IntercontinentalExchange 

March 1, 2010 © 2000-2010 IntercontinentalExchange, Inc Page 1 of 52 

ANNEX H – PARTICIPANT CODE OF CONDUCT 

PREAMBLE

This Code of Ethics and Sound Trading Practices (Code) defines and reaffirms the values, principles and 

internal controls that Participant must follow in conducting its business activities on the Exchange. The 

Code is intended to complement the internal principles and practices of Participant and to guide 

Participant as it posts bids, offers, and requests for quotation, executes Transactions, confirms Trades, 

and uses Other Services on the Exchange. Compliance with the Code allows Participant to assure ICE, 

legislators, regulators, the public and other market participants that its business activities on the 

Exchange are, and will continue to be, conducted with integrity. In addition, Participant gives assurance 

that unlawful and unethical trading practices are not tolerated, that public disclosures of trading 

information are accurate, and that it will abide by these ethical standards and maintain sound trading

practices. 

Participant acknowledges that violations of this Code can incur penalties including, but not limited to, 

temporary or permanent loss of access to the Exchange. 

I. ETHICAL STANDARDS

A. Core Value: Integrity

Conducting trading activities with integrity is the essence of ethical conduct. Integrity 

means conducting these activities in an honorable and principled manner consistent with 

the ethical standards and sound trading practices set forth herein. 

B. Ethical Standards

On the Exchange, Participant will: 

1. Conduct its business in accordance with all applicable laws, regulations, tariffs 

and rules, and in good faith, and with a commitment to honest dealing. 

2. Not engage in fraudulent behavior. 

3. Honor the terms and conditions of this Participant Agreement. 

4. Engage only in Transactions with legitimate business purposes, such as 

managing business risk or that otherwise have economic substance. In no event 

will Participant engage in any Transactions intended to boost revenues or 

volumes artificially, or intended to manipulate market prices. 

5. Not collude with other market participants to affect the price or supply of any 

commodity, allocate territories, customers or products, or otherwise unlawfully 

restrain competition. 

6. Adopt, adhere to, and enforce risk management and other policies and structures 

that are designed to ensure that trading activities are conducted in accordance 

with this Code. 
IntercontinentalExchange 

March 1, 2010 © 2000-2010 IntercontinentalExchange, Inc Page 2 of 52 

II. SOUND TRADING PRACTICES

A. Core Value: Adherence to Sound Trading Practices and Principles 

Commodity markets reflect the constantly changing dynamics of supply and demand. 

Efficient business operations in such an environment demand practices that can manage 

risk and discover market prices. Such practices must be consistent with the guiding 

Ethical Standards of this Code. 

B. Sound Trading Practices Standards 

Participant will act in accordance with these standards of sound trading practices with 

regard to its Exchange activity: 

1. No “wash” trades. Participant will not arrange and execute simultaneous 

offsetting buy and sell trades, i.e. with the same counterparty and price, 

commodity, location and quantity terms, with an intent to artificially affect 

reported revenues, trading volumes, or prices. 

2. No misrepresentative trading. No trading will be conducted for the purpose of 

misrepresenting the financial condition of the organization. 

III. INFORMATION DISCLOSURE AND DOCUMENTATION

A. Core Value: Candid and Complete Disclosure 

Markets depend on trust in the accuracy of market information provided by Participant 

and in the transparency of market behavior of all market participants. 

B. Information Disclosure and Documentation Standards 

With regard to its Exchange activity, Participant will: 

1. Provide Transaction information to regulators in compliance with all applicable 

rules and requirements and continue to cooperate with regulators as reasonably 

necessary to assist in their understanding of the markets. 

2. Ensure that any information disclosed to ICE is accurate and consistent. 

3. Maintain and adhere to internal procedures designed to ensure that all 

Transactions are properly documented in a timely fashion and that no 

Transactions or Trades are concealed or misrepresented when providing market 

information to ICE or any of its affiliates. 

4. Promptly notify ICE of any material change (to a Transaction executed on the 

Exchange) mutually agreed to by Participant and counterparty after execution, 

but prior to confirmation, including, but not limited to changes in price, quantity, 

grade, delivery location, reference index, delivery or settlement timeframes, or 

payment terms. 
IntercontinentalExchange 

March 1, 2010 © 2000-2010 IntercontinentalExchange, Inc Page 3 of 52 

5. Promptly notify ICE of any Transaction cancellation or reversing trade with the 

same counterparty for the explicit purpose of effecting cancellation (an equal, but 

opposite offsetting trade), mutually agreed to by Participant and counterparty of a 

Transaction executed or Trade confirmed on the Exchange. 

6. Maintain documentation on all Transactions for an appropriate period of time as 

required under applicable laws and regulations. 

IV. COMPLIANCE

A. Core Value: Comprehensive Corporate Compliance 

Each Participant will have a compliance program commensurate with the size and scope 

of its trading activities on the Exchange and designed to ensure appropriate, timely and 

ongoing review of trading practices and compliance with this Code. 

B. Compliance Standards

Participant will: 

1. Provide for proper training of personnel on the provisions of this Code. 

2. Maintain internal policies and procedures to promote compliance with this Code. 

3. Promptly disclose to ICE the details of any violations of this Code involving 

Participant’s activities on the Exchange or provision of market information to ICE 

or any of its affiliates. 

4. Provide an environment that encourages employees within the trading 

organization to engage in safe and confidential discussions and to disclose to 

senior management any trading practices that might violate this Code. 

5. Establish clear lines of accountability for the company’ s trading practices, 

including provisions relating to the responsibilities of corporate officers, with 

appropriate oversight by the Board of Directors or other senior corporate 

management committee.