Intercontinental Exchange Inc

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Intercontinental Exchange provides a high level of transparency around the climate-policy issues it engages on. It identifies multiple specific policies and programs it seeks to shape, including “regional cap and trade programs in the United States & Canada” such as RGGI, WCI, Washington State and Alberta, the “UK ETS,” and state schemes like the California and Washington Cap-and-Invest programs, as well as submissions tied to the Commodity Futures Trading Commission (CFTC) rules on carbon-allowance futures. The company also discloses several concrete mechanisms and named targets for this engagement: it files formal rule and contract amendments with the CFTC “Submission Pursuant to Section 5c(c)(1) of the Act and Regulation 40.2,” collaborates with the U.S. Securities and Exchange Commission on listing requirements for Natural Asset Companies, and “engage[s] with policymakers on the development of these markets,” thereby describing both direct regulatory filings and dialogue with governmental bodies. Finally, ICE is explicit about what it wants from these interactions—“development of regional cap and trade markets in North America,” “support the continuity of emissions trading for businesses in the UK,” establishment of new carbon-allowance futures contracts to “facilitate compliance” with state programs, and the creation of “a new asset class based on ecosystem services,” all of which it states it “Support[s] with no exceptions” and has assessed as aligned with the Paris Agreement. Together, these disclosures demonstrate strong transparency on the policies addressed, the channels used, and the outcomes sought in the company’s climate-related lobbying efforts.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Intercontinental Exchange Inc. provides a general description of its policy engagement framework, noting that “policy engagement activities are led and managed by our legislative and regulatory affairs team which is overseen by our Chief Regulatory Officer, who also serves as President, Sustainable Finance,” and that “our Board of Directors has oversight of the company’s policies related to political and campaign contributions and other political expenditures with explicit authority in the Nominating and Corporate Governance Committee charter.” The company further explains that it “prohibit[s] the use of corporate funds to make contributions to any candidates … or to any political party,” indicating some level of control over political expenditures. However, ICE explicitly states that it has “no public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” and we found no evidence of any dedicated mechanisms—such as criteria for evaluating industry association positions, a climate lobbying review process, or board sign-off procedures—to ensure that either its direct or indirect lobbying activities are aligned with its climate commitments or overall climate strategy.	1