the Information Security
Department conducts risk assessments of vendorsthat process Nasdaq data (including customer data)
and/or have access to Nasdaq systems and works
with our legal department regarding applicablevendor-appropriate contractual protections related
to information security.

SocialGovernance

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Community Engagement

Appendix

Our Annual Report on Form 10-K for the year ended
December 31, 2022 discloses Nasdaq’s total cash
contribution for income taxes paid during the year. For
2022, Nasdaq paid $274 million in taxes worldwide
in corporate income taxes. For further detail, seeappendix (pg. 92) for a summary by country.
Our Public Tax Policy applies to Nasdaq andall of our global subsidiaries and describes
the principles that form the foundation of ourapproach to tax governance.

For more information, please see the Evaluatingand Engaging Our Supply Chain (pg. 32) and theSupplier Diversity (pg. 45) sections.

Tax Transparency
Nasdaq and all of our subsidiaries have a
responsibility as a global taxpayer to accurately
calculate, report and pay the Company’s corporate
income taxes. Our goal is to minimize organizationaltax risk exposure by staying current on tax law
changes, implementing robust controls aroundour processes and avoiding overly aggressive
tax planning strategies which would prevent theCompany from paying its fair share of taxes andcontributing to the economic success of countries inwhich we operate. We only engage in transactions
with sufficient economic substance and don’t invest
in tax havens for the purpose of tax avoidance.

GRI 204 | GRI 207 | GRI 408-1 | GRI 409-1 | GRI 414 | GRI 414-1 | GRI 414-2

60

Support our
Clients and Enable
Positive Outcomes61

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Community Engagement

Appendix

ESG Solutions: Supporting Our Clients

2022 Highlights

As stakeholder expectations evolve, many companies recognizethat a good sustainability strategy means good business, whether
for employees, clients, suppliers, investors, regulators or otherparties. Our product strategy appreciates the diversity of needs
and leverages our unique position at the intersection of investors,
corporates and regulators to drive long-term value to our clientsand the entire ecosystem.
We have a deep appreciation for the challenges and opportunities
that corporates face in navigating the rapidly evolving demands ofthe capital markets and their engagement with investors, as well as
increasing demand for them to develop, disclose and engage across a
broadening set of ESG-focused strategies and performance metrics.
Our role is to help our clients understand these developments aswell as advocate on their behalf, provide insights to both strengthen
their programs and strategies as well as enhance their disclosuresand communications back to their investors and the wider
markets. We seek to reduce the complexity and friction our clients
experience through demand-driven, market-based solutions thatare pragmatic in nature.
Nelson Griggs
President, Nasdaq

became the first GRI software
provider to receive certification for
the revised Universal and Topic
Standards, through GRI’s Certified
Software and Tools Provider program

3.3K

Governance Solutions
launched the Nasdaq Center
for Board Excellence

Aquired Metrio, expanding oursuite of ESG Solutions

213K+
Puro.earth issued over 213,000
CORCs on behalf of suppliers
representing a 2.4x year-overyear increase in issuance

2.4x

CORC Issuance

1.5K 14K
AND

issuers

securities

Nasdaq Sustainable Bond Network
launched functionalities to report on EU
taxonomy alignment of projects financedby issuers’ green and sustainable bonds
and reached a coverage of more than 1,500
issuers and 14,000 securities globally

IR Intelligence provided insights &analytics software and advisory
services products to nearly 3,300
companies globally27%

The number of sustainable debt
instruments listed on Nasdaq
Sustainable Debt Market grew by
11% and the volume of listed bonds
grew by 27%

60% YoY

Nasdaq Risk Modelling for Catastrophes
client base increased 60% year-over-year
62

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

AppendixCollect, Measure & Disclose

ESG Products and Services

MetrioNasdaq OneReport1

Provide Oversight, Execute & Engage
IR Intelligence

Nasdaq is uniquely positioned to serve thecorporate and investment communities as
they strive to achieve their ESG-related
objectives. Our work across both thecorporate and investment communities, inaddition to our work with regulators andstandards setters, creates a virtuous cycle.
Corporate Community: We serve thecorporate community throughout their
ESG lifecycle, helping public companies
navigate the capital markets, evolving
private companies’ progress to becoming
public companies and engaging with all
types of companies to navigate a diverseand complex shareholder landscape.

Investment Community: Asset owners andasset managers equally face an increasingly
complex and dynamic ESG landscape.
We serve the investment community witha range of workflow, data and analytics
capabilities to help them manage theirportfolios and enhance their asset allocation
decision-making processes.
Fostering a Culture of Education:
Leveraging our research capabilities
and internal ESG subject matter expertise,
we engage and support our clients bycreating and sharing best practices andleading insights.

Strategy Setting

Governance Solutions

ESG Advisory

Puro.earthR
COP O R ATESECOSYSTEM

Corporate Community

Scaled impact for good across millions
of employees, customers, suppliers,
corporates, investors, the economy

Investment Community

and the planetIN

V E S T O RS

Research

Analyze & Report

eVestment

ESG FootprintESG DataHub

Nasdaq Sustainable Bond Network

InvesteVestment
ESG Indexes
1

Nasdaq’s products and services discussed below include an ESG component. They are not acomprehensive list of Nasdaq’s total offerings.

Nasdaq Sustainable Debt Market
Green Equity Designation

63

Nasdaq 2022 Sustainability Report

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Environmental

SocialGovernance

ESG Solutions

Supporting the Corporate Community
ESG Advisory
Launched as an organic growth initiative in 2019, Nasdaq’s
ESG Advisory is a service solution that pairs companies
with consultative ESG expertise to help analyze, assess
and put into action best-practice ESG programs with thegoals of attracting long-term capital and enhancing value.
Nasdaq’s ESG Advisory practice is staffed by former ESG
investors and ESG ratings agency analysts, sustainability
consultants with decades of collective experience as wellas individuals who ran sustainability programs in-house
at Fortune 500 organizations. ESG Advisory services
include ESG and climate strategy development, GHG
footprinting support, Board engagement strategies, ESG
investor engagement advice and ESG and climate reportdevelopment support for companies.

Nasdaq Listings (IPO) package,
approved by the SEC in 2021,
provides newly public companies
in the Nasdaq Global Select andthe Nasdaq Global Markets withcomplimentary sustainability
reporting support:• Three years of OneReport• ESG Advisory consultation• ESG Reporting Guide
SDG 122022 was a transformative year for Nasdaq’s ESG
Advisory practice as we more than doubled ourheadcount to meet client demand for our consultative
ESG services. Headcount growth was focused on
individuals with key skill sets including: banking, ESG
investing, in-house corporate ESG, ESG rating agencies
and ESG standard setters. 2022 also marked the firstyear that ESG Advisory expanded headcount into the
Asia Pacific (APAC) region. In 2023, ESG Advisory plans
to continue prioritizing private and public customer
needs with ESG and climate related disclosure, GHG
footprinting, ESG capital attraction strategies and ESG
goals and target setting. As the regulatory environment
heightens its disclosure requirements within the U.S.,
Europe and the Asia Pacific region, we’re aligning
our resources and competencies to help our clientsnavigate stakeholder demands.

Nasdaq OneReport
Nasdaq OneReport is an ESG data management,
reporting, audit trail and disclosure software that allows
companies to simplify ESG reporting. It optimizes
workflows, facilitates reporting to frameworks,
research and ratings organizations and helps disclose
ESG progress against a variety of metrics to multiple
stakeholders. Nasdaq OneReport’s continued
advancement and evolution is driven by our customers’
demands for a tool which is the industry leader in
the number of frameworks and research & ratingsorganizations provided.
In 2022, Nasdaq OneReport became the first Global
Reporting Initiative (GRI) software provider to receive

GRI certification for the revised Universal and Topic
Standards, released in Fall 2021, through GRI’s Certified
Software and Tools Provider program. The platform also
added new frameworks and ratings organizations suchas the Just Capital and Bloomberg Gender Equality
Index. In preparation for upcoming regulations, Nasdaq
OneReport created an EU ESG Reporting Readiness
Module to help support clients with EU Taxonomy,
Corporate Sustainability Reporting Directive (CSRD) andSustainable Finance Disclosure Regulation (SFDR) for
organizations to easily access, share and document key
organizational stakeholders. In 2023, Nasdaq OneReportplans to continue to update its platform with the latest
regulatory frameworks, helping clients mitigate risks andaccelerate their ESG efforts.

MetrioIn 2022, Nasdaq acquired Metrio, expanding our suiteof ESG Solutions. Metrio is an end-to-end sustainability
reporting software that streamlines the way companies
collect, analyze and share their ESG data. The platform issimultaneously a one source of all truth for all corporate
sustainability data, with dashboards to track Key
Performance Indicators (KPIs) and measure progress
towards set goals, while also enabling sustainability
teams to run data collection campaigns across multiple
sites, locations and departments with a review processthat sends task reminders, flags variations and generates
an audit trail. Metrio also has built-in Corporate Social
Responsibility (CSR) reporting capabilities that allows
businesses to leverage their granular data and aggregate
into both internal and external reports.

Community Engagement

Appendix

Nasdaq is working to combine thecomprehensive capabilities of Metrio
and OneReport to form an integrated
ESG workflow and data management
platform – Nasdaq Metrio – thatwill be fully scalable with products
purpose-built for companies ofall sizes and at every level of theirsustainability and climate journey.

Metrio’s platform continued to evolve with regular
updates to improve the user experience, including
adding new features around dashboards, data collection
and a home page for a role-based overview. In 2023,
Metrio plans to continue releasing new features focusedon improving metrics to connect multiple data sources.
This will allow increased autonomy for clients to build
their own CSR reports with their own branding, whileleveraging data collected across their organizations.
Metrio and Nasdaq OneReport will have increasing
connectivity to help clients aggregate granular data from
Metrio to populate reports and disclose to regulatory
bodies like the CSRD and SEC and third-party raters andrankers within Nasdaq OneReport.

64

Nasdaq 2022 Sustainability Report

Introduction

Environmental

Governance Solutions

Puro.earth

A strong corporate governance frameworkis the cornerstone of a sound ESG program.
Nasdaq Governance Solutions provides asuite of technology and advisory services
for boards and leadership teams to workat peak performance, facilitate majordecisions, advance strategic vision anddrive stakeholder value. Our solutions
drive governance excellence by bringing
efficiency to governance and complianceprograms and fostering trusted relationships
with boards and leadership teams.

The addition of Puro.earth – the world’s firstcarbon crediting platform for engineeredcarbon removals – to Nasdaq’s ESG
solutions brings suppliers of net-negativetechnologies together with companies
with residual emissions. Puro.earth’s highintegrity carbon removals, the CO2 Removal
Certificate (CORC), are in line with theguidance of Oxford Principles for net zero,providing companies with a much-needed
tool in their efforts to reach their net zerotargets. Puro.earth is the first crediting
program with a focus on durable carbon
removal with a minimum of 100-year
storage time to obtain endorsement by theInternational Carbon Reduction and Offset
Alliance (ICROA).

In 2022, we launched the Nasdaq Center for
Board Excellence, an inclusive communityof board members, executive leaders andeducators, offering best practices andinsight into latest governance topics. The
Center’s ‘ESG and Sustainability’ advisory
council regularly publishes research on
the evolving role of boards around ESGrelated matters and how to drive action
and accountability in the boardroom. In
2023, we will continue to grow an engaged
community around the Center and bringgovernance workflow tools and services tocustomers to help enable effective in personor remote board meetings and discussions.

Puro.earth issued 213,932 CORCs
on behalf of suppliers in 2022, which
represents 213,932 tonnes of CO2 removed
from the atmosphere. The issuance equals
2.4x growth from 2021. Twenty-eight new
suppliers joined the platform during 2022,
bringing the total number of suppliers to 80
from 18 countries. Puro.earth also launched
two new removal methods during 2022:
Enhanced Rock Weathering and Biomass
Burial. The number of sales channel firms
and traders who sell CORCs to their clientshas grown during the year.

SocialGovernanceIn 2022, Puro.earth also increasedtransparency in the carbon removal market
through improvements in the Puro Registry
and the Carbon Removal Reference Price
Indexes. Integrity, trust and transparency
around CORCs are key factors needed
for building a global market for carbon
removals. A well-functioning market willbring efficiency and necessary pricesignals to stakeholders.
Given the strong demand by corporate
buyers for high quality carbon removals,
Puro.earth plans to further expand thevolume of issued and retired CORCs on
the Puro.earth platform. Puro.earth aims tolaunch additional carbon removal methods,
subject to scientific review and approval by
the Advisory Board of Puro.earth.1

ESG Solutions

Community Engagement

Appendix

213,932

CORCs issued by Puro.earth on behalf of suppliersin 2022, a 2.4x increase in issuance from 2021

80

Suppliers originatingfrom 18 countries

1

The Advisory Board is ensuring high credit-level
integrity and robust principles for science-basedcarbon removal verification and is authorized by
Puro.earth’s Board of Directors to manage thePuro.earth Standard and Crediting Rules. Puro.earthStandard and Crediting Rules include project eligibility
rules, quantification of carbon removal, validationand verification rules, conditions for issuance andretirement of credits. The Advisory Board is chaired
by Myles Allen, professor of Geosystem Science in
the School of Geography and the Environment at the
University of Oxford and the director of Oxford Net
Zero Initiative. The Advisory Board are independentand non-executive, meaning they are not Puro.earth
employees.

SDG 1365

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Nasdaq Products and Services with Select ESG Features1
Nasdaq Risk Modeling for Catastrophes
Nasdaq Risk Modelling for Catastrophes is thefirst independent, multi-vendor risk modelling
solution for reinsurance firms. It brings multiple
catastrophe risk model providers together on
one independent platform, lowering the barriers
to entry for model vendors while providing
ease of access and increased choice to themarket. The platform, powered by the opensource Oasis Loss Modelling Framework,makes it possible for clients to access anddeploy a wide range of models without theneed for multiple modelling platforms. With abroad range of catastrophe risk models acrossmultiple geographies, for perils including flood,earthquake, hurricane, windstorm, bushfire andmore, exposure management teams can quickly
evaluate and apply the models that align with
their business needs.
In 2022, Nasdaq Risk Modelling forCatastrophes’ client base increased by 60%
from 2021, fueled by a desire by
re/insurers to improve their view of risk around1

complex perils such as flooding. There is
growing demand among the risk management
community for tools that assess climaterelated physical risks. Catastrophe models
that contain climate conditioned events willplay a valuable role in this regard. Nasdaq Risk
Modelling for Catastrophes provides access tomodels that combine science, engineering andprobabilistic modelling to help clients quantify
the financial impact of climate change in termsof the damage to property caused by natural
catastrophe events.

IR Intelligence

services with ownership benchmarking, as
well as advancing companies’ understandingof their shareholders ESG preferences throughour Global Perception service. In 2022, IRIntelligence produced research on sustainable
investing trends, as well as proprietary researchon corporate climate disclosure trends. In 2023,
we plan to expand upon this foundation toprovide companies with insight and analytics
tools to monitor ESG trends, assess competitive
positioning through benchmarking of ESG
disclosures and craft ESG disclosures ascompanies strive to meet increasing demands
from investors and global regulators.

Investor Relations Intelligence (IR Intelligence)is a business within our Capital Access
Platforms segment, which provides insights
and analytics software and advisory services
products to nearly 3,300 companies globallywith the mission to help clients effectively
navigate the capital markets. In 2022, IRIntelligence focused on providing transparency
into sustainable and climate strategies
through IR Insight and shareholder advisory

Not categorized as ESG products and services for financial reporting.

SDG 1366

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Supporting the Investment Community
ESG Indexes
The OMX Stockholm 30 ESG Responsible
Index (OMXS30ESG), introduced worldwide
in June 2018, was the first ESG version ofan established exchange benchmark. It
was followed by the listing of ESG index
futures contracts in November 2018. TheOMXS30ESG is an ESG responsible versionof the OMX Stockholm 30 Index, whichis the leading share index on Nasdaq
Stockholm. The OMXS30ESG is based on
OMXS30, which consists of the 30 mosttraded securities on Nasdaq Stockholm,
followed by a systematic criteria-based
ESG screening where securities that failthe criteria are excluded. The OMXS30ESG
Index is a market cap weighted index.
The liquidity of its constituents results ina highly suitable underlying benchmark
for derivatives products. In addition,
the OMXS30ESG is also designed to be
used for structured products, such as
warrants, index bonds options, exchange
traded funds and other non-standardized
derivatives products. The composition of
the OMXS30ESG index is evaluated twice ayear, at the beginning of January and July.
In November 2021, Nasdaq expanded its
1

ESG derivative offering with the listing ofoptions based on the OMXS30ESG Index.
We manage dozens of indexes that
integrate ESG criteria into the index
methodology. We achieve this in a variety ofways, with some indexes designed purely as
ESG and others designed with ESG criteria
as an overlay to a broader investment
thesis. The index with the largest tracking
fund is the ISE Cyber Security Index.
Others include the OMX Helsinki 25 ESG
Responsible Index, the OMX Copenhagen
25 ESG Responsible Index and the Nasdaq
Future Global Sustainability Leaders Index.
In 2021, we created ESG versions of twoof our flagship indexes and now offer the
Nasdaq 100 ESG Index and the Nasdaq
Next Generation 100 ESG Index.

Green Equity Designations1
Nasdaq launched Green Equity Designations
on the Nordic markets in 2021 in response
to increased demand for sustainable
investments and extensive growth in
Nasdaq Sustainable Bond Markets. Withissuers and investors searching for more
green performance indicators on theequity market, Green Equity Designations
aim to enable visibility and transparency

for investors with two voluntary
designations, Nasdaq Green Equity
Designation and Nasdaq Green Equity
Transition Designation. Through Green
Equity Designations, Nasdaq can support
environmentally sustainable companies
or companies committed to transition toincrease their visibility, transparency andcredibility towards investors, business andother stakeholders.
The Nasdaq Green Equity Designation
is currently available for companies on
the Nasdaq Nordic stock exchanges.
As the financial ecosystem anticipates
upcoming sustainability and climate-related
regulations, Nasdaq may see increasing
interest in green equity classificationfrom companies and investors outside
the Nasdaq Nordic exchanges. In March
2023, the World Federation of Exchanges(WFE) launched its classification standard
for Green Equity with reference to theexisting model from Nasdaq’s Green
Equity Designation, highlighting Green
Equity Designation’s importance inhelping investors assess companies thatare generating revenue from products
and services that contribute to positiveenvironmental outcomes.

Green Equity Designations are only available on Nasdaq Nordic stock exchanges.

SDG 1367

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Nasdaq Sustainable Bond Network
The Nasdaq Sustainable Bond Network, launched in late 2019, is a global platformthat aims to increase transparency for environmental, social and sustainable bonds.
The Nasdaq Sustainable Bond Network connects issuers of sustainable bonds withinvestors, empowering them to evaluate impact and make informed investment decisions
on sustainable bonds. The platform allows issuers of sustainable bonds to make theirsustainable bond data more accessible to investors and other stakeholders. Investors canin turn use the platform to evaluate, track and create impact reports based on issuers’ ESG
bond reporting. The database simplifies sustainable investing with an intuitive, easy-touse solution that allows investors to discover, compile and compare sustainable bonds aswell as generate impact reports. The platform also provides issuer-level information on UN
Sustainable Development Goals allocation.
In 2022, we launched functionalities that report on the EU taxonomy alignment of projects
financed by issuers’ green and sustainable bonds. Furthermore, we reached coverage ofmore than 1,500 issuers and 14,000 securities globally.
Investors in sustainable bonds are increasingly reporting on the impact of their investments
and how their proceeds are allocated. We expect this trend to continue while seeing a larger
incorporation of issuer-reported sustainable bond data in investment due diligence.
Total Number of Issuers and Bonds on the Nasdaq Sustainable Bond Network
As of December 31

2022

2021

2020

Issuers

1,550

1,012

323

Bonds

14,222

8,928

4,600

1,550 14,000+
Total issuers

Bonds listed

88

Countries represented
globally on our network

SDG 1368

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Nasdaq Sustainable Debt Market
The Nasdaq Sustainable Debt Market is comprised of dedicated segments for listing
green, social, sustainability and sustainability-linked bonds, structured products andcommercial papers.
Our sustainable debt markets are designed to highlight sustainable investment
opportunities to investors with a green, social or sustainable investment agenda. It is open
to all types of issuers that are looking to issue securities that meet our listing criteria,
which are based on the green and social bond principles as well as the sustainabilitylinked bond principles, for which the International Capital Markets Association (ICMA) acts
as a secretariat.
Number of Listings and Issuers on the Sustainable Debt Market
As of December 31

1

2022

20211

20201

Listings

471

424

293

Issuers

129

108

78

2021 and 2020 figures have been restated as a result of double-counting issuers with debt instruments on several
markets and to account for all Nasdaq European exchanges.

Macro-economic factors had a negative effect on the Nordic debt markets in 2022 but
sustainable debt markets continued to grow, emphasizing the increasing importance ofsustainability throughout the financial markets. The number of sustainable debt instruments
listed on Nasdaq grew by 11% during 2022 and the volume of listed bonds grew by 27%.
The growth was mainly driven by new, large issuers joining the market (e.g., the inaugural
Danish sovereign green bond listed on Nasdaq Copenhagen), as well as a wider adoptionof sustainability-linked bonds in the Nordic region. Sustainability-linked bonds allow issuersthat lack large capex but have set out ambitious sustainability targets to join the broader
sustainable debt markets and can spur the overall markets’ growth in the coming years byallowing new sectors to participate.

11%

growth in the number ofsustainable debt instruments
listed on Nasdaq during 2022

SDG 1369

Nasdaq 2022 Sustainability Report

ESG Data Hub
ESG Data Hub is a data solution offering
investors and other stakeholders easy
access to a wide range of comprehensive
ESG data sets, accompanied by detailed
product descriptions, selling points anduse cases. The platform enables users
to find data sets relevant to specific UN
Sustainable Development Goals (SDGs)
providing investors with visibility on the
ESG impacts of their investments. Data sets
within the product are wide ranging – they
assist our customers with their own projects
and the impact is at the customer level.
Demand for the data is driven by a customer
move away from broad ratings and insteada move towards understanding in granulardetail the different aspects of ESG. For
many customers, ratings no longer givea representative picture of a company’s
complete ESG picture. The move towards
granular data sets started in 2022 andremains a growing segment.

Introduction

Environmental

In 2022, we added several new data sets tothe product from third party providers. We
also added our sustainable bond network
data to the platform. For 2023, we continue
to look for unique data partners to add tothe solution, based on feedback and theneeds of customers. We plan to integrate
ESG data into our broader data marketplace,Nasdaq DataLink.

ESG FootprintESG Footprint is an easy-to-implement
platform that measures the global
sustainability effect of a portfolio andindividual securities. Through an intuitive
dashboard, investors and managers haveaccess to the real-life effects of each
investment, along with alternatives that may
better suit an individual’s sustainability goals.

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Within ESG Footprint, there are multiple
datasets that provide insight into thecore impact of business and investment
opportunities on SDGs. These datasets (SDG
Signals, SDG Fundamentals, SDG CAPX)
allow investors to evaluate companies’alignment against the SDG framework.
In 2022, we added functionality that helps
customers meet their SFDR requirements.
In addition, we launched the product witha group of 20 banks in Denmark that areproviding SFDR overlays for all their retailcustomers. In 2023, we continue to invest
in the product and are looking to add an
EU Taxonomy overlay while continually
improving data quality.

The tool gives investors insight into positive
and negative flags for companies within
their holdings depending on criteria set
by the customer. We have seen growing
demand for regulatory solutions, particularly
SFDR and EU Taxonomy.

SDG 1370

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Nasdaq Products and Services with
Select ESG Features1
eVestment Diversity & Inclusion (D&I) and ESG
Data in Asset Management
eVestment is a leading institutional investment
database and analytics platform acquired by Nasdaq
in 2017. To meet increasing demand for transparent
and standardized D&I and ESG data from institutional
stakeholders, eVestment launched multiple initiatives
to provide a centralized resource in collaboration with
consultants, asset managers, asset owners and key
industry organizations. We partner with key industry
parters to enhance the platform’s breadth of data.

1

Not categorized as ESG products and services for financial reporting.

D&I Data

ESG DataeVestment began collecting D&I data in collaboration with
the Institutional Investing Diversity Cooperative (IIDC)
in 2021. The D&I questionnaire gives asset managers an
opportunity to provide narrative commentary on their firms’
D&I initiatives and statistics. In partnership with FCLTGlobal
and the Institutional Limited Partners Association (ILPA),
eVestment also created a new diversity metrics template anddata collection capabilities for its private markets reporting
solutions in 2022. The data includes information on diversity
metrics for investment company firm ownership, investmentcommittee members and investment professionals, aswell as aggregated diversity metrics for board and senior
management of a fund’s portfolio companies.

In 2020, eVestment launched an ESG questionnaire to powerrobust investment research providing opportunity for asset
managers to articulate their approach to ESG with compelling
proof points. In 2022, the questionnaire was expanded withmajor enhancements to the proxy voting and engagement
data designed to better understand process and outcome,add more questions around alignment (SDGs and SFDR) as
well as introduce new climate sections at both the firm and the
product level. To date, more than 50% of active products oneVestment are providing responses to the ESG questionnaire,
while about 45% of firms are providing firm level information.
Usage of eVestment’s ESG data has tripled since the 2020
questionnaire rewrite, reflecting not only the increased valueof the data, but the increased importance of ESG data in theinvesting landscape.

SDG 1071

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialSupporting Clients through Researchand Education
Throughout 2022, we coordinated several
events and leveraged our expertise andresearch capabilities to publish thought
leadership on a range of relevant topics.
On our ESG Solutions Resource Center,
we united our knowledge and insights
to support our corporate and investor
communities as they seek to accelerate
sustainable, inclusive growth. For examplesof our research and educational materials,
please see Nasdaq's Expert Insights andQuarterly ESG Trend Reports on the right.

Governance

ESG Solutions

Our Expert Insights ​Community Engagement

Appendix

Our Quarterly 2022 ESG Trends Report​s

WebinarIn our Green Voices Newsletter, we gathered
our latest updates, insights and inspirationon all things ESG, facilitating a continuous
dialogue between investors, issuers andother stakeholders. Topics covered by theGreen Voices Newsletter include: ​Demystifying ESG Raters:
An Insider's Perspective
on Improving Your Score
W AT C H T H E W E B I N A R• ESG & Climate Trends​

Guide• Carbon Removal​

Buyer's Guide to ESG DataManagement, Reporting,Assurance & Disclosure
Software• Net-Zero Strategies​• ESG Data & Reporting​• The Green Transition​• Nasdaq’s quarterly ESG Trends Reports

DOWNLOAD THE GUIDE

Report28

white papers authored toshare ESG-insights with
the industry

4

ESG Trendsetters episodes
were published to facilitatesharing of best practices in
ESG and sustainability

43

panel discussions and industry
events were led to encourage
innovation and progress insustainability practices

Dissecting the ESG Landscape:A Nasdaq & Corporate Board
Member Report
DOWNLOAD THE REPORTWhitepaper

Lessons for Early
Stage Reporters
D OW N LOA D T H E W H I T E PA P E R

72

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

AppendixCommunity Engagement: Enabling Positive Outcomes

2022 Highlights

In a year marked by constant change, Nasdaq
remained committed to our Purpose. In 2022, throughstrategic initiatives and thoughtful partnerships, wedelivered over $6,000,000 in impact; an investmentthat accelerated our efforts globally, strengthened ourFoundation footprint and moved us that much closer toa more sustainable and prosperous future for all.

1.5K
hours volunteeredby employees

11partnership organizations
supported through Nasdaq’s
Quarterly Grant Program

3

partnership organizations selected
for Nasdaq Foundation’s New
Investor Initiative

Jailan Griffiths
Vice President and Global Head of Purpose, Nasdaq

1,000 18,000+

hours of education provided by the
Nasdaq Entrepreneurial Center

entrepreneurs served by the
Nasdaq Entrepreneurial Center80

small businesses in emerging
economies supported by the
Nasdaq Entrepreneurial Center73

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialNasdaq Purpose

The Nasdaq Foundation

As part of Nasdaq’s Purpose, we arededicated to creating lasting, positivechange within our Company and thecommunities we serve. Nasdaq employees
take pride in being active in our community
initiatives. Through our Nasdaq GoodWorks
Corporate Responsibility Program, we havecommitted to supporting the communities
in which we live and work through various
volunteer initiatives.

Relaunched in 2020, the Nasdaq Foundation
has deepened its commitment to advanceeconomic progress for all by making
markets work for the benefit of more people
across society. The Nasdaq Foundation
addresses systemic barriers faced byunder-represented communities in theirefforts to generate and sustain wealth.
Over the past year, the Nasdaq Foundation
has continued to make tremendous
strides toward our mission of reimaging
investor engagement and diversifying
entrepreneurship, growing our networkof partners through the Quarterly Grant
Program and the New Investor Initiative.

We provide employees with two paid days offeach year to volunteer for charitable concerns
or community projects. In addition, Nasdaq
organizes team events and company-widedays of service to encourage everyone totake advantage of this benefit. We also matchcharitable donations of all Nasdaq employees
and contractors up to $1,000, or more incertain circumstances, per calendar year.
GoodWorks is Nasdaq’s signature
engagement program, helping to connect
employees with the causes, charities
and communities that they support. The
Goodworks program empowered more than120 employee volunteers to participate inover 60 individual and team events. Nasdaq
employee donors generated approximately$1,035,500 in impact for over 640 charitable
and community recipients. Additionally,
Nasdaq employees volunteered more than
1,500 hours in 2022.

In 2022, the Nasdaq Foundation selected
11 partnership organizations through the
Quarterly Grant Program. The services
offered through these partnerships provide
a wide range of support for Black, Latinx
and Indigenous founders and entrepreneurs,with a strong focus on women.

Governance

ESG Solutions

Community Engagement

Appendix

The New Investor Initiative is part of the
Nasdaq Foundation’s effort to fill in the next
piece of our strategic initiatives: a portfolio
of programs focused on tackling overlooked
barriers for people of color, particularly
women of color, to participate in the capital
markets. In 2022, the Foundation selected
three partnership organizations. These
organizations are acting on different frontsof the challenge by creating a new set ofrole models, educational activations andconducting community-based researchto create a stronger investor identity forunderrepresented communities.
For more information, please see our2022 Impact Snapshot and the Nasdaq
Foundation 2022 Annual Report.

Nasdaq’s Chief Legal, Regulatory& Risk Officer was one of 208
general counsels that signed
a letter urging Congress toincrease the budget for the
Legal Services Corporation, a501(c)3 non-profit corporation
established by the U.S.
Congress that seeks to ensure
equal access to justice under
the law for all Americans.

GRI 413 | GRI 413-1 | GRI 413-2
SDG 5

74

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Nasdaq Entrepreneurial Center
The Nasdaq Entrepreneurial Center (theCenter) is an independent non-profit thatis building a better path for entrepreneurs
worldwide. Established in 2014 with thesupport of the Nasdaq Foundation, theCenter is improving inclusion, access andknowledge in entrepreneurship.

to the next five years, the Center’s ongoingcommitment for accessible entrepreneurial
ESG education is to increase the number ofentrepreneurs served with ESG education by
10%, 20% and 40% by 2023, 2025 and 2027,
respectively (from a 2022 baseline of 221
entrepreneurs).

The Center delivers free education to morethan 170 countries to meet the real timeneeds of entrepreneurs and translates
those needs into actionable data that isshared with policy makers and academic
institutions around the world to build more
opportunities for all entrepreneurs. Since its
inception, the Center has supported over
70,380 entrepreneurs, almost half of whom
are female and more than 67% of whom areentrepreneurs of color.

In addition, the Center is committed toproviding hands-on support for founders
concentrating on the UN SDGs throughits Milestone Makers program, where atargeted group of entrepreneurs receive
individualized business mentoring,coaching, training and resources all to help
them set, hit and celebrate critical company
growth milestones. In 2022, the Centerhad 53 participants accelerate throughthe Milestone Makers UN SDG-focusedprogram. The Center’s goal for 2023 and thesubsequent two years, is to maintain thisnumber. The Center intends to achieve thisby prioritizing outreach and partnerships
in support of social entrepreneurs anddeepening its storytelling around graduatesof current and past cohorts to inspire new
applicants to apply to this program.

In 2022, the Center served approximately
18,640 entrepreneurs, provided over 1,000
hours of education and supported small
business in over 80 emerging economies.
The Nasdaq Entrepreneurial Center iscommitted to advancing ESG education forentrepreneurs across the world. In 2022,
the Center supported 221 entrepreneurs
with ESG-related education. Looking ahead

For more information visit the Nasdaq
Entrepreneurial Center website.

GRI 413 | GRI 413-1 | GRI 413-2
SDG 8

SDG 1075

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Appendix76Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

ESG Data Tables
Environmental Data
GHG Emissions

Scope 1:

Scope 2:

Scope 3:2

2022 Emissions(MT CO2e)2021 Emissions(MT CO2e)2020 Emissions(MT CO2e)

Annual MT
Difference
2022 vs 2021

Annual %Difference
2022 vs 2021

On-Site Combustion

52.5

0.5

2.7

52.0

NM1

Sub-Total

52.5

0.5

2.7

52.0

NM1

Office Space (location-based)

5,843

6,001

7,027

(158)

(2.6%)

Data Centers (location-based)

11,251

8

12,812

14,638(1,561)(12.2%)

Office Space (market-based)

149

-

-

149

-

Data Centers (market-based)

-

-

-

-

-

Sub-Total (location-based)

17,094

18,8138

21,665(1,719)(9.1%)

2

Categories 4, 9, 10, 11, 12, 14 were not included, as they are not applicable to Nasdaq’s business
operations.

3

Scope 3, Category 1 and Category 2 only included tangible goods and services in 2020 and
Scope 3, Category 1 and Category 2 included tangible and intangible goods and services in 2021
and 2022.

42020 Scope 3, Category 6 travel data is limited to data provided by third party travel vendors.
The data gathering process for 2021 and 2022 improved and includes data provided by third
party travel vendors and by corporate card spend.

Note: All the emission data was calculated in accordance with the GHG Protocol guidelines.
1

NM: Not Meaningful. While the percentage increase in Nasdaq’s Scope 1 emissions is substantial,
the gross total increase in YOY emissions remains minimal. The increase is due to methodology
enhancement on moving corporate card gasoline purchases from Scope 3 to Scope 1.

1. Purchased Goods & Services3

59,213

68,34038,795(9,127)(13.4%)

2. Capital Goods3

6,297

3,538

10,219

2,759

78.0%

3. Fuel- & Energy-Related Activities

2,016

1,3399

N/A

677

50.6%

5. Waste Generated in Operations

184

132

222

52

39.4%

14,325

1,636

3,493

12,689775.6%

5

7. Employee Commuting

1,319

993

2,841

326

32.8%

The total for all scopes integrates location-based Scope 2 emissions, not market-based Scope 2
emissions.

6

8. Upstream Leased Assets6

223

8599

N/A

(636)

(74.0%)

Upstream leased assets include emissions from operation of assets leased by the company andnot included in Scope 1 and 2.

13. Downstream Leased Assets7

150

169

N/A

(19)

(11.2%)

7

Downstream leased assets include emissions from operations of assets leased to other entities.

8

2,931

1,870

N/A

1,061

56.7%

86,65878,8769

55,570

7,782

9.9%

Our 2021 Scope 2 location-based emissions were recalculated from our prior reported 2021
Scope 2 emissions. For our 2022 and recalculated 2021 Scope 2 location-based emissions, we
implemented a new, updated emissions methodology using location-specific emission factors foreach of our U.S. locations, rather than a U.S. average emission factor.

103,805

97,69077,238

6,115

6.3%

9

2021 GHG emissions were recalculated to add Category 3 and Category 8 in order to align to our
SBTi-approved base year.

6. Business Travel4

15. Investments
Sub-Total
TOTAL5

8,9

GRI 302-1 | GRI 305-1 | GRI 305-2 | GRI 305-3 | GRI 305-5
WEF Core 777Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Emissions Intensity
The table below shows the emissions per full time employee and per each million of U.S. dollars of revenue.
2022

2021

2020

Net Revenue (in $ million)$3,582$3,420$2,903

Employee Headcount

6,377

5,814

4,830

Scope 1:On-Site Combustion
Sub-Total

Scope 2:

Scope 3:Emissions(MT CO2e)Emissions
per Employee(MT CO2e)Emissions per$ Million Revenue(MT CO2e)Emissions(MT CO2e)Emissions
per Employee(MT CO2e)Emissions per$ Million Revenue(MT CO2e)Emissions(MT CO2e)Emissions
per Employee(MT CO2e)Emissions per$ Million Revenue(MT CO2e)

52.5

0.01

0.01

0.5

-

-

2.7

-

-

52.5

0.01

0.01

0.5

-

-

2.7

-

-

Location-based

17,0942.68

4.77

18,8131

3.24

5.50

21,665

4.49

7.46

Sub-Total

17,0942.68

4.77

18,8131

3.24

5.50

21,665

4.49

7.46

1. Purchased Goods & Services

59,213

9.29

16.53

68,340

11.75

19.98

38,795

8.03

13.38

2. Capital Goods

6,297

0.99

1.76

3,538

0.61

1.03

10,2192.12

3.52

3. Fuel & Energy Related Activities

2,016

0.32

0.56

1,3392

0.23

0.39

-

-

-

184

0.03

0.05

132

0.02

0.04

222

0.05

0.08

5. Waste
6. Business Travel

14,325

2.25

4.00

1,636

0.28

0.48

3,493

0.72

1.20

7. Employee Commute

1,319

0.21

0.37

993

0.17

0.29

2,841

0.59

0.98

8. Upstream Leased Assets

223

0.03

0.06

8592

0.15

0.25

-

-

-

13. Downstream Leased Assets

150

0.02

0.04

169

0.03

0.05

-

-

-

2,931

0.46

0.82

1,870

0.32

0.55

-

-

-

Sub-Total

86,658

13.59

24.19

2

78,876

13.57

23.06

55,570

11.51

19.14

TOTAL (Location-Based)

103,805

16.28

28.97

1,2

97,690

16.80

28.56

77,238

15.99

26.61

15. Investments

Note: Scope 3, Category 1 & Category 2 included tangible and intangible goods and services in 2021. Scope 3, Category 1 & Category 2 only included tangible goods and services in 2020.
1

Our 2021 Scope 2 location-based emissions were recalculated from our prior reported 2021 Scope 2 emissions. For our 2022 and recalculated 2021 Scope 2 location-based emissions, we implemented a new, updated emissions methodology using location-specific emission factors for each of our U.S.
locations, rather than a U.S. average emission factor.

22021 GHG emissions were recalculated to add Category 3 and Category 8 in order to align to our SBTi-approved base year.

GRI 302-3 | GRI 305-4

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Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Energy Consumption
Nasdaq’s energy consumption has decreased due to our optimized leasing strategy and improved data quality.
The table below breaks down energy consumption within Nasdaq.
Energy Consumption Within Nasdaq (MWh)

2022

2021

2020

64,88275,14362,364

1,173

1,694

1,242

1,163

1,676

1,229

10

17

13

Total Electricity and Steam Consumption

64,86870,78759,900Electricity Consumption

64,20070,78759,900668--

Total Renewable Electricity Consumption

64,20070,78759,900Pre-negotiated renewable Energy & vPPAs

54,10460,77749,272

Renewable Energy Certificates (RECs)

10,096

10,01010,628% of Renewable Electricity

100%

100%

100%

Total Energy Consumption
Non-Renewable Fuel Consumed

1

Natural Gas

1

Diesel/gasoline

1

Steam and Heat Consumption

2

1

Includes both direct and indirect fuels consumed.

2

Steam and heating data not available in 2021 and 2020.

The table below shows a breakdown by region of the Company's total energy use across Scope 1 and Scope 2 categories.
2022
MWh

2021

2020

Scope 1

Scope 2

Total

Scope 1

Scope 2

Total

Scope 1

Scope 2

Total

Americas11

48,041

48,052

0.1

52,03452,0340.3

42,17042,170

APAC

3

2,702

2,705

-

2,754

2,754

-

2,926

2,926

EMEA

-

14,125

14,125-

20,355

20,355-

17,26817,268Total

1464,86864,8820.1

75,14375,1430.3

62,36462,364

GRI 302 | GRI 302-1 | GRI 302-2 | GRI 302-4

79Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

The table below breaks down the 2022 Scope 2 total energy consumption by country.
Nasdaq purchases a significant portion of its Scope 2 electricity from pre-negotiated renewable sources and the remaining is procured using Renewable Energy Certificates (RECs) resulting in net-zero, market-based Scope 2 emissions
for our electricity. This aligns to our science-based targets goals to procure 100% renewable electricity annually.

Country

Total Energy Consumption
MWh/Year

Total Electricity Consumption
MWh/Year

Renewable Electricity
MWh/Year% Renewable Electricity

Total Scope 2 Location Based
Emissions (MT CO2e)

Total Scope 2 Market Based
Emissions (MT CO2e)Australia

1,463

1,463

1,463

100%

950

-

Belgium

1

1

1

100%

-

-

Canada

3,778

3,600

3,600

100%

492

54

4

4

4

100%

2

-

Denmark

351

160

160

100%

51

33

Estonia

118

118

118

100%

71

-

Finland

167

167

167

100%

12

-

France

95

95

95

100%

5

-

Germany

332

332

332

100%

118

-

Hong Kong

144

144

144

100%

92

-

Iceland

108

108

108

100%

-

-

India

698

698

698

100%

483

-

Italy

17

17

17

100%

5

-

China

Japan

47

47

47

100%

22

-

Latvia

114

114

114

100%

12

-

Lithuania

509

398

398

100%

73

19

Netherlands

350

350

350

100%

110

-

Norway

154

154

154

100%

1

-

Philippines

215

215

215

100%

152

-

Singapore

128

128

128

100%

50

-

GRI 302-2

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Appendix

Total Energy Consumption
MWh/Year

Total Electricity Consumption
MWh/Year

Renewable Electricity
MWh/Year% Renewable Electricity

Total Scope 2 Location Based
Emissions (MT CO2e)

Total Scope 2 Market Based
Emissions (MT CO2e)

Spain

7

7

7

100%

1

-

S. Korea

3

3

3

100%

1

-

Sweden10,310

10,310

10,310

100%

148

-

UK

1,489

1,489

1,489

100%

328

-

3

3

3

100%

1

-

USA

44,26344,07544,075100%

13,91443

Total

64,86864,20064,200100%

17,094149

Country

Ukraine

The table below breaks down the Company's total energy use across Scope 1 and Scope 2 categories by country.
2022
MWh

2021

2020

Scope 1

Scope 2

Total

Scope 1

Scope 2

Total

Scope 1

Scope 2

Total

Australia

-

1,463

1,463

-

1,621

1,621

-

1,573

1,573

Belgium

-

1

1

-

17

17

-

17

17

Canada

-

3,778

3,778

-

3,218

3,218

-

1,763

1,763

China

-

4

4

-

16

16

-

12

12

Denmark

-

351

351

-

146

146

-

114

114

Estonia

-

118

118

-

118

118

-

24

24

Finland

-

167

167

-

193

193

-

161

161

France

-

95

95

-

20

20

-

16

16

Germany

-

332

332

-

412

412

-

556

556

Hong Kong

-

144

144

-

174

174

-

174

174

Iceland

-

108

108

-

103

103

-

103

103

India

3

698

701

-

552

552

-

652

652

Italy

-

17

17

-

15

15

-

3

3

GRI 302 | GRI 302-2

81Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance2022

ESG Solutions

Community Engagement

2021

Appendix

2020

MWh

Scope 1

Scope 2

Total

Scope 1

Scope 2

Total

Scope 1

Scope 2

Total

Japan

-

47

47

-

37

37

-

30

30

Latvia

-

114

114

-

77

77

-

43

43

Lithuania

-

509

509

-

357

357

-

426

426

Netherlands

-

350

350

-

459

459

-

719

719

Norway

-

154

154

-

127

127

-

113

113

Philippines

-

215

215

-

165

165

-

290

290

Singapore

-

128

128

-

186

186

-

192

192

Spain

-

7

7

-

8

8

-

1

1

S. Korea

-

3

3

-

3

3

-

3

3

Sweden-10,310

10,310-15,95915,959-12,654

12,654

UK

-

1,489

1,489

-

2,332

2,332

-

2,306

2,306

Ukraine

-

3

3

-

12

12

-

12

12

USA

11

44,26344,2740.1

48,816

48,8160.3

40,40740,407

Total

14.0

64,86864,8820.1

75,14375,1430.3

62,36462,364

GRI 302 | GRI 302-2

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Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Waste
The tables below represent the disposal and treatment of waste generated in Nasdaq’s global operations.
2022
Waste and Recycling(Weight in MT)

2022
Waste and Recycling
Emissions (MT CO2e)

2021
Waste and Recycling(Weight in MT)

2021
Waste and Recycling
Emissions (MT CO2e)

2020
Waste and Recycling(Weight in MT)

2020
Waste and Recycling
Emissions (MT CO2e)

Incinerated

Landfilled

Recycled/
Composted

Incinerated

Landfilled

Recycled/
Composted

Landfilled

Recycled/
Composted

Landfilled

Recycled/
Composted

Landfilled

Recycled/
Composted

Landfilled

Recycled/
Composted

48

114

108

21

59

9

179

90

29

12

47

74

14

2

APAC

-

10

8

-

6

1

78

31

13

5

48

38

14

1

EMEA

1

71

106

-

37

8

23

22

4

5

37

67

11

1

Total

49

195

222

21

102

18

280

143

46

22

132

179

39

4

RegionAmericasNote: Nasdaq has implemented a program to periodically audit the waste of our key offices. Whenever possible, Nasdaq’s actual waste was included in the calculation; otherwise, a proportional share was determined using occupied square footage. If waste data was completely unavailable, estimates were basedon an average per square foot for waste from collected from our waste audits.

Nasdaq’s 2022 waste was affected by our offices reopening, an increase in employee count and our acquisition of Verafin. In 2022, we began quantifying the waste that was incinerated instead of just listed as landfill.

Water
Water consumption data represented in the tables below was obtained directly from utility providers and/or from landlords or datacenter operators.
2022 Water Consumption1,2

2022 Water Emissions

2021 Water Consumption1,2

2021 Water Emissions

2020 Water Consumption1,2

2020 Water Emissions

Water (Kiloliters)

Emissions (MT CO2e)

Water (Kiloliters)

Emissions (MT CO2e)

Water (Kiloliters)

Emissions (MT CO2e)

Americas20,857

23

27,967

34

83,260

20

APAC

4,213

4

4,728

6

9,832

2

EMEA

14,10516

19,04623

30,178

7

Total

39,17543

51,741

63

123,270

29

Region1

For Nasdaq office space water consumption, where the only data available was aggregated for the entire building, the Nasdaq portion of the water was calculated based on the percentage of Nasdaq occupied space within the building. Where no water consumption data at all could be obtained for a Nasdaq
office location, data was calculated using assumptions based on the number of employees, the square footage of the office, the infrastructure within the building and the green certification for the building (if applicable).

2

For Nasdaq datacenter water consumption, where only data aggregated from the operator was available, the Nasdaq portion of the water was calculated based on the percentage of racks within the datacenter occupied by Nasdaq. Where no water consumption data could be obtained for a Nasdaq
datacenter location, data was calculated using assumptions based on the number of racks occupied by Nasdaq, the infrastructure within the building and the green certification for the building (if applicable).

Nasdaq’s water consumption has decreased in 2022 partially due to better data quality and recording techniques.
GRI 303-5 | GRI 306-3 | GRI 306-4 | GRI 306-5

83

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Environmental

SocialGovernance

ESG Solutions

Community Engagement

AppendixSocial Data
Unless otherwise indicated, social data tables exclude employees of non-wholly owned consolidated subsidiaries.

Global Workforce by GenderGlobal Workforce by Employee Type

2022

20211

2020

Full-time male employees

4,019

3,202

3,116

Full-time female employees

2,258

1,775

1,652

Full-time undisclosed employees

16

3

11

Full-time non-binary employees

2

1

-

6,295

4,981

4,779

Total number of full-time employees
Part-time male employees

33

25

20

Part-time female employees

33

32

31

Total number of part-time employees

66

57

51

Employees of non-wholly owned consolidated subsidiaries

16

NR

-

6,377

5,038

4,830

Total employees

Note: Data on this page uses the traditional gender categories of male and female as required in our reports to the U.S. government. Nasdaq’s reporting in this manner does not represent our position on the issue and we deeply respect that gender is not binary.
1

Excludes Verafin employees (acquired in February 2021).

NR: Not Reported

GRI 2-7
SASB TC-SI330a.3

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ESG Solutions

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Appendix

Number of Employees by Employment Type

20221

20212

20202

Permanent contract – male employees

4,052

3,227

3,136

Permanent contract – female employees

2,291

1,807

1,683

Permanent contract – undisclosed employees

16

3

11

Permanent contract – non-binary employees

2

1

-

6,361

5,038

4,830

Fixed-term or temporary contract – male employees3

14

13

81

Fixed-term or temporary contract – female employees3

12

12

49

Total fixed-term or temporary contract employees

26

25

130

Regional Breakdown of Workforce1

2022

2021

2020

Americas – male

2,251

2,037

1,459

Americas – female

1,260

1,094

776

Total number of Americas employees

3,520

3,131

2,235

EMEA – male

1,134

1,133

1,129

EMEA – female

613

596

573

Total number of EMEA employees

1,751

1,729

1,702

Asia – male

667

583

548

Asia – female

418

365

334

1,090

948

882

Total number of undisclosed employees

16

5

11

Total number of non-binary employees

2

1

-

Total permanent contract employees

1Includes Verafin employees.

2

Excludes Verafin employees.

3

Fixed term or temporary contract employees are employed for a limited period of time.

Total number of Asia employees

1

Environmental

Includes Verafin employees.

GRI 2-7 | GRI 2-8
SASB TC-SI330a.3

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Community Engagement

Appendix

Gender by Level
2022

2021

2020

Career Level1

FemaleMale

Undisclosed

Non Binary

FemaleMale

Undisclosed

Non Binary

FemaleMale

Undisclosed

Executive

23.7%

76.3%

-

-

24.2%

75.8%

-

-

23.8%

75.7%

0.5%

Senior

30.8%

69.3%

0.4%

-

30.3%

69.4%

0.3%

-

29.4%

70.4%

0.2%

Mid

36.7%

63.3%

0.3%

-

35.2%

64.7%

-

0.1%

32.9%

67.0%

0.1%

Entry

40.8%

59.2%

0.4%

0.1%

40.6%

59.3%

0.1%

-

42.4%

57.1%

0.5%

Note: Totals may not add up to 100% due to rounding to the closest tenth decimal point.
1

Calculations exclude employees of Verafin and Metrio.

Gender at the Managerial Level (U.S. Only)
Manager is defined by a Nasdaq regular employee with at least one direct report.
2022
Managerial

2021

2020

FemaleMale

Undisclosed

Non-binary

FemaleMale

Undisclosed

Non-binary

FemaleMale

Undisclosed

38.9%

61.1%

-

-

35.6%

64.4%

-

-

31.4%

68.5%

0.1%

2022
Management-level employees in revenue generating functions1
1

2021

FemaleMale

Female

Male

49.7%

50.3%

39.1%

60.9%

FemaleMale

Female

Male

15.0%

85.0%

18.0%

82.0%

Calculations exclude employees of Verafin and Metrio.

2022
Management-level employees in STEM related fields1
1

2021

Calculations exclude employees of Verafin and Metrio.

GRI 405-1
SASB TC-SI-330a.3
WEF Core 11

86Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Workforce by Race and Ethnicity
Seniority by Race and Ethnicity (U.S. Only)
2022
Race & Ethnicity1

2021

2020

Executive

SeniorMid

Entry

Executive

SeniorMid

Entry

Executive

Senior

Mid

Entry

White

84.6%

71.8%

64.0%

57.6%

85.9%

71.0%

65.3%

57.7%

88.9%

72.8%

66.3%

57.6%

Asian

6.0%

15.3%

17.9%

16.4%

5.2%

14.4%

18.1%

18.6%

5.2%

14.9%

17.6%

19.0%

Black

4.0%

4.7%

7.1%

12.2%

3.0%

4.6%

6.8%

11.1%

2.2%

3.7%

6.7%

11.6%

Hispanic

2.7%

4.5%

5.9%

7.2%

3.7%

4.9%

5.8%

6.2%

1.5%

4.0%

5.4%

5.3%

Two or More

0.7%

1.3%

2.2%

3.0%

0.7%

2.0%

1.6%

3.3%

0.7%

2.2%

1.5%

3.4%

Pacific Islander

0.7%

-

0.3%

0.3%

0.7%

-

0.3%

-

0.7%

-

0.3%

-

Native American

-

0.5%

-

0.2%

-

0.3%

0.2%

0.2%

-

-

0.1%

0.2%

1.3%

1.8%

2.7%

3.2%

0.7%

2.9%

1.9%

2.9%

0.7%

2.5%

2.1%

3.0%

Undisclosed

Note: Totals may not add up to 100% due to rounding to the closest tenth decimal point.
1

Calculations exclude employees of Verafin and Metrio.

Race and Ethnicity at the Managerial Level (U.S. Only)
Race & Ethnicity

2022

2021

2020

White

73.7%

76.4%

76.2%

Asian

10.7%

9.9%

9.4%

Black

6.2%

5.1%

3.9%

Hispanic

4.1%

4.4%

3.6%

Two or More

2.6%

2.0%

1.9%

Pacific Islander

0.2%

0.2%

-

Native American

0.3%

0.2%

-

Undisclosed

2.3%

1.8%

5.1%

Note: Totals may not add up to 100% due to rounding to the closest tenth decimal point.
GRI 405-1
SASB TC-SI-330a.3
WEF Core 11

87Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Gender by Age
The tables below represent our global workforce by age and U.S. workforce by age and race and ethnicity.
2022

2021

2020

Under 30 Years

30-50 Years

Over 50 Years

Under 30 Years

30-50 Years

Over 50

Under 30 Years

30-50 Years

Over 50 Years

Male

21.5%

62.4%

16.1%

19.2%

62.9%

17.9%

22.2%

60.5%

17.3%

Female

26.0%

60.9%

13.1%

25.9%

59.7%

14.4%

29.9%

55.9%

14.2%

Undisclosed

50.0%

43.8%

6.3%

33.3%

33.3%

33.3%

NR

NR

NR

Non-Binary-

100.0%--

100.0%

-

NR

NR

NR

Note: Totals may not add up to 100% due to rounding to the closest tenth decimal point.
NR: Not Reported

Race and Ethnicity by Age (U.S. Only)
Race & Ethnicity

Under 30 Years

30-50 Years

Over 50 Years

White

62.5%

62.8%

71.4%

Asian

15.9%

17.4%

12.7%

Black

6.9%

8.2%

8.5%

Hispanic

8.7%

4.9%

4.6%

Two or More

3.2%

3.0%

1.6%

Pacific Islander

0.4%

0.2%

0.4%

Native American

-

0.2%

-

2.5%

3.2%

0.8%

Not disclosed
Note: Totals may not add up to 100% due to rounding to the closest tenth decimal point.

SASB TC-SI-330a.3
WEF Core 11

88

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialEmployee Turnover

1

1

1

Governance

ESG Solutions

Community Engagement

Appendix

Employee Voluntary and Involuntary Turnover Rates byRace & Ethnicity (U.S. Only)

2022

2021

Overall Employee Turnover Rates

20221

2021

2020

White

12.5%

14.3%

Voluntary

11.0%

11.5%

7.0%

Asian

13.9%

14.1%

Involuntary

2.2%

6.1%

5.5%

Black

12.1%

21.7%

Hispanic

14.8%

17.7%

Two or More

12.8%

22.2%

Pacific Islander

-

20.0%

Native American

-

50.0%

9.1%

30.6%

Calculations exclude 907 Verafin employees due to internal timing of data integration.

Employee Voluntary and Involuntary Turnover Rates by Gender

20221

2021

Male

13.1%

14.5%

Female

13.2%

14.8%

Undisclosed

8.3%

38.5%

Non-binary--

Employee Voluntary and Involuntary Turnover Rates
by Employee Level

20221

2021

Executive

7.6%

11.8%

Senior

6.3%

10.3%

Mid

12.4%

12.9%

Entry

20.1%

23.2%

Undisclosed

Calculations exclude 907 Verafin employees due to internal timing of data integration.

Calculations exclude 907 Verafin employees due to internal timing of data integration.

GRI 401-1
WEF Core 17

89Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernanceNew and Internal Hires

Percentage of open positions filled by internal hires1
1

New and Internal Hires by Level1
2022

2021

21.3%

16.1%

Calculations exclude Verafin employees.
1

1

ESG Solutions

Community Engagement

2022

Appendix

2021

Executive

1.2%

1.2%

Senior

4.7%

6.0%

Mid

47.2%

46.2%

Entry

46.9%

45.6%

Calculations exclude Verafin employees.

New and Internal Hires by Age1

2022

2021

New and Internal Hires by Race & Ethnicity (U.S. Only)1

2022

2021

Under 30 years

51.9%

50.2%

White

62.8%

57.5%

30-50 years

44.6%

43.7%

Asian

15.0%

16.2%

Over 50 years

3.5%

6.1%

Black

8.8%

9.9%

Hispanic

7.6%

8.8%

Two or More

2.9%

3.1%

Pacific Islander

0.2%

0.2%

Native American

-

0.2%

2.7%

4.2%

Calculations exclude Verafin employees.

New and Internal Hires by Gender1

2022

2021

Male

58.9%

58.4%

Female

40.6%

41.5%

Undisclosed

0.5%

0.1%

Non-binary-

NR

Undisclosed
1

Calculations exclude Verafin employees.

NR: Not Reported
1

Calculations exclude Verafin employees.

90Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Parental Leave (U.S. Only)
2022

2021

2020

Female employees who were entitled to paid parental leave

881

785

746

Male employees who were entitled to paid parental leave

1,433

1,378

1,362

Undisclosed and non-binary employees who were entitled to paid parental leave

8

2

2

Female employees who took paid parental leave

43

35

26

Male employees who took paid parental leave

50

47

30

Female employees who returned to work after paid parental leave ended

43

32

26

Male employees who returned to work after paid parental leave ended

50

45

30

Female employees who returned to work after paid parental leave ended who were still employed 12 months after their return to work

42

29

26

Male employees who returned to work after paid parental leave ended who were still employed 12 months after their return to work

48

40

29

Return to work and retention rates of female employees who returned to work after leave

98%

83%

100%

Return to work and retention rates of male employees who returned to work after leave

96%

85%

97%

GRI 401-3

91

Nasdaq 2022 Sustainability Report

Governance
Data

Introduction

Australia

Governance

ESG Solutions

Community Engagement

Appendix# of Employees

Revenue from Third-Party Sales (in Millions)

Profit/Loss Before Tax (in Millions)

Corporate Income Tax Paid on a Cash Basis, Net of Refund (in Millions)

276

125

43

13

Belgium

3

-

-

-

Canada

1,205

241

(49)

(2)

Denmark

42

51

41

8

Estonia

20

6

2

-

Finland

57

43

27

7

France6---Germany

9

-

-

-

Hong Kong

51

-

1

-

Iceland

20

12

6

1

India

431

-

4

1

Italy

6

-

-

-

Japan

14

-

-

-

S. Korea

4

1

-

-

Latvia

19

3

-

-

Lithuania

421

4

4

-

Luxembourg

-

-

3

1

Netherlands

8

-

1

-

Norway

28

19

2

2

Philippines

290

-

-

-

Saudi Arabia

-

-

-

-

Singapore

23

7

-

-

-

-

-

-

Sweden

903

425

160

43

Turkey1---

United Kingdom

199

63

15

1

Ukraine

20

-

-

-

United Arab Emirates

WEF Core 21

SocialTax Transparency

Spain

GRI 207-4

Environmental

-

-

-

-

United States

2,321

5,226

1,215

199

TOTAL

6,377

6,226

1,475

274

92

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Our Support of the United Nations Sustainable Development Goals (SDGs)
SDG

Associated SDG Targets

Nasdaq's SDG-Aligned Initiatives

5 | Gender Equality: Achieve gender equality andempower all women and girls

5.5: Ensure women’s full and effective participation and equal opportunities for leadership at all levels of decision-making
in political, economic and public life

Diversity, Equity, & Inclusion
The Nasdaq Foundation
Board Diversity Support

8 | Decent Work and Economic Growth: Promotesustained, inclusive and sustainable economic growth,
full and productive employment and decent work for all

8.3: Promote development-oriented policies that support productive activities, decent job creation, entrepreneurship,
creativity and innovation, and encourage the formation and growth of micro-, small- and medium-sized enterprises,
including through access to financial services

Capital Access Platforms: Listings (U.S. & Nordics)

9 | Industry, Innovation, and Infrastructure: Build
resilient infrastructure, promote inclusive andsustainable industrialization and foster innovation

9.3: Increase the access of small-scale industrial and other enterprises, in particular in developing countries, to financial
services, including affordable credit, and their integration into value chains and markets

Market Platforms: Marketplace Technology |European & North American Trading Services

10 | Reduced Inequalities: Reduce inequality within
and among countries

10.2: By 2030, empower and promote the social, economic and political inclusion of all, irrespective of age, sex,
disability, race, ethnicity, origin, religion or economic or other status

Nasdaq Entrepreneurial Center

9.a: Facilitate sustainable and resilient infrastructure development in developing countries through enhanced financial,technological and technical support to African countries, least developed countries, landlocked developing countries andsmall island developing States
Diversity, Equity, & Inclusion
Supplier Diversity
Nasdaq Entrepreneurial CentereVestment Diversity & Inclusion and ESG Data
10.5: Improve the regulation and monitoring of global financial markets and institutions and strengthen theimplementation of such regulation

Anti-Financial Crime

12 | Responsible Consumption and Production: Ensuresustainable consumption and production patterns

12.6: Encourage companies, especially large and transnational companies, to adopt sustainable practices and tointegrate sustainability information into their reporting cycle

Capital Access Platforms: Corporate ESG Solutions

13 | Climate Action: Take urgent action to combat
climate change and its impacts

13.2: Integrate climate change measures into national policies, strategies and planning

Decarbonization & Climate Change Strategy

17 | Partnerships for the Goals: Strengthen the meansof implementation and revitalize the Global Partnershipfor Sustainable Development

Evaluating & Engaging Our Supply Chain
13.3: Improve education, awareness-raising and human and institutional capacity on climate change mitigation,
adaptation, impact reduction and early warning

Market Platforms: European Trading Services

17.16: Enhance the Global Partnership for Sustainable Development, complemented by multi-stakeholder partnershipsthat mobilize and share knowledge, expertise, technology and financial resources, to support the achievement of the
Sustainable Development Goals in all countries, in particular developing countries

ESG Memberships

Capital Access Platforms: Investment Intelligence93Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Assurance Statements
Independent Limited AssuranceStatement on Nasdaq’s
GHG Emissions, Energy
Consumption and Employee
Data
LRQA verified Nasdaq’s 2022
greenhouse gas emissions (including
Scope 1, Scope 2 and all applicable
upstream and downstream Scope
3 emissions) energy consumption,and social data (related to employee
workforce, turnover and hires) toa limited level of assurance. Moredetails on the scope, standards and
LRQA’s conclusion can be found in
the assurance statement on right andavailable for download on our ESG
Resource Center.

LRQA Independent Assurance Statement
Relating to Nasdaq’s GHG Emissions and Social Metrics for the CY2022

This Assurance Statement has been prepared for Nasdaq, Inc. (Nasdaq) in accordance with our contract.

Terms of Engagement

LRQA was commissioned by Nasdaq to provide independent assurance of its greenhouse gas (GHG) emissions
inventory and social metrics for the Calendar Year (CY) 2022, and restatement of Base Year CY 2021 (“the Inventory”)
against the assurance criteria below to a limited level of assurance and materiality of 5% using LRQA’s verification
procedure based on ISO 14064 - Part 3 for greenhouse gas emissions. LRQA’s verification procedure is based on
current best practise and is in accordance with ISAE 3000 and ISAE 3410.
Our assurance engagement covered all activities under Nasdaq’s operational control in its global operations andspecifically the following requirements:• Verifying conformance with:• Nasdaq’s reporting methodologies for the selected datasets; and• World Resources Institute / World Business Council for Sustainable Development Greenhouse Gas
Protocol: A corporate accounting and reporting standard, revised edition (otherwise referred to as the
WRI/WBCSD GHG Protocol) for the GHG data1.
• Evaluating the accuracy and reliability of data and information for only the selected indicators listed below:• Direct (Scope 1), Energy Indirect (Scope 2) and Other Indirect (Scope 3) GHG emissions;▪ Scope 3 GHG emissions verified by LRQA consist of Category 1 Purchased Goods & Services,
Category 2 Capital Goods, Category 3 Fuel and Energy Related Activities, Category 5 Waste
Generated in Operations, Category 6 Business Travel, Category 7 Employee Commuting,
Category 8 Upstream Leased Assets, Category 13 Downstream Leased Assets, and Category 15
Investments;• Energy Consumed;• Social Metrics CYs 2021 & 2022; and• Base Year CY 2021 Restatement.
Aside from the Scope 3 emissions categories listed above, our assurance engagement excluded the data andinformation of Nasdaq’s suppliers, contractors and any third-parties mentioned in the Inventory.
LRQA’s responsibility is only to Nasdaq. LRQA disclaims any liability or responsibility to others as explained in theend footnote. Nasdaq’s responsibility is for collecting, aggregating, analysing and presenting all the data andinformation within the Inventory and for maintaining effective internal controls over the systems from which theInventory is derived. Ultimately, the Inventory has been approved by, and remains the responsibility of Nasdaq.

LRQA’s Opinion

Based on LRQA’s approach, except for the effect of the matters described in the Basis for Qualified Opinion, nothing
has come to our attention that would cause us to believe that Nasdaq has not, in all material respects:• Met the requirements of the criteria listed above; and• Disclosed accurate and reliable performance data and information as summarized in Tables 1-3 below.
The opinion expressed is formed on the basis of a limited level of assurance2 and at the materiality of 5%.
http://www.ghgprotocol.org/
The extent of evidence-gathering for a limited assurance engagement is less than for a reasonable assurance engagement.
Limited assurance engagements focus on aggregated data rather than physically checking source data at sites. Consequently,

1.

2.

the level of assurance obtained in a limited assurance engagement is lower than the assurance that would have been obtained had a reasonableassurance engagement been performed.

Workforce Seniority by Race and Ethnicity (U.S. Only)

Basis for Qualified Opinion•

Workforce by Race and Ethnicity by Age (U.S. Only)

Nasdaq has not calculated business travel emissions consistently from its data streams. This nonconformance is not material.

Quantity

Scope 1 GHG emissions
Scope 2 GHG emissions (Location-based)1
Scope 2 GHG emissions (Market-based)

1

Scope 3 Category 1 Purchased Goods & Services

Note 1: LRQA verified data and information provided in file Social Data.docx and Workday Report.xlsx received March 13, 2023

Unit

53

Tonnes CO2e

17,094

Tonnes CO2e149

Tonnes CO2e59,213Tonnes CO2e

Scope 3 Category 2 Capital Goods

6,297

Tonnes CO2e

Scope 3 Category 3 Fuel and Energy Related Activities

2,016

Tonnes CO2e

Scope 3 Category 5 Waste Generated in Operations

184

Tonnes CO2e

Scope 3 Category 6 Business Travel

14,325Tonnes CO2e

Scope 3 Category 7 Employee Commuting

1,319

Tonnes CO2e

Scope 3 Category 8 Upstream Leased Assets

223

Tonnes CO2e

Scope 3 Category 13 Downstream Leased Assets

150

Tonnes CO2e

Scope 3 Category 15 Investments

2,931

Tonnes CO2e

Energy Consumed

64,882MWh

Note 1: Scope 2, Location-based and Scope 2, Market-based are defined in the WRI/WBCSD GHG Protocol Scope 2
Guidance, 2015

Table 2. Summary of Nasdaq’s Restated Data for Base Year CY 2021:
MetricQuantity
0.49

Tonnes CO2e

18,813Tonnes CO2e

Scope 2 GHG emissions (Market-based)10

Tonnes CO2e

Note 1: Scope 2, Location-based and Scope 2, Market-based are defined in the WRI/WBCSD GHG Protocol Scope 2
Guidance, 2015

Global Workforce by Gender

LRQA’s assurance engagements are carried out in accordance with our verification procedure. The following tasks
were undertaken as part of the evidence gathering process for this assurance engagement:• interviewing relevant employees of the organization responsible for managing GHG emissions, energy andsocial data and records;• assessing Nasdaq’s GHG, energy and social data management systems to confirm they are designed to prevent
significant errors, omissions or mis-statements in the Inventory;• verifying historical GHG emissions, energy and social data and records at an aggregated level for the calendar
year 2022; and• confirming Nasdaq’s adherence to its Base Year Recalculation Policy.

LRQA’s Standards, Competence and Independence

LRQA implements and maintains a comprehensive management system that meets accreditation requirements for
ISO 14065 Greenhouse gases – Requirements for greenhouse gas validation and verification bodies for use inaccreditation or other forms of recognition and ISO/IEC 17021 Conformity assessment – Requirements for bodies
providing audit and certification of management systems that are at least as demanding as the requirements of theInternational Standard on Quality Control 1 and comply with the Code of Ethics for Professional Accountants issued
by the International Ethics Standards Board for Accountants.
LRQA ensures the selection of appropriately qualified individuals based on their qualifications, training andexperience. The outcome of all verification and certification assessments is then internally reviewed by senior
management to ensure that the approach applied is rigorous and transparent.
SignedScope 2 GHG emissions (Location-based)1

Metric

LRQA’s Approach

Dated: 26 May 2023

Unit

Scope 1 GHG emissions

Table 3. List of Nasdaq’s Social Metrics1 Verified by LRQA for CYs 2021 & 2022:

New and Internal Hires (Overall; by Age; by Gender; by Level, by Race and Ethnicity [U.S. Only])
Global Workforce by Gender

Table 1. Summary of Nasdaq’s Key GHG Emissions Data for CY 2022:
MetricEmployee Turnover (Overall; by Gender; by Level, by Race and Ethnicity [U.S. Only])

Kate Pagan
LRQA Lead Verifier
On behalf of LRQA, Inc.
2101 CityWest Blvd, Houston, TX 77042
LRQA reference: UQA00002005/ 6001952
LRQA Group, its affiliates and subsidiaries, and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'LRQA'. LRQA
assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or
howsoever provided, unless that person has signed a contract with the relevant LRQA entity for the provision of this information or advice and in that case any
responsibility or liability is exclusively on the terms and conditions set out in that contract. The English version of this Assurance Statement is the only valid version.
LRQA assumes no responsibility for versions translated into other languages. This Assurance Statement is only valid when published with the Inventory to which it
refers. It may only be reproduced in its entirety. Copyright © LRQA, 2023.

Regional Breakdown of Workforce by Gender
Workforce Gender by Level
Workforce Gender by Age
Workforce Gender at the Managerial Level
Workforce by Race and Ethnicity (U.S. Only)
Workforce by Race and Ethnicity at the Managerial Level (U.S. Only)

GRI 2-594

Nasdaq 2022 Sustainability Report

Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Independent Reasonable Assurance Statement on Nasdaq’s Supplier Data
LRQA verified Nasdaq’s 2022 U.S. addressable spend from U.S. based, diverse-owned
suppliers and suppliers by spend covering purchased goods and services and capital goods
that have SBTi targets to a reasonable level of assurance. Details on the scope, standards
and LRQA’s conclusion can be found in the assurance statement on right and available fordownload on our ESG Resource Center.

LRQA Independent Assurance Statement
Relating to Nasdaq’s Supplier Data for the calendar year 2022

This Assurance Statement has been prepared for Nasdaq, Inc. in accordance with our contract.

Terms of Engagement

LRQA was commissioned by Nasdaq, Inc. (Nasdaq) to provide independent assurance of its U.S. addressable
spend from U.S. based, diverse-owned suppliers and suppliers by spend covering purchased goods andservices and capital goods that have Science-Based Target initiative (SBTi) targets for the calendar year (CY)2022 (the Assertion). The assurance was undertaken to a reasonable level of assurance, and a materiality of
5%, using LRQA’s verification procedure. LRQA’s verification procedure is based on current best practise andis in accordance with ISAE 3000.
The assurance criteria covered the accuracy and reliability of Nasdaq’s data and information for only theselected indicators listed below:•

Percent of U.S. addressable spend1 from U.S.-based, diverse-owned2 suppliers3•

Percent of suppliers by spend1 covering purchased goods and services and capital goods that havescience-based targets4
Defined by Nasdaq as spend where Nasdaq has the ability to select the provider of the goods andservices
Defined by Nasdaq as a company that is at least 51% owned and operated by an individual or groupthat is part of a historically underrepresented or underserved group
3.
Defined by Nasdaq as Tier 1 and Tier 2 direct spend suppliers
4.
Defined by Nasdaq as targets that a supplier has set, or committed to set, in line with SBTi guidanceon “supplier or customer engagement targets” as defined in Target Validation Protocol for NearTerm Targets
1.

LRQA’s Approach

LRQA’s assurance engagements are carried out in accordance with our verification procedure. The following
tasks were undertaken as part of the evidence gathering process for this assurance engagement: interviewing relevant Nasdaq staff responsible for managing and reporting the KPIs and the related dataand information;
 completing a strategic assessment/risk analysis of each KPI to determine an adequate sample;
 recalculating sampled sources to confirm accuracy and conformance with the assurance criteria; and verifying historical data and records for Calendar Year 2022.

LRQA’s Standards and Competence

LRQA implements and maintains a comprehensive management system that meets accreditation
requirements for ISO 14065 Greenhouse gases – Requirements for greenhouse gas validation and verification
bodies for use in accreditation or other forms of recognition and ISO/IEC 17021 Conformity assessment –Requirements for bodies providing audit and certification of management systems that are at least as
demanding as the requirements of the International Standard on Quality Control 1 and comply with the Codeof Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants.
LRQA ensures the selection of appropriately qualified individuals based on their qualifications, training andexperience. The outcome of all verification and certification assessments is then internally reviewed by senior
management to ensure that the approach applied is rigorous and transparent.
LRQA is Nasdaq’s assurance provider for Greenhouse Gas Emissions reporting. This is the only additional work
undertaken by LRQA for Nasdaq and as such does not compromise our independence or impartiality.

2.

LRQA’s responsibility is only to Nasdaq. LRQA disclaims any liability or responsibility to others, as explainedin the end footnote. Nasdaq’s responsibility is for collecting, aggregating, analysing and presenting all thedata and information within the Assertion and for maintaining effective internal controls over the systems
from which the Assertion is derived. Ultimately, the Assertion has been approved by, and remains the
responsibility of Nasdaq.

SignedDated: March 10, 2023

David Hadlet
LRQA Lead Verifier
On behalf of LRQA. Inc.
1330 Enclave Parkway, Suite 200, Houston, TX 77077
LRQA reference: UQA00002005/5785182

LRQA’s Opinion

Based on LRQA’s approach, we believe that Nasdaq has, in all material respects:• Met the requirements of the criteria listed above; and• Disclosed accurate and reliable performance data and information as summarized in Table 1 below.
The opinion expressed is formed on the basis of a reasonable level of assurance and at the materiality of 5%.
Table 1. Summary of Nasdaq’s Supplier Data for Calendar Year 2022:
Indicator

Performance

U.S. Addressable spend from U.S.-based, diverse-owned suppliers

6.8%

Suppliers by spend covering purchased goods and services andcapital goods that have science-based targets

37.9%

Page 1 of 2

LRQA Group Limited, its affiliates and subsidiaries, and their respective officers, employees or agents are, individually and collectively,
referred to in this clause as 'LRQA'. LRQA assumes no responsibility and shall not be liable to any person for any loss, damage or expensecaused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract withthe relevant LRQA entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on theterms and conditions set out in that contract.
The English version of this Assurance Statement is the only valid version. LRQA assumes no responsibility for versions translated into
other languages.
This Assurance Statement is only valid when published with the Assertion to which it refers. It may only be reproduced in its entirety.
Copyright © LRQA, 2023.

Page 2 of 2

GRI 2-595

Nasdaq 2022 Sustainability Report

Introduction

Additional Resources
Nasdaq’s ESG disclosures, policies,
programs and practice statements areavailable online in our ESG Resource
Center and our Investor Relations/Annual
Reports webpage.

Environmental

SocialGovernance

ESG Material
Topics Glossary
Anti-Financial Crime & Anti-Money Laundering:
Addresses the Company's policies, procedures
and training in place to ensure the effective
establishment and implementation of a company
culture opposing money-laundering andterrorism financing.
Board Composition and Governance: Addresses
the quality, integrity and oversight of theCompany’s Board. This topic refers to diversity
factors such as gender, sexual orientation, race,
ethnicity, country of origin, nationality or cultural
background in the board nomination process;the quality of directors; their relevant industry
experience; the level of board independence;and management and oversight of ESG/
sustainability topics at the Board level.
Business Ethics & Integrity: Addresses theCompany's approach to the management of risks
and opportunities surrounding ethical conduct ofbusiness, including fraud, corruption, bribery andfacilitation payments, fiduciary responsibilities
and other behavior that may have an ethicalcomponent. This topic addresses the Company's
ability to model integrity and provide services
that satisfy the highest professional and ethicalstandards of the industry, which means avoiding
conflicts or interest, misrepresentation, bias
and negligence through training employees

ESG Solutions

adequately and implementing policies (e.g.,
Codes of Conduct) and procedures.
This topic also addresses the quality of theCompany's whistleblower program in placeallowing the anonymous reporting by an
employee, supplier or customer to expose
information, misconduct or activity that isdeemed illegal, illicit, unsafe, a waste or fraud.
Community Engagement: Addresses theCompany's involvement in the community andtheir power to bring measurable change tothe communities in which they operate anddo business. This topic includes measures topromote community investment, positive social
impact and charitable giving.
Customer Relationship Management:
Addresses the Company's actions and tools used
to manage customers, online strategy, sales anddistribution channels, customer satisfaction andcustomer protection.
Data Privacy & Cybersecurity: Addresses theCompany's management of risks related tothe collection, retention and use of sensitive,
confidential or proprietary customer data. This
topic also refers to the management of risks
related to the use of personally identifiable
information and other customer data forsecondary purposes, including marketing. Also
included are social issues that may arise fromthe Company's approach to collecting data,obtaining consent and managing customer
expectations regarding how their data is being

Community Engagement

Appendixused, or issues that may arise from incidents
such as data breaches in which personallyidentifiable information and other customer
data may be exposed. Lastly, it addresses theCompany's strategy, policies and practices
related to IT infrastructure, employee training
and other mechanisms used to ensure securityof customer data.
Decarbonization & Climate Strategy: Addresses
the Company's commitments and actions
to decarbonize its business model over thenear and long term. This topic also addresses
the processes for identifying, assessing andmanaging climate-related issues integrated
into financial and strategy planning and overallrisk management, including the implementationof the Task Force on Climate-related Financial
Disclosures (TCFD) recommendations.
This topic also addresses the management
and mitigation of energy consumption andgreenhouse gas (GHG) emissions that are under
the Company's control, including the Company's
ability to set and achieve science-based andnet-zero targets in line with the goals of theParis Agreement.
Finally, this topic addresses the Company's
approach to managing environmental risks in
its supply chain, including efforts to engage
suppliers on their environmental performance.

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Introduction

Environmental

SocialGovernanceDiversity, Equity & Inclusion: Addresses the Company’s ability to ensure its
culture, hiring and promotion practices embrace the building of a diverse
and inclusive workforce. Initiatives to support a diverse workforce include:
managerial or board level responsibility for diversity initiatives, targeted
recruitment, networking groups, mentorship programs, diversity monitoring
and/or training regarding diversity.

ESG & Sustainable Finance Products: Addresses the company's approach
to integrate ESG in its business segments and the offers or promotions of
products or services which provide an added sustainability value (e.g., ESG
Advisory, Metrio, OneReport, Puro.earth; sustainable indices and green/social bonds services; services aimed to drive stronger governance/riskpractices) compared to standard products or services.

This topic also addresses the Company's efforts to promote supplier diversity.

Executive Compensation & Incentives: Addresses the Company's program
to reward financial performance and operational excellence, effective
strategic leadership, achievement of business unit goals and objectives andperformance on material ESG/sustainability topics. This topic also refers
to the Company's ability to use compensation and incentives to compete
successfully for top talent and build an effective leadership team.

Employee Engagement & Satisfaction: Addresses the Company's
engagement activities centered on enhancing collaboration andcommunication between employees and improving their work contributions,
including mechanisms to grow employee contentment, accomplishment,satisfaction and motivation regarding their jobs and associated satisfaction
measurements and metrics.
Employee Health & Well-being: Addresses the Company’s ability tocreate and maintain a safe and healthy workplace environment. This topic
encompasses financial, physical and mental wellbeing and incorporates
corporate culture, work-life balance, compensation and benefits andrelated training.

Human Capital Management: Addresses the Company's practices,
initiatives and processes aimed at attracting and retaining top talent andsupporting employees in developing the skills necessary to succeed intheir current and next role, including regular feedback, support for careerplanning, degree and certification programs and leadership training.
Innovation & Technology: Addresses the Company's ability to fostera culture of innovation, drive productivity and increase value for its
customers. This topic also includes the Company's ability to leveragetechnology and data to deliver insights and invest in its employees to learn
leading technology skills.
Labor Practices & Human Rights: Addresses the Company's policies andprocedures to prevent discrimination and harassment and its ability to
uphold commonly accepted labor standards in the workplace, including
compliance with labor laws and internationally accepted norms & standards.
This includes but is not limited to ensuring basic human rights related tochild labor, forced labor, exploitive labor, discrimination policy, pay equality
and other basic workers' rights. This topic also addresses the Company's
human rights due diligence process, mitigation and remediation actions.

ESG Solutions

Community Engagement

Appendix

Natural Resource Consumption: Addresses the Company's impacts
on nature and its actions and commitments to mitigate them. This
topic includes the Company's approach to water consumption, waste
management and recycling, biodiversity and land use, including theimplementation of the forthcoming Taskforce on Nature-related Financial
Disclosures (TNFD) recommendations. This topic addresses the Company's
approach to assess and manage nature-related risks in its supply chain.
Policy Influence: Addresses the Company's approach to politicalcontributions and lobbying, including the Company's ability to provide
public disclosure around political activities, political involvement, lobbying
and political expenses, political contributions and lobbying spend.
Risk Management: Addresses the Company's responsibility for risk
management, including oversight, strategic direction, policies andprocedures in place to execute and implement those policies. This topic
includes an Enterprise Risk Management (ERM) framework to identify andmanage financial, operational, legal, regulatory (current and emerging),
technology, climate, nature, business and strategic risks.
Supply Chain Responsibility: Addresses the Company's approach to
managing social risks in its supply chain. This topic includes policies andprocedures related to responsible procurement practices and topics such as
human rights, labor rights, modern slavery and human trafficking.
Support for Small & Medium-Sized Enterprises: Addresses the Company’sefforts to enable small and medium-sized enterprises (SMEs) to grow bothfinancially and organically by providing access to the capital markets.
Transparency & Reporting: The Company's publicly accessible
information pertaining to its governance, stakeholders, environmental
performance and supply chain, including its adherence to leading
ESG and sustainability frameworks and standards and regulatory andlegislative disclosure mandates.

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Introduction

Environmental

SocialGovernance

ESG Solutions

Community Engagement

Appendix

Disclaimers
This report focuses on Nasdaq’s operations from January 1, 2022, through December 31, 2022, unless otherwise indicated. The report uses qualitative descriptions and quantitative metrics to describe our policies, programs, practices and performance. Note that manyof the standards and metrics used in preparing this report continue to evolve and are based on management assumptions believed to be reasonable at the time of preparation, but should not be considered guarantees. In addition, historical, current and forward-looking
sustainability-related statements may be based on standards for measuring progress that are still developing, internal controls and processes that continue to evolve and assumptions that are subject to change in the future. The information and opinions contained inthis report are provided as of the date of this report and are subject to change without notice. Nasdaq does not undertake to update or revise any such statements. The information included in and any issues identified as material for purposes of, this document may not
be considered material for SEC reporting purposes. In the context of this disclosure, the term “material” is distinct from and should not be confused with, such term as defined for SEC reporting purposes.
The information and data in this report cover Nasdaq’s owned and operated businesses and does not address the performance or operations of our suppliers or contractors unless otherwise noted.
The report includes information on topics that we have identified as significant impact topics relating to ESG matters based on our 2022 ESG materiality assessment. For more information on our significant impact process, please see page 15 of this report. All financial
information is presented in U.S. dollars unless otherwise noted.
This report contains forward-looking statements relating to Nasdaq’s operations that are based on management’s current expectations, estimates and projections. See the “Cautionary Note Regarding Forward-Looking Statements” below.
Therefore, the actual conduct of our activities, including the development, implementation or continuation of any program, policy or initiative discussed or forecasted in this report, may differ materially in the future. As with any projections or estimates, actual results or
numbers may vary.
Cautionary Note Regarding Forward-Looking Statements
Information set forth in this communication contains forward-looking statements that involve a number of risks and uncertainties. This report contains forward-looking statements relating to Nasdaq’s operations that are based on management’s current expectations,estimates and projections regarding the ESG matters described in this report. Words or phrases such as "can", "aims", "expect", "intends", "plans", "targets", "believes", "seeks", "may", "could", "should", "will", "goals", "objectives", "strategies", "opportunities" and similar
expressions are intended to identify such forward-looking statements.
Nasdaq cautions readers that any forward-looking information is not a guarantee of future performance and that actual results could differ materially from those contained in the forward-looking information. Such forward-looking statements include, but are not limitedto (i) statements about our climate, ESG or sustainability policies, programs, products or initiatives, (ii) projections relating to our future financial results, total shareholder returns, growth, trading volumes, products and services, order backlog, taxes and achievement ofsynergy targets, (iii) statements about the closing or implementation dates and benefits of certain acquisitions or divestitures and other strategic, restructuring, technology, de-leveraging and capital return initiatives, (iv) statements about our integrations of our recent
acquisitions, and (v) other statements that are not historical facts. Forward-looking statements involve a number of risks, uncertainties or other factors beyond Nasdaq’s control. These factors include, but are not limited to, Nasdaq’s ability to implement its strategic
initiatives, economic, political and market conditions and fluctuations, government and industry regulation, interest rate risk, U.S. and global competition and other factors detailed in Nasdaq’s filings with the U.S. Securities and Exchange Commission, including its mostrecent Form 10-K and quarterly reports on Form 10-Q, which are available on Nasdaq’s investor relations website at http://ir.nasdaq.com and the SEC’s website at www.sec.gov. Nasdaq undertakes no obligation to publicly update any forward-looking statement, whether
as a result of new information, future events or otherwise.
Website Disclosure
Nasdaq intends to use its website, ir.nasdaq.com, as a means for disclosing material non-public information and for complying with SEC Regulation FD and other disclosure obligations.

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