Procedures for Handling Complaints about Accounting Matters
As part of the Global Corporate Compliance & Ethics Program of CME Group Inc. and its
subsidiaries (collectively, the “Company”) and in accordance with the Sarbanes-Oxley Act, theAudit Committee has established the following procedures for: (i) the receipt, retention andtreatment of complaints and concerns received by the Company regarding accounting, internal
accounting controls, auditing matters, financial reporting or disclosure matters or other mattersrelating to actual or alleged violations or potential violations of any law, rule or regulation relating
to securities or to fraud against shareholders (collectively, “Accounting Matters”); and (ii) theconfidential, anonymous submission by Company employees of complaints or concerns
regarding Accounting Matters.
Scope of Matters Covered by Policy
These procedures relate to complaints or concerns with respect to Accounting Matters,including, without limitation, actual or alleged instances of the following:•fraud or deliberate error in the preparation, evaluation, review or audit of any financial
statement of the Company;•fraud or deliberate error in the recording and maintaining of financial records of theCompany;•deficiencies in or noncompliance with the Company’s internal controls over financial
reporting, including attempted or actual circumvention of internal controls, including
matters allegedly relating to the Sarbanes Oxley Act;•misrepresentation or false statements to or by a senior officer or accountant regarding amatter contained in the financial records, financial reports, certification process relating
to the Company’s internal controls over financial reporting or audit reports of theCompany;•mail fraud, wire fraud, bank fraud, securities fraud, violation of any Securities andExchange Commission (“SEC”) rule or regulation or violation of any federal law relating
to fraud against shareholders;•

any reports of in-house attorneys in accordance with the attorney conduct rules of theSEC; or•any deviation from full and fair reporting of the Company’s financial condition.

Submitting Complaints
The Company has established and published on its website, through employee and shareholder
communications and on the Company’s Intranet, OpenExchange, the following avenues forreporting complaints with respect to Accounting Matters on a confidential and anonymous basis,
where permitted by applicable law:•

Via the Internet by visiting www.ethicspoint.com or by clicking on the following QR code:1•

Via telephone by calling the CME Group Compliance & Ethics Helpline:
India: 000.800.100.1703
United Kingdom: 0808.234.1701
United States and Canada: 877.338.4545
Additional numbers for CME Group’s local offices are available onwww.ethicspoint.com and via CME Group’s Intranet, OpenExchange.

•

Via email through directors@cmegroup.comReports may also be submitted by mail to the Managing Director, Chief Enterprise Risk
Management (“ERM”) & Compliance Officer (“Chief ERM and CO”), the General Counsel at
the following address:
CME Group Inc.
20 South Wacker DriveChicago, Illinois 60606
Reports submitted in writing may be marked with a legend such as: “To be opened by theAudit Committee only. Submitted pursuant to the Procedures for Handling Complaints
about Accounting Matters adopted by the Audit Committee.” All such reports will beforwarded unopened to the Chairperson of the Audit Committee.
Complaints and concerns regarding Accounting Matters may be made on an anonymous basis.
The Company also has adopted a Speak Up and Escalation Policy which sets forth theCompany’s expectations for employees and managers to report and escalate compliance andethical concerns to the organization, including Accounting Matters.
Although any person with a complaint or concern regarding a potential Accounting Matter isencouraged to report allegations directly to the Company, these procedures do not require such
person first to report such complaint or concern directly to the Company and in no way limit orprevent such person from reporting such complaint or concern directly to the propergovernmental and regulatory authorities.
Treatment of Complaints
The Audit Committee has designated (1) the Chief Audit Executive and Head of Global
Assurance (“CAE”) and (2) the Chief ERM & CO as authorized representatives to assist theAudit Committee in assessing and dispositioning reported complaints and concerns regarding
potential Accounting Matters.
Recipients within the Company of any such complaints or concerns are required to escalate
them in accordance with the Company’s Speak Up and Escalation Policy or they may
escalate them directly to the CAE or the Chief ERM & CO.
Escalated Accounting Matter. Upon receipt of any allegation relating to a potential
Accounting Matter, the CAE and Chief ERM & CO will promptly determine whether the reported
allegation relates to an Escalated Accounting Matter as described below:(i) the matter involves a member of the Board of Directors or any Senior ManagingDirector;
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(ii) the matter involves or is reasonably likely to involve a sum in excess of $250,000;(iii) the matter has been reported to the SEC, the Public Company Accounting OversightBoard (“PCAOB”) or any other proper governmental or regulatory authority with jurisdiction
applicable to any Accounting Matter;(iv) the matter involves concerns or allegations relating to internal controls, the financial
statements of the Company or the Sarbanes-Oxley Act; or(v) the matter is potentially material or could significantly affect the reputation of theCompany.
If the CAE and Chief ERM & CO determine the matter is an Escalated Accounting Matter, theCAE and Chief ERM & CO will promptly report such allegation to each of the Chairperson of theAudit Committee; the Chairman and Chief Executive Officer; the Chief Financial Officer and theGeneral Counsel, unless any such person is the subject of the allegation. Such allegation willthen be reviewed on a timely basis to determine, based on the nature and extent of theallegations, how and by whom such complaint or concern should be investigated and the extent
to which the full Audit Committee, the Risk Committee or the Nominating and GovernanceCommittee (the Chair or entire Committee) should be involved.
The Audit Committee may enlist employees of the Company and/or outside legal counsel orother advisors as appropriate, to conduct any investigation of a complaint regarding anAccounting Matter.
Non-Escalated Accounting Matters. If the matter is determined to relate to an Accounting
Matter, but not an Escalated Accounting Matter (e.g., an immaterial expense policy violation),then such complaint or concern shall be reported promptly to the Chief Financial Officer andthen handled by the Company in accordance with its established procedures.
Non-Accounting Matter. If the allegation is not an Accounting Matter, then such allegation will
be handled in the same manner as other complaints or concerns are handled by the Companyin accordance with its established procedures.
All Accounting Matters, regardless of whether they are determined to be an Escalated
Accounting Matter, shall be reported by the Chief ERM & CO to the Audit Committee on aquarterly basis.
Retention of Complaints and Concerns
Copies of all complaints, investigative reports, summaries of reports and other documents
relating to Accounting Matters will be retained by representatives of the Global Corporate
Compliance & Ethics Team in accordance with the Company’s established guidelines forinvestigation processes and procedures and the Company’s Records and Information
Management Policy.
Confidentiality
The Company will maintain confidentiality regarding discussion, inquiries and the identities ofperson(s) reporting complaints or otherwise potentially involved to the extent possible,
consistent with the need to carry out an appropriate and adequate evaluation or investigation of
the matters described in a complaint or concern during any review or investigation; and further,
all reasonable attempts will be made to protect the anonymity of person(s) reporting complaints
or concerns on an anonymous basis and of witnesses who request to have identities remain
anonymous; in each case, except in connection with legal or other governmental proceedings or
as required by law.

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Non-Retaliation Policy
It is the Company’s policy not to discharge, demote, suspend, threaten, harass or in any mannerdiscriminate or retaliate against any employee in the terms and conditions of employment based
upon any lawful actions of such employee with respect to the reporting of complaints madebased on reasonable belief that misconduct may be occurring regarding Accounting Matters orotherwise.
The Committee will not tolerate retaliation against any person who reports potential issues tothe Committee based on a reasonable belief that misconduct may be occurring.
Adopted: September 4, 2003; last revised December 5, 2023

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