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FY2023 Annual Report · Nasdaq
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

_______________________________

FORM 10-K 

☒

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2023

OR

☐

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period  from ________ to ________

Commission file number: 001-38855

___________________________________
Nasdaq, Inc.
(Exact name of registrant as specified in its charter)

Delaware
(State or Other Jurisdiction of Incorporation or Organization)

52-1165937
(I.R.S. Employer Identification No.)

151 W. 42nd Street,

New York,

New York

(Address of Principal Executive Offices)

10036

(Zip Code)

Registrant’s telephone number, including area code: +1 212 401 8700

Securities registered pursuant to Section 12(b) of the Act:

Title of each class

Common Stock, $0.01 par value per share
4.500% Senior Notes due 2032
0.900% Senior Notes due 2033
0.875% Senior Notes due 2030
1.75% Senior Notes due 2029

Trading Symbol(s)

Name of each exchange on which registered

NDAQ
NDAQ32
NDAQ33
NDAQ30
NDAQ29

The Nasdaq Stock Market
The Nasdaq Stock Market
The Nasdaq Stock Market
The Nasdaq Stock Market
The Nasdaq Stock Market

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes ☒ No ☐
Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Exchange Act. Yes ☐ No ☒

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for

such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.    Yes  ☒    No  ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this

chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).    Yes  ☒    No  ☐
    Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of
“large accelerated filer,” “accelerated filer,” “smaller reporting company” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer
Non-accelerated filer
Emerging growth company

☒
☐
☐

Accelerated filer
Smaller reporting company

☐
☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting

standards provided pursuant to Section 13(a) of the Exchange Act. ☐

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under

Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report. ☒

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to

previously issued financial statements. ☐

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s executive

officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).    Yes  ☐    No   ☒ 
As of June 30, 2023, the aggregate market value of the registrant’s common stock held by non-affiliates of the registrant was approximately $17.0 billion (this amount represents approximately

340.1 million shares of Nasdaq, Inc.’s common stock based on the last reported sales price of $49.85 of the common stock on The Nasdaq Stock Market on such date).

Indicate the number of shares outstanding of each of the issuer’s classes of common stock, as of the latest practicable date.

Class
Common Stock, $0.01 par value per share

Outstanding at February 13, 2024

575,206,570  shares

Documents Incorporated by Reference: Certain portions of the Definitive Proxy Statement for the 2024 Annual Meeting of Shareholders are incorporated by reference into Part III of this Form 10-K.

 
Part I.

Item 1. Business

Item 1A. Risk Factors

Item 1B. Unresolved Staff Comments

Item 1C. Cybersecurity

Item 2. Properties

Item 3. Legal Proceedings

Item 4. Mine Safety Disclosures

Part II.

Item 5.

Market for Registrant’s Common Equity, Related Stockholder
Matters and Issuer Purchases of Equity Securities

Item 6.

[Reserved]

Item 7.

Management’s Discussion and Analysis of Financial
Condition and Results of Operations

Item 7A. Quantitative and Qualitative Disclosures About Market Risk

Item 8. Financial Statements and Supplementary Data

Item 9.

Changes in and Disagreements with Accountants on
Accounting and Financial Disclosure

Item 9A. Controls and Procedures

Item 9B. Other Information

Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections

Item 9C.

Part III.

Item 10. Directors, Executive Officers and Corporate Governance

Item 11. Executive Compensation

Item 12.

Security Ownership of Certain Beneficial Owners and
Management and Related Stockholder Matters

Item 13.

Certain Relationships and Related Transactions, and Director
Independence

Item 14. Principal Accountant Fees and Services

Part IV.

Item 15. Exhibits and Financial Statement Schedules

Item 16. Form 10-K Summary

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i

 
 
 
About this Form 10-K

Throughout this Form 10-K, unless otherwise specified:

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

“Nasdaq,” “we,” “us” and “our” refer to Nasdaq, Inc.

“Nasdaq Baltic” refers to collectively, Nasdaq Tallinn AS, Nasdaq Riga,
AS, and AB Nasdaq Vilnius.

“Nasdaq BX” refers to the cash equity exchange operated by Nasdaq BX,
Inc.

“Nasdaq BX Options” refers to the options exchange operated by Nasdaq
BX, Inc.

“Nasdaq Clearing” refers to the clearing operations conducted by Nasdaq
Clearing AB.

“Nasdaq  CXC”  and  “Nasdaq  CX2”  refer  to  the  Canadian  cash  equity
trading books operated by Nasdaq CXC Limited.

“Nasdaq  First  North”  refers  to  our  alternative  marketplaces  for  smaller
companies and growth companies in the Nordic and Baltic regions.

“Nasdaq  GEMX”  refers  to  the  options  exchange  operated  by  Nasdaq
GEMX, LLC.

“Nasdaq  ISE”  refers  to  the  options  exchange  operated  by  Nasdaq  ISE,
LLC. 

“Nasdaq MRX” refers to the options exchange operated by Nasdaq MRX,
LLC. 

“Nasdaq  Nordic”  refers  to  collectively,  Nasdaq  Clearing  AB,  Nasdaq
Stockholm  AB,  Nasdaq  Copenhagen  A/S,  Nasdaq  Helsinki  Ltd,  and
Nasdaq Iceland hf.

“Nasdaq  PHLX”  refers  to  the  options  exchange  operated  by  Nasdaq
PHLX LLC.

“Nasdaq  PSX”  refers  to  the  cash  equity  exchange  operated  by  Nasdaq
PHLX LLC.

“The Nasdaq Options Market” refers to the options exchange operated by
The Nasdaq Stock Market LLC.

“The Nasdaq Stock Market” refers to the cash equity exchange and listing
venue operated by The Nasdaq Stock Market LLC.

Nasdaq  also  provides  as  a  tool  for  the  reader  the  following  list  of
abbreviations  and  acronyms  that  are  used  throughout  this  Annual  Report  on
Form 10-K.

2022  Revolving  Credit  Facility:  $1.25  billion  senior  unsecured  revolving
credit facility, which matures on December 16, 2027, which has replaced the
$1.25 billion credit facility issued in 2020

2025  Notes:  $500  million  aggregate  principal  amount  of  5.650%  senior

unsecured notes due June 28, 2025

2029  Notes:  €600  million  aggregate  principal  amount  of  1.75%  senior

unsecured notes due March 28, 2029

2030  Notes:  €600  million  aggregate  principal  amount  of  0.875%  senior

unsecured notes due February 13, 2030

2031  Notes:  $650  million  aggregate  principal  amount  of  1.650%  senior

unsecured notes due January 15, 2031

2032  Notes:  €750  million  aggregate  principal  amount  of  4.500%  senior

unsecured notes due February 15, 2032

2033  Notes:  €615  million  aggregate  principal  amount  of  0.900%  senior

unsecured notes due July 30, 2033

2034  Notes:  $1.25  billion  aggregate  principal  amount  of  5.550%  senior

unsecured notes due February 15, 2034

2040  Notes:  $650  million  aggregate  principal  amount  of  2.500%  senior

unsecured notes due December 21, 2040

2050  Notes:  $500  million  aggregate  principal  amount  of  3.25%  senior

unsecured notes due April 28, 2050

2052  Notes:  $550  million  aggregate  principal  amount  of  3.950%  senior

unsecured notes due March 7, 2052

2053  Notes:  $750  million  aggregate  principal  amount  of  5.950%  senior

unsecured notes due August 15, 2053

2063  Notes:  $750  million  aggregate  principal  amount  of  6.100%  senior

unsecured notes due June 28, 2063

AML: Anti-money Laundering

ARR: Annualized Recurring Revenue

ASC: Accounting Standards Codification

ASU: Accounting Standards Update

ASR: Accelerated Share Repurchase

ATS: Alternative Trading System

AUM: Assets Under Management

AWS: Amazon Web Services

CAT:  A  market-wide  consolidated  audit  trail  established  under  an  SEC

approved plan by Nasdaq and other exchanges

CCP: Central Counterparty

CFTC: U.S. Commodity Futures Trading Commission

EBITDA: Earnings before interest, taxes, depreciation and amortization

EMIR: European Market Infrastructure Regulation

2026  Notes:  $500  million  aggregate  principal  amount  of  3.85%  senior

Equity Plan: Nasdaq Equity Incentive Plan

unsecured notes due June 30, 2026

2028  Notes:  $1  billion  aggregate  principal  amount  of  5.350%  senior

unsecured notes due June 28, 2028

ESG: Environmental, Social and Governance

ESPP: Nasdaq Employee Stock Purchase Plan

ETF: Exchange Traded Fund

ETP: Exchange Traded Product

ii

Exchange Act: Securities Exchange Act of 1934, as amended

FASB: Financial Accounting Standards Board

FICC: Fixed Income and Commodities Trading and Clearing

FINRA: Financial Industry Regulatory

GICS: Global Industry Classification Standard

IPO: Initial Public Offering

MiFID II: Update to the Markets in Financial Instruments Directive

MiFIR: Markets in Financial Instruments Regulation

NPM: The NASDAQ Private Market, LLC

NSCC: National Securities Clearing Corporation

OCC: The Options Clearing Corporation

OTC: Over-the-Counter

Proxy  Statement:  Nasdaq’s  Definitive  Proxy  Statement  for  the  2024  Annual

Meeting of Shareholders

PSU: Performance Share Unit

Regulation NMS: Regulation National Market System

Regulation SCI: Regulation Systems Compliance and Integrity

This  Annual  Report  on  Form  10-K  includes  market  share  and  industry  data
that  we  obtained  from  industry  publications  and  surveys,  reports  of
governmental  agencies  and  internal  company  surveys.  Industry  publications
and  surveys  generally  state  that  the  information  they  contain  has  been
obtained from sources believed to be reliable, but we cannot assure you that
this information is accurate or complete. We have not independently verified
any  of  the  data  from  third-party  sources  nor  have  we  ascertained  the
underlying  economic  assumptions  relied  upon  therein.  Statements  as  to  our
market  position  are  based  on  the  most  currently  available  market  data.  For
market  comparison  purposes,  The  Nasdaq  Stock  Market  data  in  this  Annual
Report on Form 10-K for IPOs and new listings of equity securities (including
issuers that switched from other listings venues, closed-end funds and ETPs)
is  based  on  data  generated  internally  by  us;  therefore,  the  data  may  not  be
comparable to other publicly-available IPO data. Data in this Annual Report
on  Form  10-K  for  IPOs  and  new  listings  of  equity  securities  on  the  Nasdaq
Nordic and Nasdaq Baltic exchanges and Nasdaq First North also is based on
data generated internally by us. IPOs and new listings data is presented as of
period end. While we are not aware of any misstatements regarding industry
data  presented  herein,  our  estimates  involve  risks  and  uncertainties  and  are
subject  to  change  based  on  various  factors,  including  those  discussed  in  the
“Item 1A. Risk Factors” section in this Annual Report on Form 10-K. 

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.

SaaS: Software as a Service

SEC: U.S. Securities and Exchange Commission

SERP: Supplemental Executive Retirement Plan

SFSA: Swedish Financial Supervisory Authority

SOFR: Secured Overnight Financing Rate

S&P: Standard & Poor’s

S&P 500: S&P 500 Stock Index

SPAC: Special Purpose Acquisition Company

SRO: Self-regulatory Organization

SSMA: Swedish Securities Markets Act 2007:528

TSR: Total Shareholder Return

U.S. GAAP: U.S. Generally Accepted Accounting Principles

U.S. Tape plans: U.S. cash equity and U.S. options industry data

UTP: Unlisted Trading Privileges

UTP  Plan:  Joint  SRO  Plan  Governing  the  Collection,  Consolidation,  and
Dissemination of Quotation and Transaction Information for Nasdaq-Listed
Securities Traded on Exchanges on a UTP Basis

NASDAQ, the NASDAQ logos, and other brand, service or product names or
marks referred to in this report are trademarks or service marks, registered or
otherwise, of Nasdaq, Inc. and/or its subsidiaries. FINRA and Trade Reporting
Facility are registered trademarks of FINRA.

iii

• economic,  political  and  market  conditions  and  fluctuations,  including
inflation,  interest  rate  and  foreign  currency  risk  inherent  in  U.S.  and
international operations, and geopolitical instability;

• the  performance  and  reliability  of  our  technology  and  technology  of  third

parties on which we rely;

• any significant systems failures or errors in our operational processes;

• our ability to continue to generate cash and manage our indebtedness; and

• adverse changes that may occur in the litigation or regulatory areas, or in
increased  regulatory  oversight

the  securities  markets  generally,  or 
domestically or internationally.

Most  of  these  factors  are  difficult  to  predict  accurately  and  are  generally
beyond our control. You should consider the uncertainty and any risk related
to forward-looking statements that we make. These risk factors are discussed
under the caption "Item 1A. Risk Factors" in this Annual Report on Form 10-
K.  You  are  cautioned  not  to  place  undue  reliance  on  these  forward-looking
statements, which speak only as of the date of this Annual Report on Form 10-
K.  You  should  carefully  read  this  entire  Annual  Report  on  Form  10-K,
including  “Item  7.  Management’s  Discussion  and  Analysis  of  Financial
Condition  and  Results  of  Operations”  and  the  consolidated  financial
statements and the related notes. Except as required by the federal securities
laws,  we  undertake  no  obligation  to  update  any  forward-looking  statement,
release publicly any revisions to any forward-looking statements or report the
occurrence  of  unanticipated  events.  For  any  forward-looking  statements
contained  in  any  document,  we  claim  the  protection  of  the  safe  harbor  for
forward-looking  statements  contained  in  the  Private  Securities  Litigation
Reform Act of 1995.

Forward-Looking Statements

The  SEC  encourages  companies  to  disclose  forward-looking  information  so
that  investors  can  better  understand  a  company’s  future  prospects  and  make
informed  investment  decisions.  This  Annual  Report  on  Form  10-K  contains
these  types  of  statements.  Words  such  as  “may,”  “will,”  “could,”  “should,”
“anticipates,”  “envisions,”  “estimates,”  “expects,”  “projects,”  “intends,”
“plans,”  “believes”  and  words  or  terms  of  similar  substance  used  in
connection  with  any  discussion  of  future  expectations  as  to  industry  and
regulatory  developments  or  business 
future
operating results or financial performance, and other future developments are
intended to identify forward-looking statements. These include, among others,
statements relating to:

initiatives  and  strategies, 

• our strategic direction, including changes to our corporate structure;

• the  integration  of  acquired  businesses,  including  accounting  decisions

relating thereto;

• the  scope,  nature  or  impact  of  acquisitions,  divestitures,  investments,  joint

ventures or other transactional activities;

• the  effective  dates  for,  and  expected  benefits  of,  ongoing  initiatives,
transactional  activities  and  other  strategic,  restructuring,

including 
technology, ESG, de-leveraging and capital return initiatives;

• our products and services;

• the impact of pricing changes;

• tax matters;

• the cost and availability of liquidity and capital; and

• any  litigation,  or  any  regulatory  or  government  investigation  or  action,  to
which  we  are  or  could  become  a  party  or  which  may  affect  us  and  any
potential settlements of litigation, regulatory or governmental investigations
or actions, including with respect to our CFTC investigation.

Forward-looking  statements  involve  risks  and  uncertainties.  Factors  that
could cause actual results to differ materially from those contemplated by the
forward-looking statements include, among others, the following:
• our operating results may be lower than expected;
• our  ability  to  successfully  integrate  acquired  businesses  or  divest  sold
businesses  or  assets,  including  the  fact  that  any  integration  or  transition
may be more difficult, time consuming or costly than expected, and we may
be  unable  to  realize  synergies  from  business  combinations,  acquisitions,
divestitures or other transactional activities;

• loss  of  significant  trading  and  clearing  volumes  or  values,  fees,  market

share, listed companies, market data customers or other customers;

• our ability to develop and grow our non-trading businesses;
• our  ability  to  keep  up  with  rapid  technological  advances,  including  our
ability  to  effectively  manage  the  development  and  use  of  artificial
intelligence  in  certain  of  our  products  and  offerings,  and  adequately
address cybersecurity risks;

iv

PART I

Item 1. Business

Overview

Nasdaq is a global technology company serving corporate clients, investment
managers,  banks,  brokers,  and  exchange  operators  as  they  navigate  and
interact with the global capital markets and the broader financial system. We
liquidity,
aspire 
transparency,  and  integrity  of  the  global  economy.  Our  diverse  offering  of
data,  analytics,  software,  exchange  capabilities,  and  client-centric  services
enables clients to optimize and execute their business vision with confidence.

to  deliver  world-leading  platforms 

improve 

that 

the 

We manage, operate and provide our products and services in three business
segments:  Capital  Access  Platforms,  Financial  Technology  and  Market
Services.

History

Nasdaq  was  founded  in  1971  as  a  wholly-owned  subsidiary  of  FINRA.
Beginning in 2000, FINRA restructured and broadened ownership in Nasdaq
by selling shares to FINRA members, investment companies and issuers listed
on  The  Nasdaq  Stock  Market.  In  connection  with  this  restructuring,  FINRA
fully divested its ownership of Nasdaq in 2006, and The Nasdaq Stock Market
became an independent registered national securities exchange in 2007.

In February 2008, Nasdaq and OMX AB combined their businesses, and we
changed  our  corporate  name  to  The  NASDAQ  OMX  Group,  Inc.  This
transformational combination resulted in the expansion of our business from a
U.S.-based  exchange  operator  to  a  global  exchange  company  offering
technology that powers our own exchanges and markets as well as many other
marketplaces  around  the  world.  We  operated  as  the  NASDAQ  OMX  Group
until we rebranded our business as Nasdaq, Inc. in 2015.

In November 2023, Nasdaq completed its acquisition of Adenza. Through its
two solutions, AxiomSL and Calypso, Adenza is a provider of mission-critical
risk  management,  regulatory  reporting,  and  capital  markets  software  to  the
financial services industry. The acquisition enhances our technology solutions
and further expands Nasdaq’s complementary offerings across mission-critical
capital markets infrastructure and compliance.

Growth Strategy

To enable success in the evolving global financial system, we have established
our  purpose,  vision,  and  value  proposition  together  with  a  focused  growth
strategy:

Our Purpose: We advance economic progress for all.

Our Vision: We will be the trusted fabric of the world’s financial system.

Our Value Proposition: We deliver world-leading platforms that improve the
liquidity, transparency and integrity of the global economy.

1

Our  Strategy:  In  2017,  we  set  a  new  strategic  direction  focused  on
maximizing  the  resources,  people  and  capital  allocated  to  our  largest  growth
opportunities.  These  opportunities,  which  include  anti-financial  crime  and
compliance  solutions,  marketplace  technology,  workflow  for  investment
managers and asset owners as well as insight solutions, constituted large and
growing opportunities where we felt our strengths in technology, proprietary
data,  analytics  and  capital  markets  expertise,  combined  with  our  expansive
client network, positioned us to meet our clients’ evolving needs.

Following the completion of the Adenza acquisition, including its two flagship
solutions,  AxiomSL  and  Calypso,  we  further  aligned  our  business  more
closely with the foundational shifts that are driving the evolution of the global
financial system. The divisional structure is as follows:

By  aligning  our  business  segments  against  these  secular  trends,  we  aim  to
deliver  more  for  our  clients  and  increase  growth  across  our  key  pillars  of
liquidity, transparency and integrity:

• Liquidity: Within our Financial Technology and Market Services segments,
we continue to modernize markets by utilizing technology to maximize the
liquidity  of  the  global  economy.  New  technologies,  including  cloud,
blockchain,  machine  learning  and  artificial  intelligence,  present  significant
opportunities to further enhance market resiliency and scalability and make
markets  even  more  accessible.  We  believe  that  these  technologies  will
enable more opportunities for market participants and new asset classes to
be integrated across markets globally. The Financial Technology and Market
Services segments together offer complementary capabilities to capture the
potential  these  technologies  can  unlock  in  our  industry.  By  utilizing  our
Market Services segment’s position at the center of markets, we believe that
our  Financial  Technology  segment  will  be  at  the  forefront  of  the  financial
system’s  evolution  and  will  play  a  critical  role  in  advancing  the
modernization of markets across geographies and asset classes.

• Transparency: Our Capital Access Platforms segment is uniquely placed to
help  clients  navigate  the  increasing  complexity  of  the  evolving  financial
system through access to capital and transparency which enables economic
growth.  With  approximately  10,000  corporate  clients  and  5,000  clients
across the investment management ecosystem, Nasdaq is a trusted partner to
aid  the  corporate  and  investment  communities  in  making  more  informed
decisions.  Leveraging  the  insights  and  capabilities  across  our  listings,
advisory,  data,  index,  and  analytics  teams,  we  believe  that  Capital  Access
investor  and  corporate
Platforms  serves  as  a  bridge  between 
communities,  focused  on  enhancing  the  client  experience  by  providing
efficient  routes  to  capital,  delivering  more  holistic,  actionable  insights  and
intelligence,  modernizing  workflows,  and  navigating  the  climate  and  ESG
landscape.

the 

• Integrity:  Financial  Crime  Management  Technology  and  Regulatory
Technology  include  Nasdaq’s  fraud  detection,  anti-money  laundering,
surveillance  and  risk  data  management  and  regulatory  reporting  solutions
businesses.  These  businesses  remain  focused  on  capturing  the  growth
associated  with  protecting  the  integrity  of  the  financial  system  by  fighting
financial  crime  and  helping  our  clients  with  their  most  significant
compliance  challenges.  These  businesses  will  continue  delivering  world-
class  solutions,  leveraging  the  power  of  the  cloud  and  machine  learning
across asset classes, to the full spectrum of banks and brokers, including the
emerging  ecosystem  of  financial  technology,  or  FinTech,  companies  and
digital banks.

Products and Services

Capital Access Platforms

Our  Capital  Access  Platforms  segment  delivers  liquidity,  transparency  and
integrity  to  the  corporate  issuer  and  investment  community  by  empowering
our  clients  to  effectively  navigate  the  capital  markets,  achieve  their
sustainability  goals,  and  drive  governance  excellence.  We  offer  a  suite  of
products to assist companies in managing corporate governance standards.

Our  Capital  Access  Platforms  segment  includes  Data  &  Listing  Services,
Index and Workflow & Insights.

Data & Listing Services

Our  North  American  and  European  data  products  enhance  transparency  of
market  activity  within  our  exchanges  and  provide  critical  information  to
professional  and  non-professional  investors  globally.  Our  Data  business
distributes  historical  and  real-time  market  data  to  sell-side  customers,  the
institutional  investing  community,  retail  online  brokers,  proprietary  trading
firms, and other venues, as well as internet portals and data distributors.

We collect, process, and create information and earn revenues as a distributor
of our own, as well as select third-party, content. We provide varying levels of
quote and trade information to market participants and to data distributors who
in  turn  provide  subscriptions  for  this  information.  Our  systems  enable
distributors  to  gain  access  to  our  market  depth,  fund  valuation,  order
imbalances, market sentiment and other analytical data.

We distribute this proprietary market information to both market participants
and  non-participants  through  a  number  of  proprietary  products,  including
Nasdaq  TotalView,  our  flagship  market  depth  quote  product.  We  offer
TotalView  products  for  The  Nasdaq  Stock  Market  and  our  Nasdaq  BX,
Nasdaq  PSX  and  Nordic  markets.  We  also  offer  Nordic  Equity  TotalView,
Nordic Derivatives TotalView and Nordic Fixed Income TotalView for Nordic
markets.

We  operate  several  other  proprietary  services  and  data  products  to  provide
market  information,  including  Nasdaq  Basic,  a  low  cost  alternative  to  the
industry Level 1 feed and Nasdaq Canada Basic, a low cost alternative to other
high  priced  data  feeds.  We  also  provide  various  other  data,  including  data
relating  to  our  U.S.  equities  and  options  exchanges  and  Nordic  equities,
derivatives, fixed income and futures.

Additionally, our Nasdaq Cloud Data Service provides a flexible and efficient
method  of  delivery  for  real-time  exchange  data  and  other  financial
information.  Data 
through  a  suite  of  application
programming  interfaces,  or  APIs,  allowing  for  the  integration  of  data  from
disparate  sources  and  a  reduction  in  time  to  market  for  customer-designed
applications.  These  APIs  are  highly  scalable  and  can  support  the  delivery  of
real-time exchange data.

is  made  available 

We operate a variety of listing platforms around the world to provide multiple
global capital raising solutions for public companies. Companies listed on our
markets  represent  a  diverse  array  of  industries  including,  among  others,
healthcare,  consumer  products,  telecommunication  services,  information
technology, financial services, industrials and energy. Our main listing markets
are  The  Nasdaq  Stock  Market  and  the  Nasdaq  Nordic  and  Nasdaq  Baltic
exchanges.

Companies seeking to list securities on The Nasdaq Stock Market may do so
on  one  of  the  three  market  tiers:  The  Nasdaq  Global  Select  Market,  The
Nasdaq Global Market, or The Nasdaq Capital Market. To qualify, companies
must  meet  minimum  listing  requirements,  including  specified  financial  and
corporate governance criteria. Once listed, companies must maintain rigorous
listing and corporate governance standards.

2

As of December 31, 2023, a total of 5,262 companies listed securities on our
U.S., Nasdaq Nordic, Nasdaq Baltic and Nasdaq First North exchanges. As of
December  31,  2023,  a  total  of  4,044  companies  listed  securities  on  The
Nasdaq  Stock  Market,  with  1,443  listings  on  The  Nasdaq  Global  Select
Market,  1,269  on  The  Nasdaq  Global  Market  and  1,332  on  The  Nasdaq
Capital Market.

We seek new listings from companies conducting IPOs, including SPACs, and
direct  listings  as  well  as  companies  looking  to  switch  from  alternative
exchanges. The 2023 new listings were comprised of the following:

listed  on  The  Nasdaq  Stock  Market.  More  than  100  ETPs  worldwide  track
indices in the NDX ecosystem, and had nearly $360 billion in assets tracking
the index as of December 31, 2023.

We provide index data products based on Nasdaq indices. Index data products
include our Global Index Data Service, which delivers real-time index values
throughout  the  trading  day,  and  Global  Index  Watch/Global  Index  File
Delivery  Service,  which  delivers  daily  and  historical  weightings  and
components  data,  corporate  actions  and  a  breadth  of  additional  data  for  the
indices that we operate.

Operating company IPOs

SPAC IPOs
Switches from the New York Stock Exchange LLC, or NYSE,
and the NYSE American LLC, or NYSE American
Upgrades from OTC
ETPs and Other Listings

Total

The Nasdaq Stock Market IPO win rates:

2023 total
Operating companies

103

27

18
18
164

330

82 %
81 %

During 2023, we had 18 new listings resulting from companies switching their
listings  from  NYSE  or  NYSE  American  to  join  The  Nasdaq  Stock  Market.
Together with companies that transferred additional securities to The Nasdaq
Stock  Market  during  2023,  an  aggregate  of  $377  billion  in  global  equity
market capitalization switched to The Nasdaq Stock Market.

We  also  offer  listings  on  the  exchanges  that  comprise  Nasdaq  Nordic  and
Nasdaq Baltic. For smaller companies and growth companies, we offer access
to  the  financial  markets  through  the  Nasdaq  First  North  alternative
marketplaces.  As  of  December  31,  2023,  a  total  of  1,218  companies  listed
securities on our Nordic and Baltic exchanges.

Our  European  listing  customers  include  companies,  funds  and  governments.
Customers  issue  securities  in  the  form  of  cash  equities,  depository  receipts,
warrants,  ETPs,  convertibles,  rights,  options,  bonds  or  fixed-income  related
products. In 2023, a total of 23 new companies listed on our Nordic and Baltic
exchanges.

Index

Our  Index  business  develops  and  licenses  Nasdaq-branded  indices  and
financial  products.  License  fees  for  our  trademark  licenses  vary  by  product
based on a percentage of underlying assets, dollar value of a product issuance,
number  of  products  or  number  of  contracts  traded.  We  also  license  cash-
settled options, futures and options on futures on our indices.

As  of  December  31,  2023,  388  ETPs  listed  on  27  exchanges  in  over  20
countries tracked a Nasdaq index and accounted for $473 billion in AUM. Our
flagship  index,  the  Nasdaq-100  Index,  or  NDX,  includes  the  top  100  non-
financial companies

3

Workflow & Insights

Workflow & Insights includes our analytics and corporate solutions products.

Our  analytics  products  provide  asset  managers,  investment  consultants  and
institutional asset owners with information and analytics to make data-driven
investment  decisions,  deploy  their  resources  more  productively,  and  provide
liquidity  solutions  for  private  funds.  Through  our  eVestment  and  Solovis
solutions,  we  provide  a  suite  of  cloud-based  solutions  that  help  institutional
investors  and  consultants  conduct  pre-investment  due  diligence,  and  monitor
their  portfolios  post-investment.  The  eVestment  platform  also  enables  asset
managers  to  efficiently  distribute  information  about  their  firms  and  funds  to
asset owners and consultants worldwide.

Through the Solovis platform, endowments, foundations, pensions and family
offices  transform  how  they  collect  and  aggregate  investment  data,  analyze
portfolio  performance,  model  and  predict  future  outcomes,  and  share
meaningful  portfolio  insights  with  key  stakeholders.  The  Nasdaq  Fund
Network  and  Nasdaq  Data  Link  are  additional  platforms  in  our  suite  of
investment data analytics offerings and data management tools. Nasdaq Fund
Network gathers and distributes daily net asset values from over 44,000 funds
and  other  investment  vehicles  across  North  America.  We  have  extended
Nasdaq  Fund  Network  to  support  the  distribution  of  collective  investment
trusts,  hedge  funds,  managed  accounts,  separate  accounts,  529  educational
saving plans and demand deposit accounts. Nasdaq Data Link strengthens our
position as a leading source for financial, economic, and alternative datasets.
For investment management firms, investment banks and other investors, the
platform  powers  data-driven  decision-making  for  users  across  the  globe  via
universal APIs, and provides for efficient data discovery and delivery.

Corporate  solutions  serves  both  public  and  private  companies  and
organizations 
through  our  Investor  Relations  Intelligence,  Governance
Solutions  and  ESG  Solutions  products.  Our  public  company  clients  can  be
companies  listed  on  our  exchanges  or  other  U.S.  and  global  exchanges.  Our
private company clients include a diverse group of organizations ranging from
family-owned companies, government organizations, law firms, privately held
entities,  and  various  non-profit  organizations  to  hospitals  and  healthcare
systems. We help organizations enhance their

ability  to  understand  and  expand  their  global  shareholder  base,  improve
corporate governance, and navigate the evolving ESG landscape through our
suite  of  advanced  technology,  analytics,  and  consulting  services.  We  also
advise clients on a range of governance and sustainability-related issues.

Our Investor Relations Intelligence offerings include a global team of expert
consultants  that  deliver  advisory  services  including  Equity  Surveillance  &
Shareholder Analysis, Investor Engagement and Perception Studies, as well as
an  industry-leading  platform,  Nasdaq  IR  Insight®,  to  investor  relations
professionals  and  executive  teams.  These  solutions  allow  investor  relations
officers  and  executives  to  better  manage  their  investor  relations  programs,
understand  their  investor  base,  target  new  investors,  manage  meetings  and
consume  key  data  such  as  investor  profiles,  equity  research,  consensus
estimates and news.

Through our Governance Solutions products, we provide a global technology
offering and consulting services that streamline the meeting process for board
of  directors  and  executive  leadership  teams  and  enable  them  to  accelerate
decision  making  and  strengthen  governance.  Our  solutions  help  protect
sensitive  data  and  facilitate  productive  collaboration,  which  enables  board
members and teams to work faster and more effectively.

Our ESG Solutions includes our ESG Advisory practice and our ESG software
offering.  Our  ESG  Advisory  practice  helps  companies  analyze,  assess  and
action  best  practices  to  attract  long-term  capital.  In  June  2022,  we  acquired
Metrio,  a  provider  of  ESG  data  collection,  analytics  and  reporting  services.
Metrio software is a cloud-based solution that helps firms manage ESG data,
perform greenhouse gas emissions calculations and accounting, and optimize
granular  data  collection,  report  publication  and  dashboarding  against  targets.
In  September  2023,  we  announced  the  launch  of  Nasdaq  Metrio,  which
integrates  Nasdaq  OneReport  and  Metrio  legacy  technologies  into  a  new
SaaS-based,  end-to-end  sustainability  platform.  The  new  platform  enables
corporates  to  collect,  measure,  disclose  and  communicate  investor-grade,
audited  ESG  data  efficiently  across  dozens  of  raters,  rankers  and  framework
organizations  to  drive  strategic  outcomes  and  attract  investors.  The  platform
also  features  a  new  Carbon  Accounting  and  Management  product  for
companies looking to focus on their scope 1, 2 and 3 emissions. We continue
to  launch  new  ESG  solutions  as  discussed  further  in  “Environmental,  Social
and Governance Matters” below.

Financial Technology

The  Financial  Technology  segment  delivers  world  leading  platforms  that
improve  the  liquidity,  transparency  and  integrity  of  the  global  economy  by
architecting and operating the world’s best markets. This segment comprises
Financial Crime Management Technology, Regulatory Technology and Capital
Markets Technology solutions.

We  are  a  leading  global  technology  solutions  provider  and  partner  to
exchanges,  clearing  organizations,  central  securities  depositories,  regulators,
banks, brokers, buy-side firms and corporate businesses, and power more than
130 marketplaces in more than 55 countries. Our solutions can handle a wide
array  of  assets,  including  but  not  limited  to  cash  equities,  equity  derivatives,
currencies,  various  interest-bearing  securities,  commodities,  energy  products
and digital currencies. Our solutions can also be used in the creation of new
asset classes by non-capital markets customers, as discussed further below.

Financial Crime Management Technology

Our  Financial  Crime  Management  Technology  business  includes  our  Verafin
solution  which  delivers  a  leading  platform  that  improves  the  integrity  and
transparency  of  the  financial  world  by  providing  SaaS  solutions  for  fraud
detection and AML.

The  financial  services  industry  has  seen  a  growing  demand  for  products  and
services  focused  on  anti-financial  crime.  Our  Verafin  solution  provides  a
cloud-based platform to help detect, investigate, and report money laundering
and  financial  fraud  to  approximately  2,500  financial  institutions  in  North
America.

Regulatory Technology

Regulatory Technology includes surveillance and AxiomSL solutions.

Our  surveillance  solutions  include  a  SaaS  platform  designed  for  banks,
brokers and other market participants to assist in complying with market rules,
regulations and internal market surveillance policies and serves more than 170
clients. We also provide a solution to regulators and exchanges with a robust
platform  to  manage  cross-market,  cross-asset  and  multi-venue  surveillance.
This  offering  powers  surveillance  for  more  than  50  exchanges  and  18
regulators.

AxiomSL is a global leader in risk data management and regulatory reporting
solutions for the financial industry, including banks, broker dealers and asset
managers.  Its  unique  enterprise  data  management  platform  delivers  data
lineage,  risk  aggregation,  analytics,  workflow  automation,  reconciliation,
validation and audit functionality, as well as disclosures. AxiomSL’s platform
supports compliance across a wide range of global and local regulations.

Capital Markets Technology

Capital  Markets  Technology  includes  market  technology,  trade  management
services and Calypso.

Our market technology solutions can handle a wide array of assets, including
but not limited to cash equities, equity derivatives, currencies, various interest-
bearing  securities,  commodities,  energy  products  and  digital  currencies.  Our
solutions can also be used in the creation of new asset classes by non-capital
markets customers, as discussed further below.

4

Nasdaq’s market technology is utilized by leading markets in North America,
Europe  and  Asia  as  well  as  emerging  markets  in  the  Middle  East,  Latin
America, and Africa.

We  continue  to  build  out  our  SaaS  business  portfolio  by  extending  and
migrating our current offerings to SaaS. Our market technology business has
evolved  from  its  origins  serving  the  capital  markets,  as  we  leverage  our
flexible  and  modular  architecture  technology  that  provides  next  generation
capital markets capabilities in an open and agile environment, to develop our
SaaS platform and offerings. We expect to continue to expand adoption of this
SaaS model by our clients in the future.

For  market  infrastructure  operators,  which  include  exchanges,  regulators,
clearinghouses  and  central  securities  depositories,  we  provide  and  deliver
mission-critical solutions across the trade lifecycle, which is designed to cover
all  aspects  of  a  market  operator’s  needs,  from  trading  and  clearing  to  risk
management,  market  surveillance,  index  development,  data,  management,
testing and quality assurance.

In addition to serving the market operators in the core capital markets, there is
a  demand  for  mission  critical  solutions  to  enable  robust  operation  of  new
emerging  asset  classes  such  as  crypto  currencies  and  native  digital  markets.
Our market technology business currently offers its services to several digital
assets exchanges, and the SaaS-based Marketplace Services Platform provides
next-generation marketplace capabilities spanning the transaction lifecycle to
facilitate the exchange of assets, services and information across various types
of market ecosystems and machine-to-machine transactions. The Marketplace
Services  Platform  is  targeted  at  new  emerging  digital  markets  and  enables
end-to-end marketplace implementation without the resources required for on-
premise solutions.

Numerous market technology projects involve complex delivery management
and  systems  integration.  Through  our  integration  services,  we  can  assume
responsibility  for  projects  that  involve  migration  to  a  new  system  and  the
establishment  of  entirely  new  marketplaces.  We  also  offer  operation  and
support  for 
the  applications,  systems  platforms,  networks  and  other
components  included  in  an  information  technology  solution,  as  well  as
advisory  services.  Our  ongoing  migration  to  the  cloud,  discussed  below,
created a blueprint for our Marketplace Technology clients that will be used to
demonstrate, guide and migrate their markets to the cloud, as well as for our
own future market migrations.

Our  trade  management  services  provide  market  participants  with  a  wide
variety of alternatives for connecting to and accessing our markets for a fee.
Our  marketplaces  may  be  accessed  via  a  number  of  different  protocols  used
for quoting, order entry, trade reporting and connectivity to various data feeds.
WorkX,  a  web-based,  front-end  interface  allows  market  participants  to  view
data,  utilize  risk  management  tools,  and  submit  and  review  trade  reports.
WorkX  enables  a  seamless  workflow  and  enhanced  trade  intelligence.  In
addition,  we  offer  a  variety  of  add-on  compliance  tools  to  help  market
participants comply with regulatory requirements.

We provide colocation services to market participants, whereby we offer firms
cabinet space and power to house their own equipment and servers within our
data  centers.  Additionally,  we  offer  a  number  of  wireless  connectivity
offerings between certain data centers using millimeter wave and microwave
technology.

We  completed  the  previously  announced  wind-down  of  our  broker  services
operations  business  in  2022.  This  business  primarily  offered  technology  and
customized  securities  administration  solutions  to  financial  participants  in  the
Nordic  market.  Such  services  and  solutions  primarily  consisted  of  flexible
back-office  systems,  which  allowed  customers 
to  efficiently  manage
safekeeping,  settlement  and  corporate  actions  and  reporting,  and  included
connectivity to exchanges and central securities depositories.

Calypso is a leading provider of front-to-back trading technology solutions for
the financial markets. The Calypso platform provides customers with a single
platform  designed  to  enable  consolidation,  innovation  and  growth.  The
platform supports front, middle and back office activities in exchange-traded
and  OTC  instruments  and  supports  multiple  financial  asset  classes  and  the
associated financial instruments. Calypso’s software application specializes in
capital  markets, 
investment  management,  risk  management,  clearing,
collateral, treasury and liquidity management.

Market Services

Our  Market  Services  segment  includes  our  equity  derivative  trading  and
clearing, cash equity trading, fixed income, currency and commodities trading.
We  operate  19  exchanges  across  several  asset  classes,  including  derivatives,
commodities, cash equity, debt, structured products and ETPs.

5

We  provide  trading  services  in  North  America  and  Europe.  In  the  U.S.,  we
operate  six  options  exchanges:  Nasdaq  PHLX,  The  Nasdaq  Options  Market,
Nasdaq  BX  Options,  Nasdaq  ISE,  Nasdaq  GEMX  and  Nasdaq  MRX.  These
exchanges  facilitate  the  trading  of  equity,  ETF,  index  and  foreign  currency
options.  Our  combined  options  market  share  in  2023  represented  the  largest
share  of  the  U.S.  market  for  multi-listed  equity  options.  Our  options  trading
platforms provide trading opportunities to retail investors, algorithmic trading
firms  and  market  makers,  who  tend  to  prefer  electronic  trading,  and
institutional  investors,  who  typically  require  high  touch  services  to  execute
their trades, which are often performed on our trading floor in Philadelphia.

We  also  operate  three  cash  equity  exchanges:  The  Nasdaq  Stock  Market,
Nasdaq BX and Nasdaq PSX. Our U.S. cash equity exchanges offer trading of
both  Nasdaq-listed  and  non-Nasdaq-listed  securities.  The  Nasdaq  Stock
Market  is  the  largest  single  venue  of  liquidity  for  trading  U.S.-listed  cash
equities.  Market  participants  include  market  makers,  broker-dealers,  ATSs,
institutional investors, and registered securities exchanges. We also operate a
U.S. corporate bond exchange for the listing of corporate bonds.

Market  Services  also  includes  revenues  from  U.S.  Tape  plans.  The  plan
administrators  sell  quotation  and  last  sale  information  for  all  transactions,
whether  traded  on  The  Nasdaq  Stock  Market  or  other  exchanges,  to  market
participants  and  to  data  distributors,  who  then  provide  the  information  to
subscribers. After deducting costs, the plan administrators distribute the tape
revenues  to  the  respective  plan  participants  based  on  a  formula  required  by
Regulation NMS that takes into account both trading and quoting activity.

In  Canada,  we  operate  an  exchange  with  three  independent  markets  for  the
trading  of  Canadian-listed  securities:  Nasdaq  Canada  CXC,  Nasdaq  Canada
CX2 and Nasdaq Canada CXD.

In  Europe,  we  operate  exchanges  in  Tallinn  (Estonia),  Riga  (Latvia)  and
Vilnius (Lithuania) as Nasdaq Baltic and exchanges in Stockholm (Sweden),
Copenhagen (Denmark), Helsinki (Finland), and Reykjavik (Iceland) together
with the clearing operations of Nasdaq Clearing, as Nasdaq Nordic.

Collectively, the Nasdaq Nordic and Nasdaq Baltic exchanges offer trading in
cash equities, depository receipts, warrants, convertibles, rights, fund units and
ETFs, as well as trading and clearing of derivatives and clearing of resale and
repurchase agreements. Our platform allows the exchanges to share the same
trading  system,  which  enables  efficient  cross-border  trading  and  settlement,
cross-exchange  membership  and  a  single  source  for  Nordic  data  products.
Settlement  and  registration  of  cash  equity  trading  takes  place  in  Sweden,
Finland, and Denmark via the local central securities depositories. In addition,
Nasdaq  owns  a  central  securities  depository  that  provides  notary,  settlement,
central maintenance and other services in the Baltic countries and Iceland.

In Europe, Nasdaq Nordic offers trading in derivatives, such as stock options
and  futures  and  index  options  and  futures.  Nasdaq  Clearing  offers  central
counterparty clearing services for stock options and futures and index options
and futures.

Nasdaq Fixed Income, or NFI, provides a wide range of products and services,
such as trading and clearing, for fixed income products in Sweden, Denmark,
Finland,  Iceland,  Estonia,  Lithuania  and  Latvia.  Nasdaq  is  the  largest  bond
listing venue in the Nordics, with more than 5,600 listed retail and institutional
bonds.  In  addition,  Nasdaq  Nordic  facilitates  the  trading  and  clearing  of
Nordic  fixed  income  derivatives  in  a  unique  market  structure.  Buyers  and
sellers  agree  to  trades  in  fixed  income  derivatives  through  bilateral
negotiations and then report those trades to Nasdaq Clearing. Nasdaq Clearing
offers  central  counterparty  clearing  services  for  fixed-income  options  and
futures  and  interest  rate  swaps.  Nasdaq  Clearing  also  operates  a  clearing
service for the resale and repurchase agreement market.

Nasdaq  Commodities  is  the  brand  name  for  Nasdaq’s  European  commodity-
trading  and  clearing.  Nasdaq
related  products  and  services  such  as 
Commodities’ offerings include derivatives in power, natural gas and carbon
emission  markets,  seafood  and  electricity  certificates.  These  products  are
listed on Nasdaq Oslo ASA, except for seafood, which is listed on Fish Pool, a
third-party  platform.  In  June  2023,  we  entered  into  an  agreement  to  sell  our
European energy trading and clearing business, subject to regulatory approval.

Nasdaq  Oslo  ASA  is  the  commodity  derivatives  exchange  for  European
products.  All  trades  with  Nasdaq  Oslo  ASA  are  subject  to  clearing  with
Nasdaq  Clearing,  which  offers  central  counterparty  clearing  services  for
commodities options and futures.

We also own a majority stake in Puro.earth, a Finnish-based leading platform
for carbon removal. Puro.earth offers engineered carbon removal instruments
that  are  verified  and  tradable  through  an  open,  online  platform.  Puro.earth’s
marketplace  capabilities  add  to  our  suite  of  ESG-focused  technologies  and
workflow solutions and give our clients further resources to achieve their ESG
objectives.

Enablers, Differentiators and Competition

Technology

Technology plays a key role in ensuring the growth, reliability and regulation
of  financial  markets.  We  have  established  a  technology  risk  program  to
evaluate  the  resiliency  of  critical  systems,  including  risks  associated  with
cybersecurity. This program is focused on identifying areas for improvement
in  systems,  and  implementing  changes  and  upgrades  to  technology  and
processes to minimize future risk. We have continued our focus on improving
the  security  of  our  technology  with  an  emphasis  on  employee  awareness
through  training,  targeted  phishing  education  campaigns,  and  new  tool
deployment for our securities operations team. See “Item 1A. Risk Factors,” in
this Annual Report on Form 10-K for further discussion.

6

We are focused on amplifying the impact that artificial intelligence, or AI, has
on  the  business  and  in  our  products.  We  continue  to  develop  products  and
services  using  AI,  including  generative  AI,  and  the  use  of  AI  in  product
development  is  a  priority  for  us  in  2024.  We  are  currently  leveraging  AI  to
further  develop  products  and  solutions  in  investment  analytics,  investor
relations  and  fraud  and  anti-money  laundering,  as  well  as  to  modernize
markets  with  the  SEC  approval  of  the  first  AI-powered  order  type.  For
example,  we  are  working  on  developing  AI  systems  to  track  financial
transactions  across  the  ecosystem  to  determine  potential  fraud,  money
laundering,  or  other  actions.  These  solutions  can  be  utilized  by  our  clients,
including  banks,  other  exchanges  and  brokers  firms  that  use  our  solutions  to
reduce or eliminate threats.

We  are  committed  to  the  ethical  and  responsible  use  of  AI  in  our  products,
services  and  business  operations.  Our  AI  governance  structure  aligns  the
application of AI with our core values through a framework that addresses the
new  and  unique  risks  that  AI  technology  presents,  while  enabling  us  to
explore  innovation  and  take  advantage  of  opportunities  that  AI  presents  to
better serve our customers, advance our business objectives and bring value to
our  shareholders.  Our  AI  governance  framework  applies  risk  management
across  AI-related  product  development  and  business  usage  in  the  company
through  a  multi-disciplinary  approach.  The  framework  puts  into  practice
Nasdaq’s  responsible  AI  usage  principles  and  considers  the  U.S.  National
Institute of Standards and Technology AI Risk Management Framework. It is
administered  through  company-wide  policies,  procedures  and  supporting
preventative and detective controls.

We believe that our focus on AI to enhance features of our existing offerings
and  in  the  development  of  new  solutions,  together  with  our  significant
proprietary data sets, provides us with a competitive advantage.

During  2023,  Nasdaq  continued  its  shift  to  utilizing  and  deploying  cloud
infrastructure.  We  also  migrated  two  additional  exchanges  to  the  cloud,  in
addition  to  the  options  exchange  that  we  migrated  in  2022.  We  believe  that
migrating our exchanges to the cloud, through our partnership with AWS will
result  in  improved  performance  and  increased  flexibility  for  our  customers.
We expect to move additional North American markets to the cloud with AWS
during  the  next  several  years.  The  shift  to  cloud-based  markets  will  enable
Nasdaq  to  provide  its  clients  access  to  cloud-based  capabilities,  including
virtual  connectivity  services,  market  analytics  and  machine  learning,  at  a
lower cost. We also expect to leverage the cloud-based infrastructure for our
market  technology  clients,  assisting  such  clients  in  developing  their  own
platforms  and  customizing  their  offerings  for  their  local,  rapidly  changing
industry dynamics. Additionally, we expanded our existing colocation facility
to meet the growing demand of market participants that seek proximity to the
Nasdaq  trading  systems.  Our  expanded  and  enhanced  facility  is  designed  to
provide the optimal environment for the next generation of

compute workloads and offer clients access to a wider range of services and
capabilities.

To  facilitate  the  exchange  migration  to  AWS,  Nasdaq  will  also  leverage  its
Fusion  technology  platform.  Fusion  positions  Nasdaq’s  North  American  and
European markets to manage, operate and deploy a common platform that can
be  used  across  our  nine  Nasdaq  derivative  markets,  while  enabling  our
markets for cloud deployment.

Competitive Strengths

We are a global, client-focused technology company with expertise in markets
and financial technology. We deploy robust technology capabilities and have
developed  innovative  solutions  to  further  address  client  needs  across  the
financial  ecosystem.  Our  business  segments  complement  each  other  and  we
believe  that  our  strong  competitive  position  in  large,  high-growth  markets
positions us for sustained growth.

A Unique Value Proposition

We operate leading platforms that can improve the liquidity, transparency, and
integrity of the global financial ecosystem, allowing us to:

• Develop  efficient  and  reliable  technologies  to  facilitate  and  protect  the

financial system across asset classes;

• Empower  our  clients  to  effectively  navigate  the  capital  markets,  achieve
their  sustainability  goals,  and  maintain  corporate  governance  excellence;
and

• Provide  data,  tools  and  insights  that  drive  sound  decision  making  while

complying with evolving regulatory requirements.

Technological Strength

The strength and resiliency of our technology, enhanced by our new Financial
Technology  division,  in  meeting  the  advancing  demands  of  our  global
customer  base  is  vital  to  the  continued  success  of  our  business  and
distinguishes us from our competitors.

We strive to be a trusted partner to a diverse range of clients that participate
across the global financial ecosystem, including:

• Banks and Financial Institutions - Providing safety and integrity through
a suite of trade surveillance, cloud-native fraud and anti-money laundering
solutions and robust regulatory reporting software.

• Market  Infrastructure  Operators  -  Assisting  market  infrastructure
operators  in  increasing  efficiency,  meeting  customer  needs,  and  growing
revenue across the trade lifecycle.

• Brokers  and  Traders  -  Helping  brokers  and  traders  to  confidently  plan,

optimize, manage risk and execute their business vision.

7

• Market  Participants  -  Providing  market  participants  with  access  to
liquidity  and  enabling  them  to  efficiently  consume,  monitor,  analyze,  and
capitalize on real-time market changes.

• Listed  Companies  -  Enabling  companies  to  access  capital  markets
effectively,  manage  stakeholders  and  leverage  technology  to  operate  and
govern effectively.

• Investors  and  Asset  Managers  -  Offering  products  and  services  to  assist
investors and asset managers in optimizing their portfolios and offerings.

Competition

Capital Access Platforms

Our  Data  business  includes  proprietary  data  products.  Proprietary  data
products  are  made  up  exclusively  of  data  derived  from  each  exchange’s
systems.  Competition  in  the  data  business  is  influenced  by  rapidly  changing
technology and the creation of new product and service offerings.

Our  proprietary  data  products  face  competition  globally  from  alternative
exchanges  and  trading  venues  that  offer  similar  products.  Our  data  business
competes with other exchanges and third-party vendors to provide information
to  market  participants.  Examples  of  our  competitors  in  proprietary  data
products are ICE, Cboe, and TSX.

Our Listing Services business in both the U.S. and Europe provides a means
of  facilitating  capital  formation  through  public  capital  markets.  There  are
competing ways of raising capital, and we seek to demonstrate the benefits of
listing  shares  on  our  exchange.  Our  primary  competitor  for  larger  company
stock share listings in the U.S. is NYSE. The Nasdaq Stock Market competes
with  local  and  international  markets  located  outside  the  U.S.  for  listings  of
equity securities of both U.S. and non-U.S. companies that choose to list (or
dual-list)  outside  of  their  home  country.  For  example,  The  Nasdaq  Stock
Market  competes  for  listings  with  exchanges  in  Europe  and  Asia,  such  as
London Stock Exchange Group plc, or LSE, and The Stock Exchange of Hong
Kong  Limited.  Additionally,  we  face  competition  from  private  equity  firms
that may elect to keep their portfolio companies as private companies.

The Listings Services business in Europe is characterized by a large number of
exchanges competing for new or secondary listings. Each country has one or
more  national  exchanges,  which  are  often  the  first  choice  of  companies  in
each  respective  country.  For  those  considering  an  alternative,  competing
European  exchanges  that  frequently  attract  many  listings  from  outside  their
respective  home  countries  include  LSE,  Euronext  N.V.  and  Deutsche  Börse
AG. In addition to the larger exchanges, companies seeking capital or liquidity
from public capital markets are able to raise capital without a regulated market
listing  and  can  consider  trading  their  shares  on  smaller  markets  and  quoting
facilities.

Our Index business offers Nasdaq-branded indices and financial products and
faces competition from providers of various competing financial indices. For
example, there are a number of indices that aim to track the technology sector
and  thereby  compete  with  the  Nasdaq-100  Index  and  the  Nasdaq  Composite
Index. We face competition from investment banks, dedicated index providers,
markets  and  other  product  developers,  including  S&P  Dow  Jones  Indices,
MSCI and FTSE Russell.

includes  our  analytics  and  corporate  solutions
Workflow  &  Insights 
businesses.  Our  analytics  business  faces  competition  from  a  broad  array  of
data  and  analytics  suppliers,  both  established  firms  and  small  start-ups.  Our
primary  competitors  are  Morningstar,  FactSet  and  any  number  of  smaller
firms  along  with  start-up  data  providers  and  aggregators.  Our  analytics
business offerings compete with other analytics providers, including Addepar
and Caissa.

Our  corporate  solutions  business  faces  competition  that  can  be  varied  and
fragmented. For our Investor Relations Intelligence solutions, there are many
regional  competitors  and  relatively  few  global  providers.  Other  exchange
operators  are  partnering  with  firms  that  have  capabilities  in  this  area  and
seeking  to  acquire  relevant  assets  in  order  to  provide  investor  relations
services to customers alongside listing services. Our ESG Solutions, including
Nasdaq  Metrio  and  ESG  Advisory,  are  positioned  in  evolving  markets  with
competitors  offering  multiple  point  solutions  providing  software,  data  or
consulting services. The competitive landscape for our Governance Solutions
products varies by customer segment and geography. Most competitors offer
SaaS  solutions  that  are  supported  by  a  data  centered  strategy,  while  certain
firms  offer  specialized  services  that  focus  on  a  single  niche  segment.
Customers  frequently  seek  single-source  providers  that  are  able  to  address  a
broad range of needs within a single platform.

Financial Technology

For  our  Financial  Crime  Management  Technology  and  trade  and  market
surveillance  businesses,  competitors  include  core  banking  solution  providers
ranging from small to large, independent solution providers, FinTech start-ups
and in-house custom builds. We compete against enterprise solution providers
and  point  solutions  for  clients  with  larger  AUM.  Competitors  also  include
companies that serve multiple industries in addition to financial services with
generalized  solutions,  such  as  business  intelligence  tools,  data  integrators,
investigation  platforms  and  software  covering  the  broader  compliance
lifecycle.  Recently,  there  has  been  an  increase  of  FinTech  start-ups  shifting
into  the  surveillance,  fraud  detection  and  AML  space  offering  highly-
specialized  solutions  for  advanced  data  analytics,  artificial  intelligence  and
machine  learning  technology.  The  Financial  Crime  Management  Technology
and surveillance offerings compete on a number of factors, including but not
limited to, increased workflow efficiency, quality of the data, quality of alerts
and pricing.

8

Our Financial Crime Management Technology and surveillance offerings must
demonstrate the ability to decrease false-positives and provide in-depth views
into potential abuses and risks that stem from those cases. These offerings help
firms  reduce  both  the  reputational  and  regulatory  risk  as  well  as  the
complexity in efforts to keep markets and financial institutions safe.

Our  AxiomSL  product,  which  includes  financial,  statistical  and  prudential
reporting  as  well  as  shareholder  disclosures,  trade  reporting  and  ESG
reporting, competitors include large independent solution providers, in-house
solutions  at  financial  institutions  as  well  as  some  smaller  independent  point
solution  providers.  As  regulatory  reporting  becomes  more  granular  and  time
sensitive, the ability of our platform to operate with speed at scale, and with
consistency  across  functional  business  domains  continues  to  set  AxiomSL
apart.

For  our  Calypso  product,  which  includes  solutions  for  cross-asset,  front-to-
back  trading,  treasury,  risk  and  collateral  management,  competitors  include
similar  enterprise  solution  providers  in  size  and  footprint,  as  well  as
local/regional  players  focusing  on  the  smaller  end  of  the  client  base.  In  the
higher tier of client base, such as global banks, internal development is very
often  either  the  incumbent  solution  or  an  alternative  to  FinTech  vendors.
Competitors  also  sometimes  include  companies  that  provide  point  solutions,
such as pricing library providers, and post-trade service providers.

Our  market  technology  business  faces  competition  from  exchanges  and
exchange-related  businesses  that  internally  develop  their  technology.  This
model  has  gradually  changed  as  many  operators  have  recognized  the  cost-
savings  made  possible  by  buying  technology  from  third  parties.  As  a  result,
two  types  of  competitors  have  emerged  in  our  market  technology  business:
exchange  operators  and  technology  providers  unaffiliated  with  exchanges.
These  organizations  make  available  a  range  of  off-the-shelf  technology,
including 
information
dissemination,  and  offer  customization  and  operation  expertise.  Market
conditions in market technology are evolving rapidly, which makes continuous
investment and innovation a necessity. Our partnership with AWS enables us
to compete with other companies that are developing cloud-based exchanges
and market technology offerings.

settlement,  depository  and 

trading,  clearing, 

Our  trade  management  services  business  competes  with  other  exchange
operators, extranet providers, and data center providers.

Market Services

We  face  intense  competition  in  North  America  and  Europe.  We  seek  to
provide market participants with greater functionality, trading system stability
and  performance,  high  levels  of  customer  service,  and  efficient  pricing.  In
both  North  America  and  Europe,  our  competitors  include  other  exchange
operators,  operators  of  non-exchange  trading  systems  and  banks  and
brokerages that operate their own internal trading pools and platforms.

9

In  the  U.S.,  our  options  markets  compete  with  exchanges  operated  by  Cboe
Global Markets, Inc., or Cboe, Miami International Holdings, Inc., or MIAX,
Intercontinental Exchange, Inc., or ICE, Members Exchange, or MEMX, and
BOX  Options  Market.  In  cash  equities  in  the  U.S.,  we  compete  with
exchanges operated by Cboe, ICE, MIAX, The Investors Exchange, Members
Exchange  and  Long  Term  Stock  Exchange.  We  also  face  competition  from
ATSs, known as “dark pools,” and other less-heavily regulated broker-owned
trade  facilitation  systems,  as  well  as  from  other  types  of  OTC  trading.  In
Canada, our cash equities exchange competes principally with exchanges such
as the Toronto Stock Exchange, or TSX.

Our U.S. Tape plans earn revenue from consolidated data products which are
distributed by SEC-mandated consolidators (one for Nasdaq-listed stocks and
another  for  NYSE  and  other-listed  stocks)  that  share  the  revenue  among  the
exchanges  that  contribute  data.  The  consolidated  data  business  is  under
competitive pressure from other securities exchanges that trade Nasdaq-listed
securities.  In  addition,  The  Nasdaq  Stock  Market  similarly  competes  for  the
tape fees from the sale of information on securities listed on other markets.

In  Europe,  our  cash  equities  markets  compete  with  exchanges  such  as
Euronext  N.V.,  Deutsche  Börse  AG,  LSE  and  many  Multilateral  Trading
Facilities,  or  MTFs,  such  as  Cboe,  Turquoise  and  Aquis.  Our  competitors  in
the  trading  and  clearing  of  options  and  futures  on  European  equities  include
Eurex,  Cboe,  ICE  Futures  Europe  and  London  Clearing  House,  or  LCH.  In
addition,  in  equities  markets  in  Europe,  we  face  competition  from  other
broker-owned systems, dark pools, Systematic Internalizers, or SIs, and other
types  of  OTC  trading.  Competition  among  exchanges  for  trading  European
equity derivatives tends to occur where there is competition in the trading of
the  underlying  equities.  In  addition  to  exchange-based  competition,  we  face
competition from OTC derivative markets.

The  implementation  of  MiFID  II  and  MiFIR  has  resulted  in  further
competitive  pressure  on  our  European  trading  business.  SIs  are  attracting  a
significant share of electronically matched volume and compete aggressively
for  the  trading  of  equity  securities  listed  on  our  Nordic  exchanges.  Different
bilateral  trading  systems  pursuing  block  business  also  remain  active  in
Europe.  Regulators  are  continuously  monitoring  the  market  structure  and
have, in a series of consultations, asked for input regarding suggested changes
to MiFID II.

Our European fixed income and commodities products and services are subject
to competitive pressure from European exchanges and clearinghouses.

Intellectual Property

We believe that our intellectual property assets are important for maintaining
the competitive differentiation of our products, systems, software and services,
enhancing our ability to access technology of third parties and maximizing our
return on research and development investments.

To  support  our  business  objectives  and  benefit  from  our  investments  in
research  and  development,  we  actively  create  and  maintain  a  wide  array  of
intellectual property assets, including patents and patent applications related to
our  innovations,  products  and  services;  trademarks  related  to  our  brands,
products  and  services;  copyrights  in  software  and  creative  content;  trade
secrets;  and  through  other  intellectual  property  rights,  licenses  of  various
kinds and contractual provisions. We enter into confidentiality and invention
assignment agreements with our employees and contractors, and utilize non-
disclosure  agreements  with  third  parties  with  whom  we  conduct  business  in
order  to  secure  and  protect  our  proprietary  rights  and  to  limit  access  to,  and
disclosure of, our proprietary information.

We  own,  or  have  licensed,  rights  to  trade  names,  trademarks,  domain  names
and service marks that we use in conjunction with our operations and services.
We have registered many of our most important trademarks in the U.S. and in
foreign  countries.  For  example,  our  primary  “Nasdaq”  mark  is  a  registered
trademark  that  we  actively  seek  to  protect  in  the  U.S.  and  in  over  50  other
countries worldwide.

Over  time,  we  have  accumulated  a  robust  portfolio  of  issued  patents  in  the
U.S. and in many other jurisdictions across the world. We currently hold rights
to  patents  relating  to  certain  aspects  of  our  products,  systems,  software  and
services, but we primarily rely on the innovative skills, technical competence
and marketing abilities of our personnel. No single patent is in itself core to
the operations of Nasdaq or any of its principal business areas.

Corporate Venture Program

We  operate  a  corporate  venture  program  to  make  minority  investments
primarily  in  emerging  growth  FinTech  companies  that  are  strategically
relevant  to,  and  aligned  with,  Nasdaq.  Investments  are  made  through  the
venture  program  to  further  our  research  and  development  efforts  and
accelerate  the  path  to  commercial  viability.  We  expect  that  capital  invested
will  continue  to  be  modest  and  will  not  have  a  material  impact  on  our
consolidated  financial  statements,  existing  capital  return  or  deployment
priorities. Since its inception in 2017, our venture program has grown in size
and  has  invested  in  companies  covering  various  sectors,  including  data,
analytics  and  workflow  technologies,  blockchain  and  digital  assets,  market
infrastructure,  anti-financial  crime,  new  marketplaces,  enabling  technologies
and  ESG.  As  of  December  31,  2023,  our  investments,  which  include  equity
and convertible debt investments, were valued at $169 million.

culture  of  inclusivity  and  expanding  our  portfolio  of  ESG-related  solutions
and services.

The  Nominating  &  ESG  Committee  has  formal  responsibility  and  oversight
for  corporate  ESG  policies  and  programs  and  receives  regular  reporting  on
key  ESG  matters  and  initiatives.  Our  Corporate  ESG  Steering  Committee
serves as the central coordinating body for our ESG strategy; it is co-chaired
by  executive  leaders  and  comprised  of  a  cross-functional  group  of  Nasdaq
senior executives.

We  continued  to  be  committed  to  our  decarbonization  and  climate  strategy,
achieving  carbon  neutrality  across  all  our  business  operations  for  the  sixth
consecutive  year  and  are  working  towards  our  short-  and  long-term  net  zero
science-based  targets,  which  were  validated  and  approved  by  the  Science
Based  Targets  initiative  in  2022.  In  2023,  we  were  named  to  the  Dow  Jones
Sustainability North America Index for the eighth consecutive year. We were
included on Just Capital’s Just100 list of America’s most just companies and
received  recognition  from  the  Bloomberg  Gender-Equity  Index  and  The
Human  Rights  Campaign’s  Corporate  Equality  Index.  In  addition,  Nasdaq
maintained industry leading scores from ESG rating agencies:

• MSCI: maintained a rating of “AA,” placing Nasdaq in MSCI’s “Leaders”

category.

• CDP: earned a place on CDP’s “Climate A List” for climate disclosures and

actions for the second consecutive year.

• EcoVadis:  maintained  “Gold  Medal”  status,  a  recognition  reserved  for  the

top 5% of all rated companies.

• 2023 S&P Corporate Sustainability Assessment: maintained a score of 60,

placing Nasdaq in the 96th percentile of our industry group.

Our  environmental  footprint  is  relatively  small  due  to  the  nature  of  our
business  operations.  We  remain  committed  to  reducing  our  environmental
impact,  focusing  on  several  key  areas,  including  our  energy  use,  the
management  of  our  workspaces  and  how  we  conduct  business  travel,  and
engagement with our value chain. We seek to reduce our atmospheric carbon
emissions  and  we  manage  our  water  use  and  the  waste  associated  with  our
business operations.

We help companies of all ESG maturity levels through our robust combination
of technology, tools, data, insights and capital market solutions.

Environmental, Social and Governance Matters

In 2023, we launched three new ESG-related solutions:

Nasdaq  is  committed  to  our  long-term  ESG  and  sustainability  strategy,
advocacy  and  oversight.  We  continue  to  engage  with  internal  and  external
stakeholders  at  all  levels  regarding  sustainability  matters.  During  2023,  we
advanced  our  corporate,  community  and  commercial  ESG  efforts,  including
furthering  our  commitment  to  climate  change  awareness,  reducing  our
environmental impact, building a workplace

• Nasdaq  Metrio,  a  SaaS-based,  end-to-end  platform  designed  to  help

corporate clients collect, measure and report sustainability data;

• Nasdaq  eVestment  ESG  Analytics,  a  data  analytics  platform  that  unlocks
greater  transparency  for  the  global  institutional  market,  helping  investors
make data-driven impact investment decisions; and

• Nasdaq  Sustainable  Lens,  a  SaaS-based  ESG  intelligence  platform  that

harnesses the power of generative artificial

10

intelligence  to  help  companies  navigate  complexity  and  respond  to
stakeholders’ demands for greater transparency.

During  2023,  we  also  maintained,  and  continued  to  expand,  our  portfolio  of
ESG services and solutions for our clients and stakeholders.

each  of  which  operates  an  options  market  under  its  own  SRO  license.  As
SROs, each entity has separate rules pertaining to  its  broker-dealer  members
and  listed  companies,  as  applicable.  Broker-dealers  that  choose  to  become
members of our exchanges are subject to the rules of those exchanges.

In 2023, we requested our existing leading suppliers by spend to attest to our
Supplier Code of Ethics. The Supplier Code of Ethics, which is available on
our website, encourages our suppliers and vendors to adopt sustainability and
environmental  practices  in  line  with  our  published  Environmental  Practices
Statement and to promote a diverse and inclusive workforce. Additionally, our
new  suppliers  are  required  to  attest  to  the  Supplier  Code  of  Ethics  in
connection with the commencement of their engagement.

For more information regarding our ESG efforts in 2023, both internally and
externally,  please  see  the  section  entitled  “Human  Capital  Management”
below and our Proxy Statement.

All of our U.S. national securities exchanges are subject to SEC oversight, as
prescribed by the Exchange Act, including periodic and special examinations
by the SEC. Our exchanges also are potentially subject to regulatory or legal
action  by  the  SEC  at  any  time  in  connection  with  alleged  regulatory
violations.  We  have  been  subject  to  a  number  of  routine  reviews  and
inspections  by  the  SEC  or  external  auditors  in  the  ordinary  course,  and  we
have been and may in the future be subject to SEC enforcement proceedings.
To  the  extent  such  actions  or  reviews  and  inspections  result  in  regulatory  or
other changes, we may be required to modify the manner in which we conduct
our business, which may adversely affect our business, operating results and
financial condition.

Regulation

We are subject to extensive regulation in the U.S., Canada and Europe.

U.S. Regulation

U.S.  federal  securities  laws  establish  a  system  of  cooperative  regulation  of
securities  markets,  market  participants  and  listed  companies.  SROs  conduct
the day-to-day administration and regulation of the nation’s securities markets
under the close supervision of, and subject to extensive regulation, oversight
and enforcement by, the SEC. SROs, such as national securities exchanges, are
registered with the SEC.

This regulatory framework applies to our U.S. business in the following ways:

National Securities Exchanges. SROs in the securities industry are an essential
component  of  the  regulatory  scheme  of  the  Exchange  Act  responsible  for
providing  fair  and  orderly  markets  and  protecting  investors.  The  Exchange
Act and the rules thereunder, as well as each SRO’s own rules, impose many
regulatory and operational responsibilities on SROs, including the day-to-day
responsibilities for market and broker-dealer oversight. Moreover, an SRO is
responsible for enforcing compliance by its members, and persons associated
with  its  members,  with  the  provisions  of  the  Exchange  Act,  the  rules  and
regulations  thereunder,  and  the  rules  of  the  SRO,  including  rules  and
regulations governing the business conduct of its members.

Nasdaq  currently  operates  three  cash  equity,  six  options  markets  and  one
corporate bond market in the U.S. We operate The Nasdaq Stock Market, The
Nasdaq  Options  Market  and  the  Corporate  Bond  Market  pursuant  to  The
Nasdaq  Stock  Market’s  SRO  license;  Nasdaq  BX  and  Nasdaq  BX  Options
pursuant  to  Nasdaq  BX’s  SRO  license;  Nasdaq  PSX  and  Nasdaq  PHLX
pursuant  to  Nasdaq  PHLX’s  SRO  license;  and  Nasdaq  ISE,  Nasdaq  GEMX
and Nasdaq MRX,

revisions 

including 

Section 19 of the Exchange Act provides that our exchanges must submit to
the  SEC  proposed  changes  to  any  of  the  SROs’  rules,  practices  and
procedures, 
to  provisions  of  our  certificate  of
incorporation  and  by-laws  that  constitute  SRO  rules.  The  SEC  will  typically
publish such proposed changes for public comment, after which the SEC may
approve  or  disapprove  the  proposal,  as  it  deems  appropriate.  SEC  approval
requires  a  finding  by  the  SEC  that  the  proposal  is  consistent  with  the
requirements  of  the  Exchange  Act  and  the  rules  and  regulations  thereunder.
Pursuant  to  the  requirements  of  the  Exchange  Act,  our  exchanges  must  file
with  the  SEC,  among  other  things,  all  proposals  to  change  their  pricing
structure.

Nasdaq conducts real-time market monitoring, certain equity surveillance not
involving  cross-market  activity,  most  options  surveillance,  rulemaking,
enforcement  and  membership  functions  through  our  Nasdaq  Regulation
department.  We  review  suspicious  trading  behavior  discovered  by  our
regulatory  staff,  and  depending  on  the  nature  of  the  activity,  may  refer  the
activity  to  FINRA  for  further  investigation.  Pursuant  to  regulatory  services
agreements  between  FINRA  and  our  SROs,  FINRA  provides  certain
regulatory  services  to  our  markets,  including  some  regulation  of  trading
activity and surveillance and investigative functions. Our SROs retain ultimate
regulatory  responsibility  for  all  regulatory  activities  performed  under
regulatory agreements by FINRA, and for fulfilling all regulatory obligations
for  which  FINRA  does  not  have  responsibility  under  the  regulatory  services
agreements.

In addition to its other SRO responsibilities, The Nasdaq Stock Market, as a
listing  market,  also  is  responsible  for  overseeing  each  listed  company’s
compliance  with  The  Nasdaq  Stock  Market’s  financial  and  corporate
governance  standards.  Our 
listing  qualifications  department  evaluates
applications submitted by issuers seeking to list their securities on The Nasdaq
Stock  Market  to  determine  whether  the  quantitative  and  qualitative  listing
standards have been

11

satisfied.  Once  securities  are  listed,  the  listing  qualifications  department
monitors each issuer’s on-going compliance with The Nasdaq Stock Market’s
continued listing standards.

Broker-dealer  regulation.  Nasdaq’s  broker-dealer  subsidiaries  are  subject  to
regulation  by  the  SEC,  the  SROs  and  various  state  securities  regulators.
Nasdaq  operates  three  broker-dealers:  Nasdaq  Execution  Services,  LLC,
NFSTX,  LLC,  and  Nasdaq  Capital  Markets  Advisory  LLC.  Each  broker-
dealer is registered with the SEC, a member of FINRA and registered in the
U.S. states and territories required by the operation of its business. In addition,
we own a minority interest in NPM Securities, LLC.

Nasdaq Execution Services operates as our routing broker for sending orders
from  Nasdaq’s  U.S.  cash  equity  and  options  exchanges  to  other  venues  for
execution. NFSTX is a registered ATS and acts as an intermediary to facilitate
secondary transactions in certain funds (both registered or not registered under
the  Investment  Company  Act  of  1940),  business  development  companies,
certain  closed-end  funds  and  private  real  estate  investment  funds.  Nasdaq
Capital  Markets  Advisory  acts  as  a  third-party  advisor  to  privately-held  or
publicly-traded companies during IPOs and various other offerings.

The SEC, FINRA and SROs adopt, and require strict compliance with, rules
and  regulations  applicable  to  broker-dealers.  The  SEC,  SROs  and  state
securities  commissions  may  conduct  administrative  proceedings  which  can
result  in  censures,  fines,  the  issuance  of  cease-and-desist  orders  or  the
suspension or expulsion of a broker-dealer, its officers or employees. The SEC
and  state  regulators  may  also  institute  proceedings  against  broker-dealers
seeking an injunction or other sanction. All broker-dealers have an SRO that is
assigned by the SEC as the broker-dealer’s Designated Examining Authority.
The  Designated  Examining  Authority  is  responsible  for  examining  a  broker-
dealer for compliance with the SEC’s financial responsibility rules. FINRA is
the  current  Designated  Examining  Authority  for  each  of  our  broker-dealer
subsidiaries.

Our registered broker-dealers are subject to regulatory requirements intended
to  ensure  their  general  financial  soundness  and  liquidity,  which  require  that
they comply with certain minimum capital requirements. As of December 31,
2023,  each  of  our  broker-dealers  were  in  compliance  with  applicable  capital
requirements.

Regulatory  contractual  relationships  with  FINRA.  Our  SROs  have  signed  a
series of regulatory service agreements covering the services FINRA provides
to the respective SROs. Under these agreements, FINRA personnel act as our
agents in performing the regulatory functions outlined above, and FINRA bills
us  a  fee  for  these  services.  These  agreements  have  enabled  us  to  reduce  our
headcount  while  ensuring  that  the  markets  for  which  we  are  responsible  are
properly regulated. However, we have reduced the scope of services provided
by  FINRA  under  these  regulatory  services  agreements  and  are  performing
certain  of  those  regulatory  functions  directly.  In  addition,  our  SROs  retain
ultimate

regulatory  responsibility  for  all  regulatory  activities  performed  under  these
agreements by FINRA.

Exchange Act Rule 17d-2 permits SROs to enter into agreements, commonly
called  Rule  17d-2  agreements,  approved  by  the  SEC  with  respect  to
enforcement of common rules relating to common members. Our SROs have
entered into several such agreements under which FINRA assumes regulatory
responsibility for various rules or areas covered by agreements.

Regulation  NMS  and  Options  Intermarket  Linkage  Plan.  We  are  subject  to
Regulation  NMS  for  our  cash  equity  markets,  and  our  options  markets  have
joined the Options Intermarket Linkage Plan. These are designed to facilitate
the routing of orders among exchanges to create a national market system as
mandated  by  the  Exchange  Act.  One  of  the  principal  purposes  of  a  national
market  system  is  to  assure  that  brokers  may  execute  investors’  orders  at  the
best market price. Both Regulation NMS and the Options Intermarket Linkage
Plan  require  that  exchanges  avoid  trade-throughs,  locking  or  crossing  of
markets  and  provide  market  participants  with  electronic  access  to  the  best
prices among the markets for the applicable cash equity or options order.

In addition, Regulation NMS requires that every national securities exchange
on which an NMS stock is traded and every national securities association act
jointly  pursuant  to  one  or  more  national  market  system  plans  to  disseminate
consolidated information, including a national best bid and national best offer,
on  quotations  for  transactions  in  NMS  stocks,  and  that  such  plan  or  plans
provide for the dissemination of all consolidated information for an individual
NMS stock through a single plan processor.

The UTP Plan was filed with and approved by the SEC as a national market
system  plan  in  accordance  with  the  Exchange  Act  and  Regulation  NMS  to
provide  for 
the  collection,  consolidation  and  dissemination  of  such
information for Nasdaq-listed securities. The Nasdaq Stock Market serves as
the  processor  for  the  UTP  Plan  pursuant  to  a  contract  for  a  two-year  term
through  October  2025.  The  Nasdaq  Stock  Market  also  serves  as  the
administrator for the UTP Plan. To fulfill its obligations as the processor, The
Nasdaq Stock Market has designed, implemented, maintained, and operated a
data  processing  and  communications  system,  hardware,  software  and
communications infrastructure to provide processing for the UTP Plan. As the
administrator,  The  Nasdaq  Stock  Market  manages  the  distribution  of  market
data, the collection of the resulting market data revenue, and the dissemination
of that revenue to plan members in accordance with the terms of the UTP Plan
and of Regulation NMS.

12

In  September  2023,  the  SEC  adopted  an  order  to  require  changes  to  the
governance  of  securities  information  processors.  The  new  order  would  limit
the  voting  right  of  affiliated  SROs  (including  those  owned  by  Nasdaq)  and
would  limit  the  ability  of  SROs  to  serve  as  administrators  for  securities
information  processors.  A  schedule  for  implementing  the  new  order  has  not
been imposed by the SEC, so we are not certain of the timing or the impact on
our business or our role as a securities information processor.

In December 2020, the SEC adopted a rule to modify the infrastructure for the
collection, consolidation and dissemination of market data for exchange-listed
national market stocks, or NMS data. The rule changes include, among other
things,  requiring  exchanges  to  add  more  “core  data”  to  the  securities
information  processors,  including  partial  depth-of-book,  certain  odd-lot
regulatory,  and  administrative  data;
quotations/transactions,  auction, 
eliminating central, official consolidators of tape plans and enabling multiple
competing  consolidators  to  register  to  aggregate  and  disseminate  core  data;
and authorizing persons to purchase and aggregate core data directly from the
exchanges  for  their  own  use.  In  September  2022,  the  SEC  disapproved  fees
proposed by exchanges to implement the rule but did not direct the exchanges
to  take  further  action  to  implement  the  rule.  Accordingly,  a  schedule  for
implementing  the  rule  has  not  been  imposed  by  the  SEC,  and  we  are  not
certain of the timing, or the impact, of these new rules on our business or role
as a securities information processor.

Regulation SCI.  Regulation  SCI  is  a  set  of  rules  designed  to  strengthen  the
technology  infrastructure  of  the  U.S.  securities  markets.  Regulation  SCI
applies  to  national  securities  exchanges,  operators  of  certain  ATSs,  market
data information providers and clearing agencies, subjecting these entities to
extensive compliance obligations, with the goals of reducing the occurrence of
technical  issues  that  disrupt  the  securities  markets  and  improving  recovery
time when disruptions occur. We  implemented  an  inter-disciplinary  program
to ensure compliance with Regulation SCI. We have also created Regulation
SCI  policies  and  procedures,  updated  internal  policies  and  procedures,  and
developed  an 
to  ensure
compliance.

technology  governance  program 

information 

Regulation of Registered Investment Advisor Subsidiary. Our subsidiary NDW
is  an  investment  advisor  registered  with  the  SEC  under  the  Investment
Advisors  Act  of  1940.  In  this  capacity,  NDW  is  subject  to  oversight  and
inspections  by  the  SEC.  Among  other  things,  registered  investment  advisors
like  NDW  must  comply  with  certain  disclosure  obligations,  advertising  and
fee  restrictions  and  requirements  relating  to  client  suitability  and  custody  of
funds  and  securities.  Registered  investment  advisors  are  also  subject  to  anti-
fraud provisions under both federal and state law.

CFTC  Regulation.  The  Dodd-Frank  Wall  Street  Reform  and  Consumer
Protection  Act  resulted  in  increased  CFTC  regulation  of  our  use  of  certain
regulated  derivatives  products,  as  well  as  the  operations  of  some  of  our
subsidiaries outside the U.S. and their customers.

Canadian Regulation

Regulation  of  Nasdaq  Canada  is  performed  by  the  Canadian  Securities
Administrators, an umbrella organization of Canada’s provincial and territorial
securities  regulators.  As  a  recognized  exchange  in  Ontario,  Nasdaq  Canada
must comply with the terms and conditions of its exchange recognition order.
While exempt from exchange recognition in each jurisdiction in Canada other
than  Ontario  where  Nasdaq  Canada  carries  on  business,  Nasdaq  must  also
comply  with  the  terms  and  conditions  of  an  exemption  order  granted  by  the
other jurisdictions in order to maintain its exemptive status. Oversight of the
exchange  is  performed  by  Nasdaq  Canada’s  lead  regulator,  the  Ontario
Securities Commission.

Nasdaq Canada is subject to several national marketplace related instruments
which  set  out  requirements  for  marketplace  operations,  trading  rules  and
managing electronic trading risk. Exchange terms and conditions include but
are  not  limited  to,  requirements  for  governance,  regulation,  rules  and
rulemaking, fair access, conflict management and financial viability.

European Regulation

Regulation of our markets in the European Union and the European Economic
Area  focuses  on  matters  relating  to  financial  services,  listing  and  trading  of
securities,  clearing  and  settlement  of  securities  and  commodities,  as  well  as
issues related to market abuse.

We are subject to MiFID II and MiFIR, the European Union’s Market Abuse
Regulation, which primarily affects our European trading businesses. Many of
the  provisions  of  MiFID  II  and  MiFIR  are  implemented  through  technical
standards  drafted  by  the  European  Securities  and  Markets  Authority  and
approved  by  the  European  Commission.  In  addition,  in  2016,  the  European
Union  adopted  legislation  on  governance  and  control  of  the  production  and
use of benchmark indices. The Benchmark Regulation became effective in the
European  Union  beginning  in  2018,  and  Nasdaq  must  be  in  compliance
beginning  January  1,  2026  in  relation  to  benchmarks  provided  by  non-
European Nasdaq entities. As the regulatory environment continues to evolve
and related opportunities arise, we intend to continue developing our products
and  services  to  ensure  that  the  exchanges  and  clearinghouse  that  comprise
Nasdaq Nordic and Nasdaq Baltic maintain favorable liquidity and offer fair
and efficient trading.

13

In addition, proposed rules under MiFID II and MiFIR rules are expected to
include provisions potentially impacting various parts of Nasdaq’s exchanges
and data business, including a proposal to establish a European consolidated
tape  of  pre-  and/or  post-trade  data.  The  final  rules  have  not  yet  been  issued,
and  therefore  we  cannot  be  certain  of  the  impact  on  Nasdaq  Europe’s
offerings.

with sufficient resources and powers to meet the exchange’s obligations.” That
requires  the  exchange  to,  among  other  things,  supervise  trading  and  price
information,  compliance  with  laws,  regulations  and  good  market  practice,
participant  compliance  with  trading  participation  rules,  financial  instrument
compliance  with  relevant  listing  rules  and  the  extent  to  which  issuers  meet
their obligation to submit regular financial information to relevant authorities.

The entities that operate trading venues in the Nordic and Baltic countries are
each subject to local regulations. As a result, we have a strong local presence
in  each  jurisdiction  in  which  we  operate  regulated  businesses.  The  regulated
entities  have  decision-making  power  and  can  adopt  policies  and  procedures
and  retain  resources  to  manage  all  operations  subject  to  their  license.  In
Sweden, general supervision of the Nasdaq Stockholm exchange is carried out
by  the  SFSA,  while  Nasdaq  Clearing’s  role  as  CCP  in  the  clearing  of
derivatives  is  supervised  by  the  SFSA  and  overseen  by  the  Swedish  central
bank  (Riksbanken).  Additionally,  as  a  function  of  the  Swedish  two-tier
supervisory model, certain surveillance of the exchange market is carried out
by the Nasdaq Stockholm exchange, through its surveillance function.

Nasdaq Stockholm’s exchange activities are regulated primarily by the SSMA,
which  implements  MiFID  II  into  Swedish  law  and  which  sets  up  basic
requirements  for  the  board  of  directors  of  the  exchange  and  the  exchange’s
share  capital,  and  which  also  outlines  the  conditions  on  which  exchange
licenses  are  issued.  The  SSMA  also  provides  that  any  changes  to  the
exchange’s  articles  of  association  following  initial  registration  must  be
approved  by  the  SFSA.  Nasdaq  Clearing  holds  the  license  as  a  CCP  under
EMIR.

The SSMA requires exchanges to conduct their activities in an honest, fair and
professional manner, and in such a way as to maintain public confidence in the
securities  markets.  When  operating  a  regulated  market,  an  exchange  must
apply  the  principles  of  free  access  (i.e.,  that  each  person  which  meets  the
requirements  established  by  law  and  by  the  exchange  may  participate  in
trading), neutrality (i.e., that the exchange’s rules for the regulated market are
applied  in  a  consistent  manner  to  all  those  who  participate  in  trading)  and
transparency  (i.e.,  that  the  participants  must  be  given  prompt,  simultaneous
and correct information concerning trading and that the general public must be
given the opportunity to access this information). Additionally, the exchange
operator must identify and manage the risks that may arise in its operations,
use secure technical systems and identify and handle the conflicts of interest
that may arise between the exchange or its owners’ interests and the interest in
safeguarding effective risk management and secure technical systems. Similar
requirements are set up by EMIR in relation to clearing operations.

The SSMA also contains the framework for both the SFSA’s supervisory work
in relation to exchanges and clearinghouses and the surveillance to be carried
out by the exchanges themselves. The latter includes the requirement that an
exchange should have “an independent surveillance function

Due to the underlying EU regulation, the regulatory requirements in the other
Nordic and Baltic countries in which a Nasdaq entity has a trading venue are
similar  to  the  requirements  in  Sweden  described  above.  The  supervisory
authorities in Sweden, Iceland, Denmark, Finland and Norway all cooperate to
safeguard  effective  and  comprehensive  supervision  of 
the  exchanges
comprising  Nasdaq  Nordic  and  the  systems  operated  by  it,  and  to  ensure  a
common supervisory approach.

Nasdaq  owns  a  central  securities  depository  known  as  Nasdaq  CSD  SE
(Societas Europaea)¸ that provides notary, settlement, central maintenance and
other  services  in  the  Baltic  countries  and  in  Iceland.  Nasdaq  CSD  SE  is
licensed under the European Central Securities Depositories Regulation and is
supervised by the respective regulatory institutions.

We operate a licensed exchange, Nasdaq Oslo ASA, in Norway that trades and
lists commodity derivatives. Although Norway is not a member of the EU, as
a  result  of  the  European  Economic  Area,  or  EEA,  agreement  (entered  into
between  the  EU  and  European  Free  Trade  Association)  the  regulatory
environment  is  broadly  similar  to  what  applies  in  EU  member  states.  Since
Norway  has  adopted  legislation  mirroring  the  provisions  of  MiFID  II  and
MIFIR,  the  regulatory  environment  in  Norway  is  similar  to  Sweden.  The
Financial  Supervisory  Authority  of  Norway  supervises  the  Norwegian
exchange  on  an  autonomous  basis  and  the  Norwegian  exchange  also  has  a
separate  market  surveillance  function  overseen  by  the  Financial  Supervisory
Authority.

Confidence  in  capital  markets  is  paramount  for  trading  to  function  properly.
Nasdaq  Nordic  carries  out  market  surveillance  through  an  independent  unit
that  is  separate  from  the  business  operations.  The  surveillance  work  is
conceptually organized into two functions: one for the review and admission
of  listing  applications  and  surveillance  activities  related  to  issuers  (issuer
surveillance)  and  one  for  surveillance  of  trading  (trading  surveillance).  The
real-time trading surveillance for the Finnish, Icelandic, Danish and Swedish
markets  has  been  centralized  in  Stockholm.  In  addition,  there  are  designated
personnel  who  carry  out  surveillance  activities  at  Nasdaq  Oslo  and  the  three
Baltic  exchanges.  In  Finland,  Sweden  and  Estonia,  decisions  to  list  new
companies  on  the  main  market  are  made  by  listing  committees  that  have
external members in addition to members from each respective exchange and
in the other countries the decision is made either by the respective president of
the exchange or by the executive board.

14

If there is suspicion that a listed company or member has acted in breach of
exchange  regulations,  the  matter  is  handled  by  the  respective  surveillance
department.  Serious  breaches  are  considered  by  the  respective  disciplinary
committee  in  Denmark,  Finland,  Iceland,  Sweden  and  Norway.  Suspected
insider  trading  is  reported  to  the  appropriate  authorities  in  the  respective
country.

In  the  United  Kingdom,  The  Nasdaq  Stock  Market,  Nasdaq  Oslo  ASA,
Nasdaq  Stockholm  AB,  Nasdaq  Copenhagen  A/S,  and  Nasdaq  Helsinki  Ltd
are  each  subject  to  regulation  by  the  Financial  Conduct  Authority  as
“Recognised Overseas Investment Exchanges.” Nasdaq Clearing is registered
as  a  recognized  third  country  CCP  with  the  Bank  of  England  under  the
temporary recognition regime. The registration became effective on December
31,  2020,  and  lasts  for  four  years  (which  may  be  extended  further),  during
which  time  Nasdaq  Clearing  may  continue  to  act  as  a  CCP  vis-a-vis  UK
members.  Nasdaq  Clearing  has  submitted  its  application  for  permanent
recognition and is awaiting further information as to the process and timeline
from the Bank of England.

Human Capital Management

Nasdaq  has  continued  to  strengthen  our  commitment  to,  and  investment  in,
attracting, retaining, developing and motivating our employees during 2023.

We  also  continued  our  efforts  to  create  a  diverse  and  inclusive  work
environment of equal opportunity, where employees feel respected and valued
for 
its  employees  have
opportunities to make positive contributions to our local communities.

their  contributions,  and  where  Nasdaq  and 

As  of  December  31,  2023,  Nasdaq  had  8,525 full  and  part-time  employees,
including employees of non-wholly owned consolidated subsidiaries.

Employee Safety

We are committed to ensuring the safety and well-being of our employees and
stakeholders, and complying with local government regulations in the areas in
which  we  operate.  We  have  adopted  a  hybrid  work  environment,  where
employees both work in our offices and from home, which we believe enables
a  more  consistent  in-office  experience,  greater  levels  of  connectivity  and
engagement, and an improved sense of community across Nasdaq.

Talent Management and Development

We continued to increase our efforts in attracting and retaining our employees.
Nasdaq  seeks  to  hire  world-class,  innovative,  and  diverse  talent  across  the
globe.

In  2023,  our  internal  employee  engagement  score,  based  on  our  biannual
employee engagement surveys, maintained its record high rating achieved in
2022. Our workforce voluntary attrition rate during 2023 was approximately
7.3%, which was nearly four percentage points lower than 2022.

Our  Talent  Attraction  Team  focused  on  strategic  marketing  and  branding  to
position  Nasdaq  as  a  leading  employer  of  choice  for  talent  in  our  industry,
helping to increase our pool of top candidates for open positions, particularly
diverse candidates. We ran targeted attraction campaigns in our major markets
using (with permission) local employee stories and photos, and partnered with
diverse talent organizations, such as the National Society of Black Engineers,
AfroTech,  Sistas  in  Sales,  Women  in  Tech,  Information  Technology  Senior
Management  Forum  and  the  Society  of  Hispanic  Professional  Engineers  to
help  improve  brand  awareness  of  Nasdaq  and  attract  a  higher  number  of
diverse candidates for potential hiring, as compared to 2022.

During 2023, we continued a series called the Manager Forum, facilitated by
our  CEO  and  other  senior  and  mid-career  leaders,  to  engage  managers  in
sustained  leadership  development,  alongside  our  existing  formal  leadership
development curriculum.

Our  artificial  intelligence-driven  career  development  platform,  the  Career
Hub,  matches  employees,  based  on  their  career  aspirations,  to  internal
training,  potential  mentors,  short-term  projects  and  full-time  internal  roles.
This  helped  us  again  increase  our  career  satisfaction  scores  in  our  biannual
employee engagement survey and supported employee retention.

We  have  invested  in  professional  development  for  our  employees,  including
offering  access  to  more  than  26,000  professional  development  programs;
providing  tuition  assistance  to  employees  enrolled  in  degree-granting
academic  programs;  holding  internal  career  fairs  and  career  development
programs;  connecting  employees  to  our  formal  mentoring  programs  and
providing  one-on-one  professional  coaching  opportunities.  We  welcomed
approximately 150 interns to Nasdaq during 2023.

To  reward  our  employees  at  various  stages  of  their  tenure  with  Nasdaq,  we
continued our anniversary recognition program that includes Nasdaq-branded
merchandise, and, for major milestones, recognition on our Nasdaq Tower in
Times  Square.  Additionally,  our  peer-to-peer  employee  recognition  program
rewards employees and highlights recognized employees on our internal social
media channels, further amplifying the recognition.

A Culture of Inclusion

At  Nasdaq,  three  pillars  guide  our  diversity,  equity  and  inclusion  efforts:
Workforce,  Workplace  and  Marketplace.  Workforce  seeks  to  ensure  that  our
employee  population  is  representative  of  the  communities  in  which  we
operate. Workplace seeks to create a positive, equitable workplace experience
for  all  employees  of  Nasdaq.  Marketplace  aims  to  positively  influence  our
peers  in  the  capital  market  ecosystem  and  invest  in  the  local  communities
where we operate.

15

Nasdaq  sponsors  twelve  employee-led  internal  affinity  networks.  These
networks include more than 2,900 members, representing approximately 36%
of  our  eligible  employees  and  contractors.  Nasdaq’s  Employee  Networks
support  the  diverse  communities  that  comprise  our  workforce,  including
Black,  Asian  American,  Hispanic,  LGBTQ+,  female,  disabled,  veteran,  and
parent/caregiver  communities.  Nasdaq’s  Employee  Networks  provide  both
formal and informal development programs and guidance for their members.
The networks benefit the entire Nasdaq workforce through educational events,
guest speakers, and volunteering opportunities.

Nasdaq  regularly  and  proactively  reviews  and  monitors  diversity  data  across
its businesses, including workforce composition, talent pipeline, and sentiment
by  business  unit.  In  2023,  we  expanded  our  Inclusion  Learning  Library,
offering two new courses aimed at helping managers lead more inclusively in
addition to our two fundamental diversity trainings. We also added customized
developmental  programs  for  underrepresented  talent,  including  executive
mentoring  and  accelerated  leadership  development  programs.  In  2023,  we
graduated  our  first  class  of  Acclerate(her),  which  is  our  high-potential
leadership  program  for  our  female  employees  to  enhance  their  skills  and
increase advancement opportunities. Additionally, we expanded our leadership
development  program  aimed  to  help  foster  community,  understanding  and
develop 
from  diverse
backgrounds.

leadership  skills 

for  employees 

fundamental 

Our dedication to fostering diversity extends globally, as Nasdaq was included
in  the  2023  Seramount  Alliance  for  Global  Inclusion  and  was  named  to  the
2023 Seramount Global Inclusion Index. We received acknowledgement from
the Human Rights Campaign, for the fifth consecutive year, underscoring our
commitment to LGBTQ+ employees.

Workplace Demographics

Our global female employee base in 2023 was approximately 35%, including
the  employees  that  joined  us  from  Adenza  in  November  2023.  Our  minority
representation  in  the  U.S.,  which  includes  Asian,  Black/African  American,
Hispanic/Latino, Multiracial, Native American, Native Hawaiian, and Pacific
Islander employees, was 32% in 2023, including Adenza employees.

Gender  and  Ethnicity  Performance  Data  as  of  December  31,  2023  and
2022

Gender:

We  continue  to  seek  to  monitor  our  diversity  metrics,  both  through
development  of  our  internal  talent  pool  and  by  focusing  on  interviewing
diverse  candidates  externally  for  new  employment  opportunities.  During  our
annual  executive  succession  planning  exercise  with  our  Board  of  Directors,
we realized a 3% increase, as compared to 2022, in the diversity of our senior
executive  succession  candidate  pool  (considering  gender,  race  and  LGBTQ+
status) due to a focus by our senior executives on identifying and cultivating
talent deeper in their organizations.

Nasdaq  monitors  our  employee  sentiment  semi-annually,  and  has  a  92%
average  participation  rate  in  these  employee  surveys.  We  also  introduced  a
new Inclusion Index that helps us to understand where in the organization we
may  have  employees  having  a  differing  experience  from  one  another,  thus
allowing  us  to  seek  to  understand  root  causes  and  explore  and  implement
solutions.

In  2023,  Nasdaq  was  honored  with  multiple  awards,  affirming  our
commitment  to  excellence  and  inclusion  in  human  capital  management.
Nasdaq  was  named  to  Seramount  100  Best  Companies,  the  2023  Seramount
Inclusion  Index  and  the  ParityLIST  for  both  Women  and  People  of  Color  to
Advance.

16

Finally, to increase transparency of our workforce, Nasdaq publishes statistics
on  the  composition  of  its  own  global  workforce  by  gender,  and  of  its  U.S.
workforce  by  gender,  race  and  ethnicity,  in  our  U.S.  EEO-1  report  and  our
Sustainability Report, which are available on our website.

Compensation and Benefits

Our  Total  Rewards  program  is  designed  to  attract,  retain,  and  empower
employees  to  successfully  execute  our  growth  strategy  and  our  mission  to
better  serve  our  clients.  Our  comprehensive  Total  Rewards  program  reflects
our commitment to protecting our employees’ health, well-being and financial
security.

compensation  programs 

Our  pay-for-performance 
includes  market-
competitive  base  salaries,  annual  bonuses  or  sales  commissions,  and  equity
grants. The  majority  of  our  employees  are  granted  annual,  long-term  equity
awards, enabling them to be owners of the company, committed to our long-
term  success  and  aligning  their  interests  with  the  short-term  and  long-term
interests of our shareholders.

Beyond compensation, we offer a suite of programs, benefits, perquisites, and
resources.  Our  core  benefits  include  health  (medical,  dental,  and  vision)  and
risk  insurances  (life  and  disability),  retirement  plans,  and  an  employee  stock
purchase  plan.  We  also  offer  robust  paid  time-off  benefits  which  include
vacation, incidental sick days and parental leave.

In  addition,  all  Nasdaq  employees,  regardless  of  their  location  in  any  of  our
global offices, are offered paid time off for key life events. Beginning January
1, 2024, we announced a new flexible time off policy for our North American
employees.  These  programs,  coupled  with  our  hybrid  work  schedules,  are
designed to meet the diverse needs of our work force.

In  2023,  we  recognized  the  importance  of  well-being  in  the  overall
performance of our workforce. We introduced toolkits and trainings to help to
support both our leaders and employees.

Community Involvement

We  are  committed  to  creating  lasting,  positive  change  within  our  Company
and  the  communities  we  serve.  Our  employees  take  pride  in  being  active  in
our communities. Through our Nasdaq GoodWorks Corporate Responsibility
Program, we have committed to supporting the communities in which we live
and work by providing eligible full and part-time employees two paid days off
per  year  to  volunteer.  We  also  match  charitable  donations  of  all  Nasdaq
employees and contractors up to $1,000, or more in certain circumstances, per
calendar  year.  In  2023,  Nasdaq  employees  raised  over  $450,000,  including
donations and matches, supporting almost 600 charities worldwide.

* In the charts above, not disclosed percentage includes employees that have

chosen not to disclose and race and ethnicities that are less than 0.3%.

In  2023,  we  conducted  a  pay  equity  analysis,  which  supplements  our  annual
multifaceted  compensation  review  program,  successfully  concluding  that
review in the fourth quarter of the year. Our pay equity analysis for 2024 has
already  begun  as  part  of  the  annual  compensation  review  program  to  be
completed in the same cycle next year.

17

Nasdaq’s  “Purpose”  comprises  our  philanthropic,  community  outreach,
entrepreneurial support and employee volunteerism programs, all designed to
leverage  our  unique  place  at  the  center  of  capital  creation,  markets,  and
technology  and  drive  stronger  economies,  more  equitable  opportunities  and
contribute to a more sustainable world.

During 2023, Nasdaq held its third annual “Purpose Week,” which is a week
dedicated  to  celebrating  and  advancing  economic  progress  for  all.  Purpose
included  a  series  of  company-wide  webinars,  volunteer
Week  2023 
opportunities,  and  global  activities  involving  and  recognizing  company
employees.  Purpose  Week  also  included  a  series  of  workshops  with  Nasdaq
Foundation  partnership  organizations.  We  hosted  two  investor  education
workshops for employees.

Our inaugural Purpose Forum convened thought leaders, change makers, and
innovators  from  around  the  world  to  discuss  how  Nasdaq  can  empower
individuals  to  embrace  their  purpose,  advance  their  economic  growth  and
reach their full potential.

The  Nasdaq  Foundation  works  with  organizations  that  promote  and  support
under-resourced  communities  by  reimagining  investor  engagement  and
equipping  communities  with  the  financial  knowledge  needed  to  share  in  the
wealth that markets create.

During 2023, the Nasdaq Foundation provided 13 grants to organizations that
seek to fulfill that mission. These grants were awarded to, among others: Defy
Ventures,  which  provides  entrepreneur  training  for  formerly  incarcerated
Black and indigenous men and women and people of color; the GO Project for
the GO Families Financial Literacy Workshop Series in New York City; and
the  Global  Entrepreneur  Network,  in  partnership  with  Hello  Alice,  for  the
Equitable  Access  Program  aimed  at  enhancing  credit  access  and  financial
education to underserved entrepreneurs facing credit challenges.

Nasdaq Website and Availability of SEC Filings

We file periodic reports, proxy statements and other information with the SEC.
The  SEC  maintains  a  website  that  contains  reports,  proxy  and  information
statements, and other information regarding issuers that file electronically with
the SEC. The address of that site is www.sec.gov.

Our website is http://ir.nasdaq.com. Information on our website is not a part of
this Form 10-K. We make available free of charge on our website, or provide a
link to, our Forms 10-K, Forms 10-Q and Forms 8-K and any amendments to
these documents, that are filed or furnished pursuant to Section 13(a) or 15(d)
of the Exchange Act as soon as reasonably practicable after we electronically
file such material with, or furnish it to, the SEC. To access these filings, go to
our website and click on “Financials” then click on “SEC Filings.”

Item 1A. Risk Factors

The risks and uncertainties described below are not the only ones facing us.
Additional  risks  and  uncertainties  not  presently  known  to  us  or  that  we
currently  believe  to  be  immaterial  may  also  adversely  affect  our  business.  If
any of the following risks actually occur, our business, financial condition, or
operating results could be adversely affected.

RISKS RELATED TO OUR BUSINESS AND INDUSTRY

Economic  conditions  and  market  factors,  which  are  beyond  our  control,
may adversely affect our business and financial condition.

Our  business  performance  is  impacted  by  a  number  of  factors,  including
general  economic  conditions,  current  or  expected  inflation,  interest  rate
fluctuations,  market  volatility,  changes  in  investment  patterns  and  priorities,
pandemics  and  other  factors  that  are  generally  beyond  our  control.  To  the
extent that global or national economic conditions weaken and result in slower
growth  or  recessions,  our  business  may  be  negatively  impacted.  Adverse
market  conditions  could  reduce  customer  demand  for  our  services  and  the
ability  of  our  customers,  lenders  and  other  counterparties  to  meet  their
obligations  to  us.  Poor  economic  conditions  may  result  in  a  reduction  in  the
demand for our products and services, including our market technology, fraud
detection,  AML  and  surveillance  solutions,  data,  indices  and  corporate
solutions, or could result in a decline in the number of IPOs, reduced trading
volumes  or  values  and  deterioration  of  the  economic  welfare  of  our  listed
companies, which could cause an increase in delistings.

Trading volumes and values are driven primarily by general market conditions
and  declines  in  trading  volumes  or  values  may  affect  our  market  share  and
impact  our  pricing.  In  addition,  our  Market  Services  businesses  receive
revenues  from  a  relatively  small  number  of  customers  concentrated  in  the
financial  industry,  so  any  event  that  impacts  one  or  more  customers  or  the
financial industry in general could impact our revenues.

The number of listings on our markets is primarily influenced by factors such
as  investor  demand,  the  global  economy,  available  sources  of  financing,  and
tax and regulatory policies. Adverse conditions may jeopardize the ability of
our listed companies to comply with the continued listing requirements of our
exchanges, or reduce the number of issuers launching IPOs, including SPACs,
and direct listings. The number of IPOs on our exchanges decreased in both
2023 and 2022, and the number of delistings increased in 2023.

Our  Capital  Access  Platforms  revenues  may  be  significantly  affected  by
global  economic  conditions.  Professional  subscriptions  to  our  data  products
are  at  risk  if  staff  reductions  occur  in  financial  services  companies  or  if  our
customers  consolidate,  which  could  result  in  significant  reductions  in  our
professional  user  revenue  or  expose  us  to  increased  risks  relating  to
dependence on a smaller number of

18

customers. In addition, adverse market conditions may cause reductions in the
number  of  non-professional  investors  with  investments  in  the  market  and  in
ETP  AUM  tracking  Nasdaq  indices  as  well  as  trading  in  futures  linked  to
Nasdaq indices.

There  may  be  less  demand  for  our  analytics,  corporate  solutions,  market
technology and risk and regulatory products and services if global economic
conditions remain weak. Our customers historically reduce purchases of new
services  and  technology  when  growth  rates  decline,  thereby  diminishing  our
opportunities  to  sell  new  products  and  services  or  upgrade  existing  products
and services.

Additionally,  during  a  global  economic  downturn,  or  periods  of  economic,
political or regulatory uncertainty, our sales cycle may become longer or more
unpredictable due to customer budget constraints or unplanned administrative
delays to approve purchases.

A reduction in trading volumes or values, market share of trading, the number
of  our  listed  companies,  or  demand  for  our  products  and  services  due  to
economic  conditions  or  other  market  factors  could  adversely  affect  our
business, financial condition and operating results.

The industries we operate in are highly competitive.

We  face  significant  competition  in  our  Capital  Access  Platforms,  Financial
Technology and Market Services segments from other market participants. We
face intense competition from other exchanges and markets for market share
of  trading  activity  and  listings.  This  competition  includes  both  product  and
price competition.

The  liberalization  and  globalization  of  world  markets  has  resulted  in  greater
mobility  of  capital,  greater  international  participation  in  local  markets  and
more  competition.  As  a  result,  both  in  the  U.S.  and  in  other  countries,  the
competition  among  exchanges  and  other  execution  venues  has  become  more
intense.  Marketplaces  in  both  Europe  and  the  U.S.  have  also  merged  to
achieve greater economies of scale and scope.

Regulatory  changes  also  have  facilitated  the  entry  of  new  participants  in  the
European  Union  that  compete  with  our  European  markets.  The  regulatory
environment,  both  in  the  U.S.  and  in  Europe,  is  structured  to  maintain  this
environment of intense competition. In addition, a high proportion of business
in  the  securities  markets  is  becoming  concentrated  in  a  smaller  number  of
institutions and our revenue may therefore become concentrated in a smaller
number of customers.

We also compete globally with other regulated exchanges and markets, ATSs,
MTFs  and  other  traditional  and  non-traditional  execution  venues.  Some  of
these  competitors  also  are  our  customers.  Competitors  may  develop  market
trading  platforms  that  are  more  competitive  than  ours.  Competitors  may
leverage data more effectively or enter into strategic partnerships, mergers or
acquisitions  that  could  make  their  trading,  listings,  clearing,  data  or
technology businesses more competitive than ours.

We face intense price competition in all areas of our business. In particular, the
trading  industry  is  characterized  by  price  competition.  We  have  in  the  past
lowered  prices,  and  in  the  U.S.,  increased  rebates  for  trade  executions  to
attempt  to  gain  or  maintain  market  share.  These  strategies  have  not  always
been  successful  and  have  at  times  hurt  operating  performance.  Additionally,
we  have  also  been,  and  may  once  again  be,  required  to  adjust  pricing  to
respond  to  actions  by  competitors  and  new  entrants,  or  due  to  new  SEC
regulations, which could adversely impact operating results. We also compete
with  respect  to  the  pricing  of  data  products  and  with  respect  to  products  for
pre-trade book data and for post-trade last sale data.

If  we  are  unable  to  compete  successfully  in  the  industries  in  which  we  do
business,  our  business,  financial  condition  and  operating  results  will  be
adversely affected.

System limitations or failures could harm our business.

Our  businesses  depend  on  the  integrity  and  performance  of  the  technology,
computer and communications systems supporting them. If new systems fail
to  operate  as  intended  or  our  existing  systems  cannot  expand  to  cope  with
increased  demand  or  otherwise  fail  to  perform,  we  could  experience
unanticipated disruptions in service, slower response times and delays in the
introduction  of  new  products  and  services.  We  could  experience  a  systems
failure due to human error by our employees, contractors or vendors, electrical
or telecommunications failures or disruptions, hardware or software failures or
defects,  cyberattacks,  sabotage  or  similar  unexpected  events.  These
consequences could result in service outages, lower trading volumes or values,
financial  losses,  decreased  customer  satisfaction,  litigation  and  regulatory
sanctions.  Our  markets  and  the  markets  that  rely  on  our  technology  have
experienced systems failures and delays in the past and we could experience
future systems failures and delays.

Although  we  currently  maintain  and  expect  to  maintain  multiple  computer
facilities,  and  leverage  third  party  cloud  providers,  that  are  designed  to
provide redundancy and back-up to reduce the risk of system disruptions and
have facilities in place that are expected to maintain service during a system
disruption,  such  systems  and  facilities  may  prove  inadequate.  If  trading
volumes  increase  unexpectedly  or  other  unanticipated  events  occur,  we  may
need  to  expand  and  upgrade  our  technology,  transaction  processing  systems
and  network  infrastructure.  We  do  not  know  whether  we  will  be  able  to
accurately project the rate, timing or cost of any volume increases, or expand
and upgrade our systems and infrastructure to accommodate any increases in a
timely manner.

19

While  we  have  programs  in  place  to  identify  and  minimize  our  exposure  to
vulnerabilities and work in collaboration with the technology industry to share
corrective measures with our business partners, we cannot guarantee that such
events  will  not  occur  in  the  future.  Any  system  issue  that  causes  an
interruption  in  services,  decreases  the  responsiveness  of  our  services  or
otherwise affects our services could impair our reputation, damage our brand
name  and  negatively  impact  our  business,  financial  condition  and  operating
results.

We must continue to introduce new products, initiatives and enhancements
to maintain our competitive position.

We intend to launch new products and initiatives and continue to explore and
pursue  opportunities  to  strengthen  our  business  and  grow  our  company.  We
may  spend  substantial  time  and  money  developing  new  products,  initiatives
and enhancements to existing products. If these products and initiatives are not
successful  or  their  launches  are  delayed,  we  may  not  be  able  to  offset  their
costs, which could have an adverse effect on our business, financial condition
and operating results.

In  our  technology  operations,  we  have  invested  substantial  amounts  in  the
development  of  system  platforms,  the  rollout  of  our  platforms  and  the
adoption  of  new  technologies,  including  cloud-based  infrastructure  and
artificial  intelligence  for  certain  of  our  offerings.  Although  investments  are
carefully  planned,  there  can  be  no  assurance  that  the  demand  for  such
platforms  or  technologies  will  justify  the  related  investments.  If  we  fail  to
generate adequate revenue from planned system platforms or the adoption of
new  technologies,  or  if  we  fail  to  do  so  within  the  envisioned  timeframe,  it
could  have  an  adverse  effect  on  our  results  of  operations  and  financial
condition.  In  addition,  clients  may  delay  purchases  in  anticipation  of  new
products  or  enhancements.  We  may  allocate  significant  amounts  of  cash  and
other resources to product technologies or business models for which market
demand  is  lower  than  anticipated.  In  addition,  the  introduction  of  new
products  by  competitors,  the  emergence  of  new  industry  standards  or  the
development of entirely new technologies to replace existing product offerings
could render our existing or future products obsolete.

A  decline  in  trading  and  clearing  volumes  or  values  or  market  share  will
decrease our trading and clearing revenues.

Trading  and  clearing  volumes  and  values  are  directly  affected  by  economic,
political  and  market  conditions,  broad  trends  in  business  and  finance,
unforeseen  market  closures  or  other  disruptions  in  trading,  the  level  and
volatility  of  interest  rates,  inflation,  changes  in  price  levels  of  securities  and
the  overall  level  of  investor  confidence.  Over  the  past  several  years,  trading
and  clearing  volumes  and  values  across  our  markets  have  fluctuated
significantly  depending  on  market  conditions  and  other  factors  beyond  our
control. Because a significant percentage of our revenues is tied directly to the
volume or value of securities traded and cleared on our markets, it is

likely that a general decline in trading and clearing volumes or values would
lower revenues and may adversely affect our operating results if we are unable
to  offset  falling  volumes  or  values  through  pricing  changes.  Declines  in
trading and clearing volumes or values may also impact our market share or
pricing structures and adversely affect our business and financial condition.

If our total market share in securities decreases relative to our competitors, our
venues may be viewed as less attractive sources of liquidity. If our exchanges
are  perceived  to  be  less  liquid,  then  our  business,  financial  condition  and
operating results could be adversely affected.

Since  some  of  our  exchanges  offer  clearing  services  in  addition  to  trading
services,  a  decline  in  market  share  of  trading  could  lead  to  a  decline  in
clearing and depository revenues. Declines in market share also could result in
issuers  viewing  the  value  of  a  listing  on  our  exchanges  as  less  attractive,
thereby  adversely  affecting  our  listing  business.  Finally,  declines  in  market
share  of  Nasdaq-listed  securities,  or  recently  adopted  SEC  rules  and
regulations,  could  lower  The  Nasdaq  Stock  Market’s  share  of  tape  pool
revenues under the consolidated data plans, thereby reducing the revenues of
our U.S. Tape plans business.

Our  role  in  the  global  marketplace  positions  us  at  greater  risk  for  a
cyberattack.

Our  systems  and  operations  are  vulnerable  to  damage  or  disruption  from
security breaches. Due to our adoption of a hybrid work environment, we have
a broader and more distributed network footprint and increased reliance on the
home  networks  of  employees,  and  such  remote  work  may  cause  heightened
cybersecurity and operational risks. Some of these threats include attacks from
foreign governments, hacktivists, insiders and criminal organizations. Foreign
governments  may  seek  to  obtain  a  foothold  in  U.S.  critical  infrastructure,
hacktivists may seek  to  deploy  denial  of  service  attacks  to  bring  attention  to
their cause, insiders may pose a risk of human error or malicious activity and
criminal  organizations  may  seek  to  profit  from  stolen  data.  Computer
malware,  such  as  viruses  and  worms,  also  continue  to  be  a  threat  with
ransomware increasingly being used by criminals to extort money. Given our
position  in  the  global  securities  industry,  we  may  be  more  likely  than  other
companies to be a direct target, or an indirect casualty, of such events.

While we continue to employ and invest additional resources to monitor our
systems and protect our infrastructure, these measures may prove insufficient
depending  upon  the  attack  or  threat  posed.  Any  system  issue,  whether  as  a
result of an intentional breach, collateral damage from a new virus or a non-
malicious act, the use of artificial intelligence by bad actors, including the use
of such tools to engage in social engineering or similar activities, or due to a
cybersecurity  breach  of  a  customer  that  results  in  a  loss  of  our  data  or
compromises  our  systems  or  those  of  our  other  customers  utilizing  the  same
products,  could  damage  our  reputation  and  result  in:  a  loss  of  customers;
disrupted  customer  relationships;  the  loss  of  our  intellectual  property  or
sensitive

20

data;  lower  trading  volumes  or  values,  significant  liabilities,  litigation  or
regulatory  fines  or  otherwise  have  a  negative  impact  on  our  business,  our
products  and  services,  financial  condition  and  operating  results.  Further,
cybersecurity  incidents  that  impact  our  vendors  and  other  third  parties  that
support  our  organization  and  industry  could  directly  or  indirectly  impact  us.
For  example,  a  data  breach  involving  one  of  our  vendors  occurred  in  2023,
and  was  identified  and  mitigated  by  the  vendor  before  material  damage  to
Nasdaq  occurred.  There  can  be  no  assurance  we  will  be  able  to  identify  and
mitigate every incident involving cybersecurity attacks, breaches or incidents.
A system breach may go undetected for an extended period of time.

address  our  regulatory  responsibilities,  and  our  business  will  be  negatively
affected if our platforms or the technology solutions we sell to our customers
fail  to  function  as  expected.  If  we  are  unable  to  develop  our  platforms  to
include  other  products  and  markets,  or  if  our  platforms  do  not  have  the
required functionality, performance, capacity, reliability and speed required by
our business and our regulators, as well as by our customers, we may not be
able  to  compete  successfully.  Further,  our  failure  to  anticipate  or  respond
adequately  to  changes  in  technology  and  customer  preferences  or  any
significant  delays  in  product  development  efforts,  could  have  a  material
adverse effect on our business, financial condition and operating results.

cybersecurity 

Expanded 
cybersecurity
regulations,  and 
infrastructure  and  compliance  costs,  may  adversely  impact  our  results  of
operations.

increased 

As cybersecurity threats continue to increase in frequency and sophistication,
and  as  the  domestic  and  international  regulatory  and  compliance  structure
related  to  information,  cybersecurity,  data  privacy  and  data  usage  becomes
increasingly complex and exacting, we may be required to devote significant
additional  resources  to  strengthen  our  cybersecurity  capabilities,  and  to
identify and remediate any security vulnerabilities. Compliance with laws and
regulations concerning cybersecurity, data privacy and data usage could result
in significant expense, and any failure to comply could result in proceedings
against us by regulatory authorities or other third parties. Costs for bolstering
cybersecurity  capabilities,  and  increased  cybersecurity  and  data  privacy
compliance  costs,  could  adversely  impact  our  business,  financial  condition
and  operating  results.  Additionally,  our  clients  increasingly  demand  rigorous
contractual,  certification  and  audit  provisions  regarding cybersecurity,  data
protection  and  data  usage,  which  may  also  increase  our  overall  compliance
burden and costs in meeting such obligations.

The  success  of  our  business  depends  on  our  ability  to  keep  up  with  rapid
technological  and  other  competitive  changes  affecting  our  industry.
Specifically, we must complete development of, successfully implement and
maintain  platforms  that  have  the  functionality,  performance,  capacity,
reliability and speed required by our business and our regulators, as well as
by our customers.

industry 

evolving 

standards, 

regulatory 

The  markets  in  which  we  compete  are  characterized  by  rapidly  changing
technology, 
frequent
and 
enhancements to existing products and services, the adoption of new services
and  products  and  changing  customer  demands.  We  are  reliant  on  our
customers that purchase our on-premise solutions to maintain a certain level of
network infrastructure for our products to operate and to allow for our support
of  those  products,  and  there  is  no  assurance  that  a  customer  will  implement
such measures. We may not be able to keep up with rapid technological and
other  competitive  changes  affecting  our  industry.  For  example,  we  must
continue to enhance our platforms to remain competitive as well as to

Our  artificial  intelligence  initiatives  under  development  and  the  use  of
artificial 
in  certain  of  our  existing  products  may  be
unsuccessful and may give rise to various risks, which could adversely affect
our business, reputation, or operating results.

intelligence 

We  are  making  significant  investments  in  artificial  intelligence,  or  AI,
including  generative  AI,  to,  among  other  things,  develop  new  products  or
features for our existing products, including our anti-financial crime, investor
relations  and  investment  analytics  solutions,  and  to  enhance  and  refine  our
internal business operations. As  AI  is  a  new  and  evolving  technology  in  the
early  stages  of  commercial  use,  there  are  significant  risks  involved  in  the
development and deployment of AI, and there can be no assurance that the use
of  AI  will  enhance  our  products  or  services  or  augment  our  business  or
operating results. Market acceptance of AI technologies is uncertain, and we
may  be  unsuccessful  in  our  product  development  efforts.  Moreover,  our  AI-
related  product  initiatives  and  offerings,  or  use  in  our  internal  business
operations,  may  give  rise  to  risks  related  to  harmful  content,  accuracy,  bias,
discrimination,  intellectual  property  infringement,  the  ability  to  obtain
intellectual property protection, misappropriation or leakage, defamation, data
privacy, and cybersecurity, among others. In addition, these risks include the
possibility of new or enhanced laws or regulations, for which compliance may
be  costly  and  burdensome  or  involve  litigation  or  other  legal  liability,  or
additional oversight, audits or enforcement under existing laws or regulations.
The  use  of  AI  may  also  give  rise  to  ethical  concerns  or  negative  public
perceptions,  which  may  cause  brand  or  reputational  harm.  Additionally,  our
competitors  may  be  developing  their  own  AI  products  and  technologies,
which  may  be  superior  in  features  or  functionality,  or  cost,  to  our  offerings.
Any  of  these  factors  could  adversely  affect  our  business,  reputation,  or
operating results.

Failure to attract and retain key personnel may adversely affect our ability
to conduct our business.

Our future success depends, in large part, upon our ability to attract and retain
highly qualified and skilled professional personnel that can learn and embrace
new  technologies.  In  the  current  tight  labor  market,  we  have  intensified  our
efforts to recruit and retain talent. Competition for key personnel in

21

the  various  localities  and  business  segments  in  which  we  operate  is  intense.
We have, and may continue to, experience higher compensation costs to retain
personnel,  and  hire  new  talent,  that  may  not  be  offset  by  improved
productivity,  higher  revenues  or  increased  sales.  Our  ability  to  attract  and
retain  key  personnel,  in  particular  senior  officers  or  technology  personnel,
including from companies that we acquire, will be dependent on a number of
factors,  including  prevailing  market  conditions,  office/remote  working
arrangements  and  compensation  and  benefit  packages  offered  by  companies
competing  for  the  same  talent.  There  is  no  guarantee  that  we  will  have  the
continued service of key employees who we rely upon to execute our business
strategy  and  identify  and  pursue  strategic  opportunities  and  initiatives.  Our
ability to execute our business strategy could be impaired if we are unable to
replace such persons without incurring significant costs or in a timely manner
or at all.

Our  clearinghouse  operations  expose  us  to  risks,  including  credit  or
liquidity  risks 
include  defaults  by  clearing  members,  or
that  may 
insufficiencies in margins or default funds.

We are subject to risks relating to our operation of a clearinghouse, including
counterparty and liquidity risks, risk of defaults by clearing members and risks
associated  with  adequacy  of  the  customer  margin  and  of  default  funds.  Our
clearinghouse  operations  expose  us  to  counterparties  with  differing  risk
profiles. We may be adversely impacted by the financial distress or failure of a
clearing member, which may cause us negative financial impact, reputational
harm  or 
regulatory
enforcement actions.

regulatory  consequences, 

litigation  or 

including 

We  are  exposed  to  credit  risk  from  third  parties,  including  customers,
counterparties and clearing agents.

We  are  exposed  to  credit  risk  from  third  parties,  including  customers,
counterparties  and  clearing  agents.  These  parties  may  default  on  their
obligations  to  us  due  to  bankruptcy,  lack  of  liquidity,  operational  failure  or
other reasons.

We  clear  a  range  of  equity-related  and  fixed-income-related  derivative
products, commodities and resale and repurchase agreements. We assume the
counterparty risk for all transactions that are cleared through Nasdaq Clearing
on our markets and guarantee that our cleared contracts will be honored. We
enforce minimum financial and operational criteria for membership eligibility,
require members and investors to provide collateral, and maintain established
risk policies and procedures to ensure that the counterparty risks are properly
monitored  and  proactively  managed;  however,  none  of  these  measures
provides  absolute  assurance  against  experiencing  financial  losses  from
defaults by our counterparties on their obligations. No guarantee can be given
that  the  collateral  provided  will  at  all  times  be  sufficient.  Although  we
maintain clearing capital resources to serve as an additional layer of protection
to  help  ensure  that  we  are  able  to  meet  our  obligations,  these  resources  also
may not be sufficient.

We also have credit risk related to transaction and subscription-based revenues
that are billed to customers on a monthly or quarterly basis, in arrears.

Credit  losses  such  as  those  described  above  could  adversely  affect  our
consolidated financial position and results of operations.

Technology  issues  relating  to  our  role  as  exclusive  processor  for  Nasdaq-
listed stocks could affect our business.

Nasdaq,  as  technology  provider  to  the  UTP  Operating  Committee,  has
implemented  measures  to  enhance  the  resiliency  of  the  existing  processor
system.  Nasdaq  transferred  the  processor  technology  platform  to  our  INET
platform  and  this  migration  further  enhanced  the  resiliency  of  the  processor
systems.  However,  if  future  outages  occur  or  the  processor  systems  fail  to
function properly while we are operating the systems, it could have an adverse
effect on our business, reputation and financial condition.

Stagnation or decline in the listings market could have an adverse effect on
our revenues.

The  market  for  listings  is  dependent  on  the  prosperity  of  companies  and  the
availability  of  risk  capital.  A  stagnation  or  decline  in  the  number  of  new
listings,  or  an  increase  in  the  number  of  delistings,  on  The  Nasdaq  Stock
Market  and  the  Nasdaq  Nordic  and  Nasdaq  Baltic  exchanges  could  cause  a
decrease  in  revenues  for  future  years.  In  2023,  we  again  experienced  a
decrease  in  new  listings  from  IPOs,  including  SPACs,  and  an  increase  in
delistings.  A  prolonged  decrease  in  the  number  of  listings,  or  failure  of
existing  SPACs  to  successfully  complete  transactions  with  target  companies
and  dissolve,  could  negatively  impact  the  growth  of  our  revenues.  Our
Corporate  Solutions  business  is  also  impacted  by  declines  in  the  listings
market  or  increases  in  acquisitions  activity  as  there  may  be  fewer  publicly-
traded customers that need our products.

RISKS  RELATED  TO  TRANSACTIONAL  ACTIVITIES  AND
STRATEGIC RELATIONSHIPS

We may not be able to successfully integrate acquired businesses, which may
result in an inability to realize the anticipated benefits of our acquisitions.

We  must  rationalize,  coordinate  and  integrate  the  operations  of  our  acquired
businesses,  including  the  acquisition  of  Adenza,  which  was  completed  in
November  2023.  This  process  involves  complex  technological,  operational
and  personnel-related  challenges,  which  are  time-consuming  and  expensive
and may disrupt our business. The difficulties, costs and delays that could be
encountered may include:

• difficulties, costs or complications in combining the companies’ operations,
including  technology  platforms,  and  security  measures  and  infrastructure
that may need greater remediation than anticipated, which could lead to us
not  achieving  the  synergies  we  anticipate  or  customers  not  renewing  their
contracts with us as we migrate platforms;

22

• incompatibility of systems and operating methods;

• reliance on, or provision of, transition services;

• inability  to  use  capital  assets  efficiently  to  develop  the  business  of  the

combined company;

• difficulties of complying with government-imposed regulations in the U.S.

and abroad, which may be conflicting;

• resolving  possible  inconsistencies  in  standards,  controls,  procedures  and

policies, business cultures and compensation structures;

• the  diversion  of  management’s  attention  from  ongoing  business  concerns

and other strategic opportunities;

• difficulties in operating businesses we have not operated before;

• difficulties of integrating multiple acquired businesses simultaneously;

• the retention of key employees and management;

• the  implementation  of  disclosure  controls,  internal  controls  and  financial
reporting systems at non-U.S. subsidiaries to enable us to comply with U.S.
GAAP  and  U.S.  securities  laws  and  regulations,  including  the  Sarbanes-
Oxley Act of 2002, required as a result of our status as a reporting company
under the Exchange Act;

• the coordination of geographically separate organizations;

• the  coordination  and  consolidation  of  ongoing  and  future  research  and

development efforts;

• possible tax costs or inefficiencies associated with integrating the operations

of a combined company;

• pre-tax restructuring and revenue investment costs;

• the retention of strategic partners and attracting new strategic partners; and

• negative  impacts  on  employee  morale  and  performance  as  a  result  of  job

changes and reassignments.

Foreign  acquisitions,  or  acquisitions  involving  companies  with  numerous
foreign  subsidiaries,  involve  risks  in  addition  to  those  mentioned  above,
including  those  related  to  integration  of  operations  across  different  cultures
and  languages,  our  ability  to  enforce  contracts  in  various  jurisdictions,
currency  risks  and  the  particular  economic,  political  and  regulatory  risks
associated with specific countries. We may not be able to address these risks
successfully,  or  at  all,  without  incurring  significant  costs,  delays  or  other
operating  problems  that  could  disrupt  our  business  and  have  a  material
adverse effect on our financial condition.

For these reasons, we may not achieve the anticipated financial and strategic
benefits from our acquisitions and strategic initiatives. Any actual cost savings
and  synergies  may  be  lower  than  we  expect  and  may  take  a  longer  time  to
achieve than we anticipate, and we may fail to realize the anticipated benefits
of acquisitions.

We  rely  on  third  parties  to  perform  certain  functions,  and  our  business
could be adversely affected if these third parties fail to perform as expected
or experience service interruptions affecting our operations.

We  rely  on  third  parties  for  regulatory,  data  center,  cloud  computing,  data
storage  and  processing,  connectivity,  data  content,  clearing,  maintaining
markets and exchange liquidity and other services. Interruptions or delays in
services  from  our  third-party  providers  could  impair  the  delivery  of  our
services and harm our business. To the extent that any of our vendors or other
third-party  service  providers  experiences  difficulties  or  a  significant
disruption,  breach  or  outage,  materially  changes  their  business  relationship
with us or is unable for any reason to perform their obligations, including due
to  geopolitical  instability,  our  business  or  our  reputation  may  be  materially
adversely affected.

Our  access  to  cloud  service  provider  infrastructure  could  be  limited  by  a
number  of  events,  including  technical  or  infrastructure  failures,  natural
disasters  or  cybersecurity  attacks.  As  we  continue  to  grow  our  SaaS
businesses,  our  dependency  on  the  continuing  operation  and  availability  of
these cloud service providers increases. If our cloud services from third party
providers  are  unavailable  to  us  for  any  reason,  or  there  are  cloud  service
disruptions or a delay or inability to access our exchanges, platforms or certain
of our cloud products or features, such unavailability or delays may adversely
affect our clients, which could significantly impact our reputation, operations,
business, and financial results.

For example, in 2023, we continued to migrate our North American markets to
AWS  in  a  phased  approach,  as  we  added  two  additional  exchanges  to  our
cloud-enabled infrastructure. AWS operates a platform that we use to provide
services to our clients, and therefore we are vulnerable to service outages on
the AWS platform that affect Nasdaq workloads running or stored in the AWS
environment. If AWS does not deliver our system requirements on time, fails
to  provide  maintenance  and  support  to  our  specifications  or  a  migration
experiences integration challenges, the successful migration of our exchanges
to  the  AWS  cloud  platform  may  be  significantly  delayed,  which  may
adversely affect our reputation and financial results.

We also rely on members of our trading community to maintain markets and
add  liquidity.  To  the  extent  that  any  of  our  largest  members  experience
difficulties, materially change their business relationship with us or are unable
for  any  reason  to  perform  market  making  activities,  our  business  or  our
reputation may be materially adversely affected.

23

We  may  be  required  to  recognize  impairments  of  our  goodwill,  intangible
assets or other long-lived assets in the future.

Our  business  acquisitions  typically  result  in  the  recording  of  goodwill  and
intangible  assets,  and  the  recorded  values  of  those  assets  may  become
impaired  in  the  future.  As  of  December  31,  2023,  goodwill  totaled  $14.1
billion  and  intangible  assets,  net  of  accumulated  amortization,  totaled  $7.4
billion. The determination of the value of such goodwill and intangible assets
requires  management  to  make  estimates  and  assumptions  that  affect  our
consolidated financial statements.

We  assess  goodwill  and  intangible  assets,  as  well  as  other  long-lived  assets,
including  equity  method  investments,  equity  securities,  and  property  and
equipment, for potential impairment on an annual basis or more frequently if
indicators  of  impairment  arise.  We  estimate  the  fair  value  of  such  assets  by
assessing  many  factors,  including  historical  performance  and  projected  cash
flows. Considerable management judgment is necessary to project future cash
flows  and  evaluate  the  impact  of  expected  operating  and  macroeconomic
changes  on  these  cash  flows.  The  estimates  and  assumptions  we  use  are
consistent  with  our  internal  planning  process.  However,  there  are  inherent
uncertainties in these estimates.

There  were  no  impairment  charges  recorded  relating  to  goodwill  and
indefinite-lived  intangible  assets  and  there  were  no  material  impairment
charges recorded relating to other long-lived assets in 2023, 2022 and 2021.

We may experience future events that may result in asset impairments. Future
disruptions to our business, prolonged economic weakness, due to pandemics
or otherwise, or significant declines in operating results at any of our reporting
units or businesses, may result in impairment charges to goodwill, intangible
assets or other long-lived assets. A significant impairment charge in the future
could have a material adverse effect on our operating results.

Acquisitions,  divestments, 
ventures  and  other
investments, 
transactional  activities  may  require  significant  resources  and/or  result  in
significant unanticipated losses, costs or liabilities.

joint 

Over  the  past  several  years,  acquisitions,  such  as  Adenza,  have  been,  or  are
expected to be, significant factors in our growth. We have divested businesses
and  may  continue  to  divest  additional  businesses  or  assets  in  the  future.
Although  we  cannot  predict  our  transactional  activities,  we  believe  that
additional  acquisitions,  divestments,  investments,  joint  ventures  and  other
transactional activities will be important to our strategy. Such transactions may
be  material  in  size  and  scope.  Other  potential  purchasers  of  assets  in  our
industry  may  have  greater  financial  resources  than  we  have.  Therefore,  we
cannot  be  sure  that  we  will  be  able  to  complete  future  transactions  on  terms
favorable to us.

We  also  invest  in  early-stage  companies  through  our  Nasdaq  Ventures
program and hold minority interests in other entities. Given the size of these
investments, we do not have operational control of these entities and may have
limited visibility into risk management practices. Thus, we may be subject to
additional  capital  requirements  in  certain  circumstances  and  financial  and
reputational risks if there are operational failures.

We  may  finance  future  transactions  by  issuing  additional  equity  and/or  debt.
The  issuance  of  additional  equity  in  connection  with  any  such  transaction
could  be  substantially  dilutive  to  existing  shareholders.  In  addition,  the
announcement or implementation of future transactions by us or others could
have  a  material  effect  on  the  price  of  our  common  stock.  The  issuance  of
additional debt could increase our leverage substantially. Additional debt may
reduce  our  liquidity,  curtail  our  access  to  financing  markets,  impact  our
standing  with  credit  rating  agencies  and  increase  the  cash  flow  required  for
debt service. Any incremental debt incurred to finance a transaction could also
place significant constraints on the operation of our business.

Furthermore, any future transactions could entail a number of additional risks,
including:

• the inability to maintain key pre-transaction business relationships;

• increased operating costs;

• the inability to meet our target for return on invested capital;

• increased  debt  obligations,  which  may  adversely  affect  our  targeted  debt

ratios;

• risks to the continued achievement of our strategic direction;

• risks  associated  with  divesting  employees,  customers  or  vendors  when

divesting businesses or assets;

• declines in the value of investments;

• exposure  to  unanticipated  liabilities,  including  after  a  transaction  is

completed;

• incurred but unreported claims for an acquired company;

• difficulties  in  realizing  projected  efficiencies,  synergies  and  cost  savings;

and

• changes in our credit rating and financing costs.

RISKS RELATED TO LIQUIDITY AND CAPITAL RESOURCES

A  downgrade  of  our  credit  rating  could  increase  the  cost  of  our  funding
from the capital markets.

Our  debt  is  currently  rated  investment  grade  by  two  of  the  major  rating
agencies. These rating agencies regularly evaluate us, and their ratings of our
long-term  debt  and  commercial  paper  are  based  on  a  number  of  factors,
including our financial strength and corporate development activity, as well as
factors not entirely within our control, including

24

conditions affecting our industry generally. There can be no assurance that we
will  maintain  our  current  ratings.  Our  failure  to  maintain  such  ratings  could
reduce or eliminate our ability to issue commercial paper and adversely affect
the  cost  and  other  terms  upon  which  we  are  able  to  obtain  funding  and
increase our cost of capital. A reduction in credit ratings would also result in
increases  in  the  cost  of  our  commercial  paper  and  other  outstanding  debt  as
the interest rate on the outstanding amounts under our credit facilities and our
senior notes fluctuates based on our credit ratings.

Our  leverage  limits  our  financial  flexibility,  increases  our  exposure  to
weakening  economic  conditions  and  may  adversely  affect  our  ability  to
obtain additional financing.

Our indebtedness as of December 31, 2023 was $10.5 billion. We may borrow
additional  amounts  by  utilizing  available  liquidity  under  our  existing  credit
facilities,  issuing  additional  debt  securities  or  issuing  short-term,  unsecured
commercial paper notes through our commercial paper program.

Our leverage and reliance on the capital markets could:

• reduce funds available to us for operations and general corporate purposes
or  for  capital  expenditures  as  a  result  of  the  dedication  of  a  substantial
portion  of  our  consolidated  cash  flow  from  operations  to  the  payment  of
principal and interest on our indebtedness;

• increase  our  exposure  to  a  continued  downturn  in  general  economic

conditions;

ability  to  pursue  new  financing  opportunities,  and  it  may  be  more  expensive
for  us  to  issue  new  debt  securities.  Limited  access  to  capital  or  credit  in  the
future  could  have  an  impact  on  our  ability  to  refinance  debt,  maintain  our
credit  rating,  meet  our  regulatory  capital  requirements,  engage  in  strategic
initiatives, make acquisitions or strategic investments in other companies, pay
dividends,  repurchase  our  stock  or  react  to  changing  economic  and  business
conditions. If we are unable to fund our capital or credit requirements, it could
have  an  adverse  effect  on  our  business,  financial  condition  and  operating
results.

In addition to our debt obligations, we will need to continue to invest in our
operations  for  the  foreseeable  future  to  integrate  acquired  businesses  and  to
fund new initiatives. If we do not achieve the expected operating results, we
will  need  to  reallocate  our  cash  resources.  This  may  include  borrowing
additional  funds  to  service  debt  payments,  which  may  impair  our  ability  to
make investments in our business or to integrate acquired businesses.

If we need to raise funds through incurring additional debt, we may become
subject  to  covenants  more  restrictive  than  those  contained  in  our  credit
facilities, the indentures governing our notes and our other debt instruments.
Furthermore,  if  adverse  economic  conditions  occur,  we  could  experience
decreased  revenues  from  our  operations  which  could  affect  our  ability  to
satisfy financial and other restrictive covenants to which we are subject under
our existing indebtedness.

• place us at a competitive disadvantage compared with our competitors with

RISKS RELATED TO LEGAL AND REGULATORY MATTERS

less debt;

• affect our ability to obtain additional financing in the future for refinancing
indebtedness,  acquisitions,  working  capital,  capital  expenditures  or  other
purposes; and

• increase  our  cost  of  debt  and  reduce  or  eliminate  our  ability  to  issue

commercial paper.

In addition, we must comply with the covenants in our credit facilities. Among
other things, these covenants restrict our ability to effect certain fundamental
transactions, dispose of certain assets, incur additional indebtedness and grant
liens  on  assets.  Failure  to  meet  any  of  the  covenant  terms  of  our  credit
facilities could result in an event of default. If an event of default occurs, and
we  are  unable  to  receive  a  waiver  of  default,  our  lenders  may  increase  our
borrowing  costs,  restrict  our  ability  to  obtain  additional  borrowings  and
accelerate repayment of all amounts outstanding.

We will need to invest in our operations to maintain and grow our business
and to integrate acquisitions, and we may need additional funds, which may
not be readily available.

We depend on the availability of adequate capital to maintain and develop our
business.  Although  we  believe  that  we  can  meet  our  current  capital
requirements  from  internally  generated  funds,  cash  on  hand  and  borrowings
under  our  revolving  credit  facility  and  commercial  paper  program,  if  the
capital and credit markets experience volatility, access to capital or credit may
not be available on terms acceptable to us or at all. Rising interest rates could
adversely affect our

We  operate  in  a  highly  regulated  industry  and  may  be  subject  to  censures,
fines  and  enforcement  proceedings  if  we  fail  to  comply  with  regulatory
obligations that can be ambiguous and can change unexpectedly.

We  operate  in  a  highly  regulated  industry  and  are  subject  to  extensive
regulation in the U.S., Europe and Canada. The securities trading industry is
subject  to  significant  regulatory  oversight  and  could  be  subject  to  increased
governmental and public scrutiny in the future that can change in response to
global  conditions  and  events,  or  due  to  changes  in  trading  patterns,  such  as
due to the recent volatility involving the trading of certain stocks.

Our  ability  to  comply  with  complex  and  changing  regulation  is  largely
dependent  on  our  establishment  and  maintenance  of  compliance,  audit  and
reporting systems that can quickly adapt and respond, as well as our ability to
attract and retain qualified compliance and other risk management personnel.
There is no assurance that our policies and procedures will always be effective
or that we will always be successful in monitoring or evaluating the risks to
which we are or may be exposed.

25

Our  regulated  markets  are  subject  to  audits,  investigations,  administrative
proceedings  and  enforcement  actions  relating  to  compliance  with  applicable
rules and regulations. Regulators have broad powers to impose fines, penalties
or censure, issue cease-and-desist orders, prohibit operations, revoke licenses
or registrations and impose other sanctions on our exchanges, broker-dealers,
central  securities  depositories,  clearinghouse  and  markets  for  violations  of
applicable requirements.

In the future, we could be subject to regulatory investigations or enforcement
proceedings that could result in substantial sanctions, including revocation of
our  operating  licenses.  Any  such  investigations  or  proceedings,  whether
successful  or  unsuccessful,  could  result  in  substantial  costs,  the  diversion  of
resources, including management time, and potential harm to our reputation,
which  could  have  a  material  adverse  effect  on  our  business,  results  of
operations or financial condition. In addition, our exchanges could be required
to modify or restructure their regulatory functions in response to any changes
in the regulatory environment, or they may be required to rely on third parties
to perform regulatory and oversight functions, each of which may require us
to  incur  substantial  expenses  and  may  harm  our  reputation  if  our  regulatory
services are deemed inadequate.

The  regulatory  framework  under  which  we  operate  and  new  regulatory
requirements  or  new  interpretations  of  existing  regulatory  requirements
could  require  substantial  time  and  resources  for  compliance,  which  could
make it difficult and costly for us to operate our business.

Under current U.S. federal securities laws, changes in the rules and operations
of  our  securities  markets,  including  our  pricing  structure,  must  be  reviewed
and  in  many  cases  explicitly  approved  by  the  SEC.  The  SEC  may  approve,
disapprove, or recommend changes to proposals that we submit. In addition,
the SEC may delay either the approval process or the initiation of the public
comment  process.  Favorable  SEC  rulings  and  interpretations  can  be
challenged  in  and  reversed  by  federal  courts  of  appeals,  reducing  or
eliminating  the  value  of  such  prior  interpretations.  Any  delay  in  approving
changes, or the altering of any proposed change, could have an adverse effect
on our business, financial condition and operating results.

We  must  compete  not  only  with  non-exchanges,  such  as  ATSs  that  are  not
subject  to  the  same  SEC  approval  requirements  and  processes,  but  also  with
other exchanges that may have lower regulation and surveillance costs than us.
There  is  a  risk  that  trading  will  shift  to  exchanges  or  non-exchanges  that
charge lower fees because, among other reasons, they spend significantly less
on regulation.

In 2016, the SEC approved a plan for Nasdaq and other exchanges to establish
a CAT to improve regulators’ ability to monitor trading activity. In addition to
increased  regulatory  obligations,  implementation  of  a  CAT  has  resulted  in
significant  additional  expenditures, 
the  new
technology  to  meet  many  of  the  plan’s  requirements.  Creating  the  CAT  has
required the development and

implement 

including 

to 

implementation  of  complex  and  costly  technology.  This  development  effort
has been funded by the SROs (including Nasdaq) in exchange for promissory
notes. In September 2023, the SEC approved a “Funding Model” for the CAT
that allocated one-third of CAT expenses to the SROs, including Nasdaq, and
two-thirds of CAT expenses to the industry. This SEC approval order has been
appealed  to  the  11th  Circuit  U.S.  Court  of  Appeals,  and  the  appeal  remains
pending. In January 2024, the SROs submitted filings, which remain pending,
to  the  SEC  to  establish  the  rate  at  which  the  industry  would  reimburse  the
SROs  for  its  two-thirds  share  of  CAT  expenses.  Those  two  pending  matters
could  be  resolved  unfavorably  to  the  SEC  and  to  the  SROs,  resulting  in  a
delay in recovering expenses or the inability to recover those expenses. As of
December  31,  2023,  we  have  accrued  a  net  receivable  of  $115  million  in
connection with our portion of expenses related to the CAT implementation. In
addition,  the  ongoing  failure  to  timely  launch  or  properly  operate  such
technology exposes Nasdaq and other exchanges to SEC fines.

In addition, our registered broker-dealer subsidiaries are subject to regulation
by  the  SEC,  FINRA  and  other  SROs.  These  subsidiaries  are  subject  to
regulatory  requirements  intended  to  ensure  their  general  financial  soundness
and  liquidity,  which  require  that  they  comply  with  certain  minimum  capital
requirements.  The  SEC  and  FINRA  impose  rules  that  require  notification
when  a  broker-dealer’s  net  capital  falls  below  certain  predefined  criteria,
dictate  the  ratio  of  debt  to  equity  in  the  regulatory  capital  composition  of  a
broker-dealer  and  constrain  the  ability  of  a  broker-dealer  to  expand  its
business  under  certain  circumstances.  Additionally,  the  SEC’s  Uniform  Net
Capital Rule and FINRA rules impose certain requirements that may have the
effect of prohibiting a broker-dealer from distributing or withdrawing capital
and requiring prior notice to the SEC and FINRA for certain withdrawals of
capital. Any failure to comply with these broker-dealer regulations could have
a material adverse effect on the operation of our business, financial condition
and operating results.

Our non-U.S. business is subject to regulatory oversight in all the countries in
which we operate regulated businesses, such as exchanges, clearinghouses or
central  securities  depositories.  In 
these  countries,  we  have  received
authorization  from  the  relevant  authorities  to  conduct  our  regulated  business
activities. The authorities may issue regulatory fines or may ultimately revoke
our  authorizations  if  we  do  not  suitably  carry  out  our  regulated  business
activities. The authorities are also entitled to request that we adopt measures in
order to ensure that we continue to fulfill the authorities’ requirements. We are
also subject to current and forthcoming regulations applicable to the financial
services sector generally including, but not limited to, the Digital Operational
Resilience  Act,  or  DORA,  which  will  become  effective  in  2025.  Such
regulations may impact our operational, contracting and compliance costs by
requiring 
risk  management  procedures,
implementation  of  new 
requirements for procuring information and communication

the 

26

technology services, and ongoing processes to monitor compliance; failure to
maintain  compliance  may  cause  us  to  be  subject  to  regulatory  actions  and
fines.  Additionally,  we  are  subject  to  the  obligations  under  the  Benchmark
Regulation ((EU) 2016/1011), compliance with which could be costly or cause
a change in our business practices.

Certain  of  our  customers  operate  in  a  highly  regulated  industry.  Regulatory
authorities  could  impose  regulatory  changes  that  could  impact  the  ability  of
our  customers  to  use  our  exchanges.  The  loss  of  a  significant  number  of
customers or a reduction in trading activity on any of our exchanges as a result
of such changes could have a material adverse effect on our business, financial
condition and operating results. In addition, regulatory changes could impact
the ability of current or prospective customers to procure commercial services
from us, increase our cost of delivery or performance due to regulatory-driven
changes to services or related business processes and lengthen sales cycles as
customers  are  required  to  conduct  additional  diligence  and  contracting
processes prior to procuring our services.

Regulatory  changes  and  changes  in  market  structure  and  proprietary  data
could have a material adverse effect on our business.

the  securities  markets, 

Regulatory  changes  adopted  by  the  SEC  or  other  regulators  of  our  markets,
and  regulatory  changes  that  our  markets  may  adopt  in  fulfillment  of  their
regulatory  obligations,  could  materially  affect  our  business  operations.  In
recent  years,  there  has  been  increased  regulatory  and  governmental  focus  on
issues  affecting 
including  market  structure,
technological oversight and fees for proprietary market data, connectivity and
transactions.  The  SEC,  FINRA  and  the  national  securities  exchanges  have
introduced  several  initiatives  to  ensure  the  oversight,  integrity  and  resilience
of  markets.  In  December  2022,  the  SEC  proposed  significant  rule  changes
that, if adopted in their current form, would substantially alter how stocks are
traded  in  the  United  States.  In  October  2023,  the  SEC  proposed  to  require
exchanges  to  modify  their  pricing  practices  for  certain  types  of  transactions.
While  we  and  other  market  participants  have  the  opportunity  to  submit
comments  on  these  proposals,  and  we  will  adjust  our  business  model  in
accordance with any new SEC regulations implemented, the adoption of these
proposals regarding trading may negatively impact our business and revenue.

With respect to our regulated businesses, our business model can be severely
impacted  by  policy  decisions.  In  May  2020,  the  SEC  adopted  an  order  to
require  changes  to  the  governance  of  securities  information  processors.  In
December  2020,  the  SEC  adopted  a  rule  to  modify  the  infrastructure  for  the
collection, consolidation and dissemination of market data for exchange-listed
national  market  stocks.  In  2022,  the  U.S.  Court  of  Appeals  for  District  of
Columbia  Circuit  vacated  portions  of  the  governance  order  but  upheld  the
remainder of the SEC’s 2022 actions. If the remaining aspects of the order and
rule  are  fully  implemented,  they  may  adversely  affect  our  revenues.  The
timing for the implementation is currently unknown, and we believe they may
take  two  or  more  years  to  fully  implement.  If  the  remaining  aspects  of  the
order  and  rule  are  ultimately  implemented  as  set  forth  in  their  adopting
releases,  demand  for  certain  of  our  proprietary  tape  share  data  products  may
be  reduced,  or  we  may  have  to  reduce  our  pricing  to  compete  with  other
entrants into the market for consolidated data. Our opponents in some markets
are larger and better funded and, if successful in influencing certain policies,
may  successfully  advocate  for  positions  that  adversely  impact  our  business.
These  regulatory  changes  could  impose  significant  costs,  including  litigation
costs, and other obligations on the operation of our exchanges and processor
systems and have other impacts on our business.

In  Canada,  all  new  marketplace  fees  and  changes  to  existing  fees,  including
trading and market data fees, must be filed with and approved by the Ontario
Securities  Commission.  The  Canadian  Securities  Administrators  adopted  a
Data  Fees  Methodology  that  restricts  the  total  amount  of  fees  that  can  be
charged  for  professional  uses  by  all  marketplaces  to  a  reference  benchmark.
Currently, all marketplaces are subject to annual reviews of their market data
fees tying market data revenues to pre- and post- trade market share metrics.
Permitted  fee  ranges  are  based  on  an  interim  domestic  benchmark  that  is
subject  to  change  to  an  international  benchmark,  which  could  lower  the
permitted  fees  charged  by  marketplaces,  which  could  adversely  impact  our
revenues.

Our European exchanges currently offer market data products to customers on
a non-discriminatory and reasonable commercial basis. The MiFID II/MiFIR
rules entail that the price for regulated market data such as pre- and post-trade
data shall be based on cost plus a reasonable margin. However, these terms are
not clearly defined. There is a risk that a different interpretation of these terms
may  influence  the  fees  for  European  market  data  products  adversely.  In
addition,  any  future  actions  by  European  Union  institutions  could  affect  our
ability  to  offer  market  data  products  in  the  same  manner  as  today,  thereby
causing an adverse effect on our market data revenues.

27

We are subject to litigation risks and other liabilities.

Many  aspects  of  our  business  potentially  involve  substantial  liability  risks.
Although  under  current  law  we  are  immune  from  private  suits  arising  from
conduct  within  our  regulatory  authority  and  from  acts  and  forbearances
incident to the exercise of our regulatory authority, this immunity only covers
certain of our activities in the U.S., and we could be exposed to liability under
national and local laws, court decisions and rules and regulations promulgated
by regulatory agencies.

We face risks related to compliance with economic sanctions (including those
administered  by  the  U.S.  Office  of  Foreign  Assets  Control),  export  controls,
corruption  (including  the  U.S.  Foreign  Corrupt  Practices  Act)  and  money
laundering.  While  we  maintain  compliance  programs  to  prevent  and  detect
potential  violations,  such  programs  cannot  completely  eliminate  the  risk  of
non-compliance.  Since  our  Financial  Crime  Management  Technology  and
surveillance solutions are important offerings, a significant compliance event
involving one of these areas could more negatively impact our business than a
comparable business without this service offering.

Liability could also result from disputes over the terms of a trade, claims that a
system  failure  or  delay  cost  a  customer  money,  claims  we  entered  into  an
unauthorized  transaction  or  claims  that  we  provided  materially  false  or
misleading  statements  in  connection  with  a  securities  transaction.  Although
we carry insurance that may limit our risk of damages in some cases, we still
may  incur  significant  legal  expenses  and  may  sustain  uncovered  losses  or
losses in excess of available insurance that would affect our business, financial
condition and results of operations.

We  have  self-regulatory  obligations  and  also  operate  for-profit  businesses,
and these two roles may create conflicts of interest.

We  have  obligations  to  regulate  and  monitor  activities  on  our  markets  and
ensure compliance with applicable law and the rules of our markets by market
participants  and  listed  companies.  In  the  U.S.,  some  have  expressed  concern
about  potential  conflicts  of  interest  of  “for-profit”  markets  performing  the
regulatory  functions  of  an  SRO.  We  perform  regulatory  functions  and  bear
regulatory responsibility related to our listed companies and our markets. Any
failure by us to diligently and fairly regulate our markets or to otherwise fulfill
our  regulatory  obligations  could  significantly  harm  our  reputation,  prompt
SEC scrutiny and adversely affect our business and reputation.

Our Nordic and Baltic exchanges monitor trading and compliance with listing
standards in accordance with the European Union’s Market Abuse Regulation
and  other  applicable  laws.  As  further  described  in  Note  18,  “Commitments,
Contingencies and Guarantees” to the consolidated financial statements of this
Form  10-K,  during  2023,  the  SFSA  initiated  a  review  of  the  Nasdaq
Stockholm exchange regarding the obligation of Nasdaq Stockholm to report
suspected  market  abuse.  Any  failure  to  diligently  and  fairly  regulate  the
Nordic and Baltic exchanges could significantly harm our reputation, prompt
scrutiny from regulators and adversely affect our business and reputation.

Laws  and  regulations  regarding  security  and  safeguarding  of  our  systems
and  services,  protection  of  sensitive  customer  data  and  the  handling  of
personal data and information may affect our services or result in increased
costs, legal claims or fines against us.

Our  business  operates  certain  systems  that  may  be  considered  “critical
infrastructure” under certain regulations and licenses or sells certain systems
or services to customers that are used by customers in their role as providers
of  critical  infrastructure  or  to  fulfill  certain  core  business  requirements  or
process certain sensitive data. New cybersecurity regulations may impact the
requirements  and  cost  of  delivery  for  impacted  systems  and  services  and,  in
the event of an incident, increase the cost and complexity of our response and
the  potential  financial  and  reputation  impact  from  fines  or  private  litigation.
These regulations may also impact customer decision making and conditions
on contracting for our services.

Our businesses and internal operations rely on the processing of data in many
jurisdictions  and  the  movement  of  data,  including  personal  data,  across
the
national  borders.  Legal  and  contractual  requirements  relating 
processing,  including,  but  not  limited  to,  collection,  storage,  handling,  use,
disclosure,  transfer  and  security,  of  personal  data  continue  to  evolve  and
regulatory  scrutiny  and  customer  requirements  in  this  area  are  increasing
around the world. Significant uncertainty exists as privacy and data protection
laws may be interpreted and applied differently across jurisdictions and may
create inconsistent or conflicting requirements with privacy and other laws to
which we are subject.

to 

Laws  and  regulations  such  as  the  European  Union  and  United  Kingdom
General  Data  Protection  Regulation,  the  California  Privacy  Rights  Act  and
other comparable laws and regulations adopted globally and within the United
States and Canada can apply to our processing of their residents’ personal data
by Nasdaq legal entities regardless of the location of such entities; such laws
may  also  require  our  customers  located  in  such  jurisdictions  to  contractually
obligate our compliance.

28

In addition to directly applying to some of our business activities, these laws
and industry-specific regulations, such as the Health Insurance Portability and
Accountability  Act  and  the  Gramm  Leach  Bliley  Act,  impact  many  of  our
customers,  which  may  affect  their  decisions  to  purchase  our  services.  As  a
supplier  to  such  customers,  regulators  may  engage  in  direct  enforcement
actions or seek to impose liability on us if we do not comply with applicable
regulations. Our efforts to comply with privacy and data protection laws may
entail  substantial  expenses,  may  divert  resources  from  other  initiatives  and
projects, and could impact the services that we offer. The enactment of more
restrictive 
laws,  rules  or  regulations,  future  enforcement  actions  or
investigations, or the creation of new rights to pursue damages could impact
us through increased costs or restrictions on our business, and noncompliance
could result in regulatory penalties and significant legal liability.

Changes in tax laws, regulations or policies could have a material adverse
effect on our financial results.

Changes in tax laws, regulations or policies could result in us having to pay
higher taxes, which may reduce our net income, or could adversely affect our
ability  to  continue  our  capital  allocation  program  or  effect  strategic
transactions  in  a  tax-favorable  manner.  In  addition,  such  changes,  including
federal  or  state  financial  transaction  taxes,  may  increase  the  cost  of  our
offerings or services, which may cause our clients to reduce their use of our
services.

Some of our subsidiaries are subject to tax in the jurisdictions in which they
are  organized  or  operate,  and  in  computing  our  tax  obligation  in  these
jurisdictions,  we  take  various  tax  positions.  We  cannot  ensure  that  upon
review  of  these  positions,  the  applicable  authorities  will  agree  with  our
positions. A successful challenge by a tax authority could result in additional
taxes imposed on our clients or our subsidiaries.

RISKS  RELATED  TO  INTELLECTUAL  PROPERTY  AND  BRAND
REPUTATION

Damage  to  our  reputation  or  brand  name  could  have  a  material  adverse
effect on our businesses.

One  of  our  competitive  strengths  is  our  strong  reputation  and  brand  name.
Various issues may give rise to reputational risk, including issues relating to:

• our ability to maintain the security of our data and systems;

• the quality and reliability of our technology platforms and systems;

• the ability to fulfill our regulatory obligations;

• the  ability  to  execute  our  business  plan,  key  initiatives  or  new  business

ventures and the ability to keep up with changing customer demand;

• the representation of our business in the media;

• the  accuracy  of  our  financial  statements,  other  financial  and  statistical

information or ESG-related disclosures;

• the accuracy of our financial guidance or other information provided to our

investors;

• the quality of our corporate governance structure;

• the quality of our products the reliability of our solutions and the accuracy

of our information and data offerings;

• the  quality  of  our  disclosure  controls  or  internal  controls  over  financial

reporting, including any failures in supervision;

• extreme price volatility on our markets;

• any negative publicity surrounding our listed companies or our listing rules;

• any negative publicity surrounding the use of our products and/or services
by our customers, including in connection with emerging asset classes such
as crypto assets; and

• any  misconduct,  fraudulent  activity  or  theft  by  our  employees  or  other

persons formerly or currently associated with us.

Negative publicity or misrepresentations by third parties, particularly on social
media, may adversely impact our credibility as a leader in the global capital
markets  and  as  a  source  for  data  and  analytics.  This  may  have  an  adverse
effect on our brands, business and operating results. Damage to our reputation
could cause some issuers not to list their securities on our exchanges or switch
to  a  different  exchange.  Reputational  damage  may  also  reduce  trading
volumes or values on our exchanges or cause us to lose customers. This may
have  a  material  adverse  effect  on  our  business,  financial  condition  and
operating results.

Failure to meet customer expectations or deadlines for the implementation
of our products could result in negative publicity, losses and reduced sales,
each of which may harm our reputation, business and results of operations.

We generally mutually agree with our customers on the duration, budget and
costs  associated  with  the  implementation  of  certain  of  our  products,
particularly  our  market  technology  large-scale  market  infrastructure  projects.
Various  factors  may  cause  implementations  to  be  delayed,  inefficient  or
otherwise unsuccessful, including due to unforeseen project complexities, our
deployment of insufficient resources or other external factors. The effects of a
failure to meet an implementation schedule could include monetary credits for
current  or  future  service  engagements,  a  reduction  in  fees  for  the  project,  or
the  expenditure  of  additional  expenses  to  mitigate  such  delays.  In  addition,
time-consuming  implementations  may  also  increase  the  personnel  we  must
allocate to such customer, thereby increasing our costs and diverting attention
from other projects. Unsuccessful, lengthy, or costly customer implementation
projects  could  result 
in  claims  from  customers,  decreased  customer
satisfaction,  harm  to  our  reputation,  and  opportunities  for  competitors  to
displace  us,  each  of  which  could  have  an  adverse  effect  on  our  reputation,
business and results of operations.

29

Our  reputation  or  business  could  be  negatively  impacted  by  ESG  matters
and our reporting of such matters.

our  intellectual  property  rights  could  result  in  the  expenditure  of  significant
financial and managerial resources.

We  communicate  certain  ESG-related  initiatives,  goals,  and/or  commitments
regarding  environmental  matters,  social  matters,  vendors  and  suppliers  and
other  matters  in  our  annual  Sustainability  Report,  Task  Force  on  Climate-
related Financial Disclosures, on our website, in our filings with the SEC and
elsewhere. These initiatives, goals, or commitments, such as our commitment
to achieve net-zero for Scope 3 greenhouse gas emissions by 2050, could be
difficult  to  achieve  and  costly  to  implement.  We  could  fail  to  achieve,  or  be
perceived  to  fail  to  achieve,  these  initiatives,  goals,  or  commitments.  In
addition,  we  could  be  criticized  for  the  timing,  scope  or  nature  of  these
initiatives, goals, or commitments, or for any revisions to them. We could be
subject to litigation or regulatory enforcement actions regarding the accuracy,
adequacy,  or  completeness  of  our  ESG-related  disclosures.  Our  actual  or
perceived 
initiatives,  goals,  or
commitments  could  negatively  impact  our  reputation  or  otherwise  materially
harm our business.

to  achieve  our  ESG-related 

failure 

Failure  to  protect  our  intellectual  property  rights,  or  allegations  that  we
have infringed on the intellectual property rights of others, could harm our
brand-building efforts and ability to compete effectively.

To  protect  our  intellectual  property  rights,  we  rely  on  a  combination  of
trademark  laws,  copyright  laws,  patent  laws,  trade  secret  protection,
confidentiality  agreements  and  other  contractual  arrangements  with  our
affiliates,  clients,  strategic  partners,  employees  and  others.  However,  the
efforts we have taken to protect our intellectual property and proprietary rights
might  not  be  sufficient,  or  effective,  at  stopping  unauthorized  use  of  those
rights. We may be unable to detect the unauthorized use of, or take appropriate
steps to enforce, our intellectual property rights.

jurisdictions.  However,  effective 

We have registered, or applied to register, our trademarks in the United States
and  in  over  50  foreign  jurisdictions  and  have  pending  U.S.  and  foreign
applications  for  other  trademarks.  We  also  maintain  copyright  protection  for
software products and pursue patent protection for inventions developed by us.
We  hold  a  number  of  patents,  patent  applications  and  licenses  in  the  United
States  and  other  foreign 
trademark,
copyright,  patent  and  trade  secret  protection  might  not  be  available  or  cost-
effective  in  every  country  in  which  we  offer  our  services  and  products.
Moreover, changes in patent law, regulation or practices at the U.S. Patent and
Trademark  Office  and/or  analogous  offices  in  other  jurisdictions,  such  as
changes in the law regarding patentable subject matter, could also impact our
ability to obtain patent protection for our innovations. The scope of protection
under our patents may not be sufficient in some cases, or existing patents may
be  deemed  invalid  or  unenforceable.  Failure  to  protect  our  intellectual
property  adequately  could  harm  our  brand  and  affect  our  ability  to  compete
effectively. Further, defending

Third parties may assert intellectual property rights claims against us, which
may  be  costly  to  defend,  could  require  the  payment  of  damages  and  could
limit  our  ability  to  use  certain  technologies,  trademarks  or  other  intellectual
property.  Any  intellectual  property  claims,  with  or  without  merit,  could  be
expensive  to  litigate  or  settle  and  could  divert  management  resources  and
attention.  Successful  challenges  against  us  could  require  us  to  modify  or
discontinue  our  use  of  technology  or  business  processes  where  such  use  is
found  to  infringe  or  violate  the  rights  of  others,  or  require  us  to  purchase
licenses from third parties, any of which could adversely affect our business,
financial condition and operating results.

GENERAL RISK FACTORS

We are a holding company that depends on cash flow from our subsidiaries
to meet our obligations, and any restrictions on our subsidiaries’ ability to
pay  dividends  or  make  other  payments  to  us  may  have  a  material  adverse
effect on our results of operations and financial condition.

As  a  holding  company,  we  require  dividends  and  other  payments  from  our
subsidiaries  to  meet  cash  requirements.  Minimum  capital  requirements
mandated  by  regulatory  authorities  having  jurisdiction  over  some  of  our
regulated  subsidiaries  indirectly  restrict  the  amount  of  dividends  that  can  be
paid upstream.

If our subsidiaries are unable to pay dividends and make other payments to us
when  needed,  or  if  regulators  or  counterparties  require  us  to  increase  capital
deployed in certain of our regulated subsidiaries, we may be unable to satisfy
our obligations, which would have a material adverse effect on our business,
financial condition and operating results.

We  may  experience  fluctuations  in  our  operating  results,  which  may
adversely affect the market price of our common stock.

Our  industry  is  risky  and  unpredictable  and  is  directly  affected  by  many
national and international factors beyond our control, including:

• economic, political and geopolitical market conditions;

• natural disasters, terrorism, pandemics, war or other catastrophes;

• broad trends in finance and technology;

• changes in price levels and volatility in the stock markets;

• the level and volatility of interest rates;

• volatility in commodity markets, including the energy markets;

• inflation;

• disruptions or delays in our supply chains;

30

• changes in government monetary or tax policy;

• the  imposition  of  governmental  economic  sanctions  on  countries  in  which

we do business or where we plan to expand our business; and

• the perceived attractiveness of the U.S. or European capital markets.

Any one of these factors could have a material adverse effect on our business,
financial condition and operating results by causing a substantial decline in the
financial services markets and reducing trading volumes or values.

Additionally,  since  borrowings  under  our  credit  facilities  bear  interest  at
variable rates and commercial paper is issued at prevailing interest rates, any
increase  in  interest  rates  on  debt  that  we  have  not  fixed  using  interest  rate
hedges will increase our interest expense, reduce our cash flow or increase the
cost  of  future  borrowings  or  refinancings.  Other  than  variable  rate  debt,  we
believe  our  business  has  relatively  large  fixed  costs  and  low  variable  costs,
which magnifies the impact of revenue fluctuations on our operating results.
As a result, a decline in our revenue may lead to a relatively larger impact on
operating results. A substantial portion of our operating expenses is related to
personnel  costs,  regulation  and  corporate  overhead,  none  of  which  can  be
adjusted quickly and some of which cannot be adjusted at all. Our operating
expense  levels  are  based  on  our  expectations  for  future  revenue.  If  actual
revenue  is  below  management’s  expectations,  or  if  our  expenses  increase
before  revenues  do,  both  revenues  less  transaction-based  expenses  and
operating results would be materially and adversely affected. Because of these
factors, it is possible that our operating results or other operating metrics may
fail  to  meet  the  expectations  of  stock  market  analysts  and  investors.  If  this
happens, the market price of our common stock may be adversely affected.

Our operational processes are subject to the risk of error, which may result
in financial loss or reputational damage.

We have instituted extensive controls to reduce the risk of error inherent in our
operations;  however,  such  risk  cannot  completely  be  eliminated.  Our
businesses are highly dependent on our ability to process and report, on a daily
basis,  a  large  number  of  transactions  across  numerous  and  diverse  markets.
Some  of  our  operations  require  complex  processes,  and  the  introduction  of
new  products  or  services  or  changes  in  processes  or  reporting  due  to
regulatory requirements may result in an increased risk of errors for a period
after 
likelihood  of  such  errors  or
vulnerabilities  is  heightened  as  we  acquire  new  products  from  third  parties,
whether as a result of acquisitions or otherwise.

implementation.  Additionally, 

the 

Data, other content or information that we distribute may contain errors or be
delayed, causing reputational harm. Use of our products and services as part of
the investment process creates the risk that clients, or the parties whose assets
are managed by our clients, may pursue claims against us in the event of such
delay  or  error,  and  significant  litigation  against  us  might  unduly  burden
management, personnel, financial and other resources.

In  addition,  the  sophisticated  software  we  sell  to  our  customers  may  contain
undetected  errors  or  vulnerabilities,  some  of  which  may  be  discovered  only
after  delivery,  or  could  fail  to  perform  its  intended  purpose.  Because  our
clients  depend  on  our  solutions  for  critical  business  functions,  any  service
interruptions,  failures  or  other  issues  may  result  in  lost  or  delayed  market
acceptance and lost sales, or negative customer experiences that could damage
our reputation, resulting in the loss of customers, loss of revenues and liability
for  damages,  which  may  adversely  affect  our  business,  operating  results  and
financial condition.

Climate change may have a long-term adverse impact on our business, and
climate  and  ESG-related  disclosure  requirements  may  reduce  demand  for
listings on our exchanges.

While we seek to mitigate our business risks associated with climate change
by  establishing  robust  environmental  and  sustainability  programs,  there  are
inherent climate related risks wherever our business is conducted. There is an
increased  focus  from  our  regulators,  investors,  clients,  employees,  and  other
stakeholders  concerning  corporate  citizenship  and  sustainability  matters.
Access  to  clean  water  and  reliable  energy  in  the  communities  where  we
conduct our business, whether for our offices, data centers, vendors, clients or
other  stakeholders,  is  a  priority.  For  example,  changes  in  weather  where  we
operate may increase the costs of powering and cooling our data centers or the
facilities that we use to operate our exchanges and clearinghouses, develop our
products  or  provide  cloud-based  services.  Climate  related  events,  including
extreme  weather  events  and  their  impact  on  the  critical  infrastructure  in  the
United States and elsewhere, have the potential to disrupt our business or the
business  of  our  clients;  cause  increased  volatility  in  commodity  markets  in
which  Nasdaq  Clearing  operates  as  a  clearinghouse,  which  may  result  in
Nasdaq Clearing holding insufficient collateral for such volatility; lead to an
increase in costs of raw materials, which may adversely affect certain of our
listed  companies  operating  in  certain  sectors  and  create  adverse  market
conditions, including trading volatility beyond historical levels, any of which
could  adversely  affect  our  business,  reputation,  financial  condition  and
operating  results.  Additionally,  if  the  SEC  or  other  federal,  state  or
international regulatory agencies impose comprehensive reporting obligations
regarding climate change on U.S. public companies, there may be a decrease
in new listings or an increase in delistings of our listed companies, which may
adversely affect our business, financial condition and operating results. Such
new regulations, whether in the U.S.

31

or  in  other  countries  in  which  we  operate,  could  also  cause  us  to  incur
additional compliance and reporting costs.

Because  we  have  operations  in  numerous  countries,  we  are  exposed  to
currency risk.

Our businesses operate in various international markets, which are subject
to political, economic and social uncertainties.

Our  businesses  operate  in  various  international  markets,  including  but  not
limited  to  Northern  Europe,  the  Baltics,  the  Middle  East,  Latin  America,
Africa and Asia, and our non-U.S. operations are subject to the risk inherent in
the  international  environment.  Political,  economic  or  social  events  or
developments in one or more of our non-U.S. locations or in the U.S. arising
from  such  international  developments,  such  as  limitations  imposed  on
securing  new  listings  on  our  exchanges  or  restrictions  on  entering  into
transactions with new or existing customers, could adversely affect our sales,
operations and financial results. Some locations, such as Lithuania, India, the
Philippines  and  in  other  emerging  markets,  have  economies  that  may  be
subject  to  greater  political,  economic  and  social  uncertainties  than  countries
with  more  developed  institutional  structures,  which  may  increase  our
operational risk.

Unforeseen  or  catastrophic  events  could  interrupt  our  critical  business
functions.  In  addition,  our  U.S.  and  European  businesses  are  heavily
concentrated in particular areas and may be adversely affected by events in
those areas.

We may incur losses as a result of unforeseen or catastrophic events, such as
terrorist  attacks,  natural  disasters,  pandemics,  extreme  weather,  fire,  power
loss, telecommunications failures, human error, theft, sabotage and vandalism.
Given our position in the global capital markets, we may be more likely than
other companies to be a target for malicious disruption activities.

In  addition,  our  U.S.  and  European  business  operations  are  heavily
concentrated  in  the  east  coast  of  the  U.S.,  and  Stockholm,  Sweden,
respectively.  Any  event  that  impacts  either  of  those  geographic  areas  could
potentially affect our ability to operate our businesses.

We  have  disaster  recovery  and  business  continuity  plans  and  capabilities  for
critical systems and business functions to mitigate the risk of an interruption.
Any interruption in our critical business functions or systems could negatively
impact  our  financial  condition  and  operating  results.  Additionally,  some
colocation  customers  may  lack  adequate  disaster  recovery  solutions  to  avoid
loss of trade flow from a sustained interruption of our critical systems.

We have operations in the U.S., the Nordic and Baltic countries, Canada, the
United  Kingdom,  Australia  and  many  other  foreign  countries.  We  therefore
have  significant  exposure  to  exchange  rate  movements  between  the  Euro,
Swedish Krona, the Canadian dollar and other foreign currencies against the
U.S.  dollar.  Significant  inflation  or  disproportionate  changes  in  foreign
exchange rates with respect to one or more of these currencies could occur as
a result of general economic conditions, acts of war or terrorism, changes in
governmental  monetary  or  tax  policy,  changes  in  local  interest  rates  or  other
factors. These exchange rate differences will affect the translation of our non-
U.S.  results  of  operations,  interest  expense  and  financial  condition  into  U.S.
dollars as part of the preparation of our consolidated financial statements.

If our risk management methods are not effective, our business, reputation
and financial results may be adversely affected.

We  utilize  widely-accepted  methods  to  identify,  assess,  monitor  and  manage
our  risks,  including  oversight  of  risk  management  by  Nasdaq’s  Global  Risk
Management  Committee,  which  comprises  senior  executives  and  has  the
responsibility  for  regularly  reviewing  risks  and  referring  significant  risks  to
the  board  of  directors  or  specific  board  committees.  Local  risk  management
committees  in  our  international  offices  provide  local  risk  oversight  and
escalation  to  local  boards,  as  appropriate.  Certain  risk  management  methods
require  subjective  evaluation  of  dynamic  information  regarding  markets,
customers or other matters. That variable information may not in all cases be
accurate, complete, up-to-date or properly evaluated. If we do not successfully
identify,  assess,  monitor  or  manage  the  risks  to  which  we  are  exposed,  our
business,  reputation,  financial  condition  and  operating  results  could  be
materially adversely affected.

Decisions  to  declare  future  dividends  on  our  common  stock  will  be  at  the
discretion of our board of directors and there can be no guarantee that we
will pay future dividends to our stockholders.

Our board of directors regularly declares quarterly cash dividend payments on
our  outstanding  common  stock.  Future  declarations  of  dividends  and  the
establishment  of  future  record  and  payment  dates  are  subject  to  approval  by
Nasdaq’s  board  of  directors.  The  board’s  determination  to  declare  dividends
will  depend  upon  our  profitability  and  financial  condition,  contractual
restrictions, restrictions imposed by applicable law and other factors that the
board deems relevant. Based on an evaluation of these factors, the board may
determine not to declare future dividends at all or to declare future dividends
at a reduced amount.

32

Provisions  of  our  certificate  of  incorporation,  by-laws,  exchange  rules
(including provisions included to address SEC concerns) and governing law
restrict  the  ownership  and  voting  of  our  common  stock.  In  addition,  such
provisions  could  delay  or  prevent  a  change  in  control  of  us  and  entrench
current management.

Item 1B. Unresolved Staff Comments

None.

Item 1C. Cybersecurity

Risk management and strategy

Our organizational documents place restrictions on the voting rights of certain
stockholders.  The  holders  of  our  common  stock  are  entitled  to  one  vote  per
share on all matters to be voted upon by the stockholders except that no person
may exercise voting rights in respect of any shares in excess of 5% of the then
outstanding  shares  of  our  common  stock.  Any  change  to  the  5%  voting
limitation would require SEC approval.

In response to the SEC’s concern about a concentration of our ownership, the
rules  of  some  of  our  exchange  subsidiaries  include  a  prohibition  on  any
member  or  any  person  associated  with  a  member  of  the  exchange  from
beneficially owning more than 20% of our outstanding voting interests. SEC
consent would be required before any investor could obtain more than a 20%
voting  interest  in  us.  The  rules  of  some  of  our  exchange  subsidiaries  also
require the SEC’s approval of any business ventures with exchange members,
subject to exceptions.

Our organizational documents contain provisions that may be deemed to have
an anti-takeover effect and may delay, deter or prevent a change of control of
us, such as a tender offer or takeover proposal that might result in a premium
over  the  market  price  for  our  common  stock.  Additionally,  certain  of  these
provisions make it more difficult to bring about a change in the composition of
our  board  of  directors,  which  could  result  in  entrenchment  of  current
management.

Our certificate of incorporation and by-laws:

• do not permit stockholders to act by written consent;

• require  certain  advance  notice  for  director  nominations  and  actions  to  be

taken at annual meetings; and

• authorize  the  issuance  of  undesignated  preferred  stock,  or  “blank  check”
preferred  stock,  which  could  be  issued  by  our  board  of  directors  without
stockholder approval.

Section 203 of the Delaware General Corporation Law imposes restrictions on
mergers and other business combinations between us and any holder of 15%
or more (or, in some cases, a holder who previously held 15% or more) of our
common stock. In general, Delaware law prohibits a publicly held corporation
from  engaging  in  a  “business  combination”  with  an  “interested  stockholder”
for three years after the stockholder becomes an interested stockholder, unless
the  corporation’s  board  of  directors  and  stockholders  approve  the  business
combination in a prescribed manner.

Finally,  many  of  the  European  countries  where  we  operate  regulated  entities
require  prior  governmental  approval  before  an  investor  acquires  10%  or
greater of our common stock.

regulatory  enforcement  actions  or 

Nasdaq’s  brand  and  role  as  a  critical  infrastructure  provider  for  global
financial  markets,  and  operator  of  the  Nasdaq  Stock  Market,  make  us  an
attractive  target  for  cybersecurity  risks,  including  from  international  political
opponents,  hacktivists  and  ransomware  or  other  financially  motivated
criminals  targeting  the  financial  sector.  Our  cybersecurity  risks  include
financial and reputational damage, along with collateral damage from loss of
customer  confidence  in  our  exchange,  products  or  offerings,  as  applicable,
from
potential 
governmental  authorities  or  shareholders,  or  the  failure  to  comply  with
contractual breach notifications. To date, no risks from cybersecurity threats,
including as a result of any previous cybersecurity incidents, have materially
affected or are reasonably likely to materially affect our business, our business
strategy,  our  results  of  operations  or  financial  condition.  For  further
information,  see  “Our  role  in  the  global  marketplace  positions  us  at  greater
risk  for  a  cyberattack”  and  “Expanded  cybersecurity  regulations,  and
increased  cybersecurity  infrastructure  and  compliance  costs,  may  adversely
impact  our  results  of  operations”  in  “Item  1A,  Risk  Factors”  of  this  Annual
Report on Form 10-K.

litigation,  either 

Our  risk  management  and  mitigation  approach  includes  the  adoption  of
security  controls  and  adaptive  ongoing  threat  analysis.  Our  policies  and  our
baseline security controls incorporate robust security infrastructure, risk-based
controls  and  multi-  layered  defense  systems.  We  have  16  System  and
Organization  Controls  Type  2,  or  SOC  2,  certifications  with  respect  to  our
information  security  and  infrastructure.  Our  adaptive  analysis  monitors  the
threat landscape relevant to Nasdaq, our vendors and financial industry peers,
and threats arising from geopolitical events. As the external threat landscape
evolves, our information security controls are regularly evaluated, updated and
enhanced  to  help  protect  against  emerging  risks.  Additionally,  we  conduct
extensive  cybersecurity  assessments  of  our  acquired  entities,  both  prior  to
acquisition  and  following  completion  of  the  transaction,  to  understand
potential threats and mitigate any potential security gaps, as well as to ensure
compliance with our security infrastructure and access management practices
and policies.

We  periodically  engage  external  advisors  to  perform  an  analysis  of  our
information  security  procedures,  which  include  a  review  of  program
documentation  and  an  overall  maturity  assessment  of  Nasdaq’s  information
security  programs.  These  advisors  provide  recommendations  to  further
enhance our procedures. The findings are then presented to the Audit & Risk
Committee  of  the  Board  of  Directors,  or  the  Audit  &  Risk  Committee.  In
2023,  our  management  team  and  the  Board  of  Directors  conducted  tabletop
exercises  and  simulations  in  cybersecurity  matters  with  assistance  from
internal and outside experts.

33

We use certain cloud-based third-party vendors for the core trading systems of
certain of our exchanges and certain of our governance products and solutions.
Prior 
to  engaging  such  vendors,  we  analyze  each  provider’s  SOC2
certifications  and  perform  due  diligence  and  testing  for  information  security
and  interoperability  with  our  systems,  and  annually  review  the  SOC2
certifications.  Our  security  assurance  and  threat  assessment  team,  within  our
Information  Security  organization,  collaborates  with  our  external  threat
intelligence  providers  to  proactively  review  Nasdaq,  and  our  vendors  with
respect to emerging threats and associated risks.

For  our  third-party  service  providers,  our  risk  assessment  process  evaluates
the probability and potential impact of incidents related to operational errors,
technology  disruptions,  information  security  breaches,  workforce  issues,
internal and external fraud, financial actions, and legal and regulatory matters.
This  assessment  process  is  part  of  our  Supplier  Risk  Management  program,
which  establishes  processes  for  identifying,  assessing,  and  periodically
reviewing our exposure to risk through third party vendors.

Governance

Cybersecurity is an integral part of risk management at Nasdaq. The Board of
Directors  appreciates  the  rapidly  evolving  nature  of  threats  presented  by
cybersecurity incidents and is committed to the prevention, timely detection,
and  mitigation  of  the  effect  any  such  incidents  may  have  on  us.  We  use  a
cross-departmental approach to assess and manage cybersecurity risk, with our
Information  Security;  Legal,  Risk  and  Regulatory;  and  Internal  Audit
functions  presenting  on  key  topics  to  the  Audit  &  Risk  Committee,  which
provides  oversight  of  our  cybersecurity  risk.  Additionally,  members  from
these  organizations,  along  with  Finance  and  Accounting,  comprise  a  rapid
response team that would mobilize in the event of a significant cybersecurity
incident and would analyze and evaluate the incident while also advising the
executive  management  team.  Our  Global  Risk  Management  Committee,
which  includes  our  Chair  and  CEO  and  other  senior  executives,  assists  the
Board of Directors in its cybersecurity risk oversight role.

Our Audit & Risk Committee receives quarterly or, if needed, more frequent
reports  on  cybersecurity  and  information  security  matters  from  our  Chief
Information Security Officer, or CISO, and his team. The CISO has more than
25  years  of  experience  in  information  technology  and  information  security,
particularly  in  the  financial  services  industry,  and  our  Information  Security
organization  has  more  than  100  members,  with  expertise  in  application
security; governance and compliance; program and vulnerability management;
security  engineering;  security  operations  security  assurance;  and  threat
intelligence and security architecture.

that  contains 

This  regular  reporting  to  the  Audit  &  Risk  Committee  also  includes  a
cybersecurity  dashboard 
information  on  cybersecurity
governance  processes,  and  from  time  to  time,  also  includes  the  status  of
internal  cybersecurity,  ongoing  prevention  and
projects 
mitigation  efforts,  security  features  of  the  products  and  services  we  provide
our customers, or the results of security events during the period. The Audit &
Risk  Committee  also  reviews  and  discusses  recent  cyber  incidents  affecting
the industry and the emerging threat landscape.

to  strengthen 

Cybersecurity is a shared responsibility, and our goal is for all employees to be
vigilant in helping to protect our organization and themselves, at all times. We
routinely perform simulations and tabletop exercises, and incorporate external
resources  and  advisors  as  needed,  to  help  strengthen  our  cybersecurity
protection and information security procedures and safeguards. All employees
are  required  to  complete  annual  cybersecurity  awareness  training  and  have
access  to  continuous  cybersecurity  educational  opportunities  throughout  the
year.  Nasdaq  also  maintains  a  cybersecurity  and  information  security  risk
insurance  policy,  and  our  Nasdaq  Information  Security  Management  System
conforms to ISO 27001 requirements and is ISO 27001 certified.

On  an  annual  basis,  the  Information  Security  team  reviews  and  updates  its
governance  documents,  including  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. Additionally, the Information Security team maintains
a  formal  cybersecurity  strategic  three-year  plan,  which  outlines  the  strategic
vision and associated goals for the cybersecurity of our global operations. The
plan  is  regularly  updated  with  new  initiatives  that  align  with  technology
innovations and changes in the threat landscape, and is reviewed and approved
by the CISO and the Audit & Risk Committee. Throughout the three-year plan
term, the CISO regularly provides management with progress reports.

Item 2. Properties

We  conduct  our  business  operations  in  leased  facilities.  We  do  not  own  any
real property. Our U.S. headquarters are located in New York, New York, and
our European headquarters are located in Stockholm, Sweden. We also lease
space in multiple locations around the world, which are used for research and
development,  sales  and  support,  and  administrative  activities,  as  well  as  for
data centers and disaster preparedness facilities.

Generally,  our  properties  are  not  allocated  for  use  by  a  particular  segment.
Instead,  most  of  our  properties  are  used  by  two  or  more  segments.  We
regularly monitor the facilities we occupy to ensure that they suit our needs in
a  hybrid  work  environment.  We  believe  the  facilities  that  we  occupy  are
adequate  for  the  purposes  for  which  they  are  currently  used  and  are  well-
maintained.  See  Note  16,  “Leases,”  to  the  consolidated  financial  statements
for further discussion.

34

Item 3. Legal Proceedings

Purchases of Equity Securities by the Issuer and Affiliated Purchasers

For a description of our legal proceedings, if any, see “Legal and Regulatory
Matters”  of  Note  18,  “Commitments,  Contingencies  and  Guarantees,”  to  the
consolidated financial statements, which is incorporated herein by reference.

The  table  below  represents  repurchases  made  by  or  on  behalf  of  us  or  any
“affiliated  purchaser”  of  our  common  stock  during  the  fiscal  quarter  ended
December 31, 2023:

Item 4. Mine Safety Disclosures

Not applicable.

PART II

Item  5.  Market  for  Registrant’s  Common  Equity,  Related  Stockholder
Matters and Purchases of Equity Securities

Market Information

Our  common  stock  is  listed  on  The  Nasdaq  Stock  Market  under  the  ticker
symbol  “NDAQ.”  As  of  February  13,  2024,  we  had  approximately  202
holders of record of our common stock.

Issuer Purchases of Equity Securities

Share Repurchase Program

See “Share Repurchase Program,” of Note 12, “Nasdaq Stockholders’ Equity,”
to  the  consolidated  financial  statements  for  further  discussion  of  our  share
repurchase program.

(c) 
Total Number of
Shares Purchased
as Part of
Publicly
Announced Plans
or Programs

(d) Maximum
Dollar Value of
Shares that
May Yet Be
Purchased
Under the Plans
or Programs (in
millions)

(a) 
Total Number of
Shares Purchased

(b) Average
Price Paid Per
Share

—  $

19,360  $

1,751,513  $

Period
October 2023
Share repurchase
program
Employee
transactions
November 2023
Share repurchase
program
Employee
transactions
December 2023
Share repurchase
program
Employee
transactions
Total Quarter Ended December 31, 2023
Share repurchase
program
Employee
transactions

2,084,774  $

333,261  $

17,883  $

37,243  $

—  $

— 

—  $

2,000 

48.85 

52.36 

 N/A

 N/A

1,751,513  $

1,908 

— 

 N/A

 N/A

54.44 

56.22 

52.69 

52.39 

333,261  $

1,890 

 N/A

 N/A

2,084,774  $

1,890 

 N/A

N/A

In the preceding table:

• N/A - Not applicable.

• See  “Share  Repurchase  Program,”  of  Note  12,  “Nasdaq  Stockholders’
Equity,”  to  the  consolidated  financial  statements  for  further  discussion  of
our share repurchase program. 

• Employee  transactions  represents  shares  surrendered  to  us  to  satisfy  tax
withholding  obligations  arising  from  the  vesting  of  restricted  stock  and
PSUs previously issued to employees.

35

 
 
 
The  following  performance  graph  and  related  information  shall  not  be  deemed  “filed”  for  purposes  of  Section  18  of  the  Exchange  Act  or  incorporated  by
reference into any of our other filings under the Securities Act or the Exchange Act, except as shall be expressly set forth by specific reference in such filing.

The following graph compares the total return of our common stock to the Nasdaq Composite Index, the S&P 500 and a peer group selected by us for the past five
years.  We  changed  our  peer  group  in  the  table  below  to  the  S&P  500  GICS  4020  Index,  or  New  Peer  Group,  which  is  a  blend  of  exchanges,  as  well  as  data,
financial technology and banking companies to align more closely with Nasdaq’s diverse business and competitors.

PERFORMANCE GRAPH

Nasdaq, Inc.
Nasdaq Composite Index
S&P 500
New Peer Group
2022 Peer Group

Fiscal Year Ended December 31,

2018

2019

2020

2021

2022

2023

$

100  $
100 
100 
100 
100 

134  $
137 
131 
125 
128 

169  $
198 
156 
139 
153 

$

270 
242 
200 
188 
171 

240  $
163 
164 
167 
142 

231 
236 
207 
193 
170 

The figures represented below assume an initial investment of $100 in the common stock or index at the closing price on December 31, 2018 and the reinvestment
of all dividends.

COMPARISON OF 5 YEAR CUMULATIVE TOTAL RETURN
Among Nasdaq, Inc., the Nasdaq Composite Index, the S&P 500 and Peer Groups

The prior peer group, collectively referred to as the 2022 Peer Group, was comprised of the following companies:

2022 Peer Group

•
•
•
•
•

ASX Limited
B3 S.A.
Bolsas Mexicana de Valores, S.A.B. de C.V.
Cboe
CME Group Inc.

• Deutsche Börse AG
• Euronext N.V.
• Hong Kong Exchanges and Clearing Limited
• ICE
• Japan Exchange Group, Inc.

• LSE
• Singapore Exchange Limited
• TMX Group Limited

36

Item 6. [Reserved]

Nasdaq’s Operating Results

Item  7.  Management’s  Discussion  and  Analysis  of  Financial  Condition
and Results of Operations

The following discussion and analysis of the financial condition and results of
operations  of  Nasdaq  refers  to  the  year-over-year  comparison  for  the  fiscal
years ended December 31, 2023 and December 31, 2022 and should be read in
conjunction  with  our  consolidated  financial  statements  and  related  notes
included  in  this  Form  10-K,  as  well  as  the  discussion  under  “Item  1A.  Risk
Factors.” For further discussion of our growth strategy, products and services,
and competitive strengths, see “Item 1. Business.”

Discussion  of  fiscal  year  2022  items  and  the  year-over  year  comparison  of
changes in our financial condition and results of operations as of and for the
fiscal years ended December 31, 2022 and December 31, 2021 can be found in
Part  II,  “Item  7.  Management’s  Discussion  and  Analysis  of  Financial
Condition and Results of Operations” of our Annual Report on Form 10-K for
the fiscal year ended December 31, 2022, which was previously filed with the
SEC on February 23, 2023. For the Financial Technology segment, which was
impacted  by  the  new  divisional  structure  subsequent  to  the  Adenza
acquisition,  the  comparisons  presented  in  this  discussion  and  analysis  also
include  the  year-over-year  comparison  of  results  of  operations  for  the  fiscal
years ended December 31, 2022 and December 31, 2021.

Business Segments

Our organizational structure aligns our businesses with the foundational shifts
that  are  driving  the  evolution  of  the  global  financial  system.  Following  the
acquisition of Adenza, we further refined the divisional structure into Capital
Access  Platforms,  Financial  Technology  and  Market  Services  reportable
segments.  All  prior  periods  have  been  restated  to  conform  to  the  current
period presentation. See Note 1, “Organization and Nature of Operations,” and
Note  19,  “Business  Segments,”  to  the  consolidated  financial  statements  for
further discussion of our reportable segments and geographic data, as well as
how  management  allocates  resources,  assesses  performance  and  manages
these businesses as three separate segments. See “Part I, Item 1. Business” for
additional discussion on recent developments and highlights.

The following tables summarize our financial performance for the year ended
December  31,  2023  compared  to  the  same  period  in  2022  and  for  the  year
ended  December  31,  2022  when  compared  to  the  same  period  in  2021.  The
comparability  of  our  results  of  operations  between  reported  periods  is
impacted  by  the  acquisition  of  Adenza  in  November  2023.  See  “2023
Acquisition,”  of  Note  4,  “Acquisitions,”  to  the  consolidated  financial
statements  for  further  discussion.  For  a  detailed  discussion  of  our  results  of
operations, see “Segment Operating Results” below.

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions, except per share amounts)

Revenues less
transaction-
based expenses $
Operating
expenses
Operating
income
Net income
attributable to
Nasdaq
Diluted earnings
per share
Cash dividends
declared per
common share $

$

$

3,895  $

3,582  $

3,420 

8.7 %

4.7 %

2,317 

2,018 

1,979 

14.8 %

2.0 %

1,578 

1,564 

1,441 

0.9 %

8.5 %

1,059  $

1,125  $

1,187 

(5.9)%

(5.2)%

2.08  $

2.26  $

2.35 

(8.0)%

(3.8)%

0.86  $

0.78  $

0.70 

10.3 %

11.4 %

In countries with currencies other than the U.S. dollar, revenues and expenses
are translated using monthly average exchange rates. Impacts on our revenues
less  transaction-based  expenses  and  operating  income  associated  with
fluctuations in foreign currency are discussed in more detail under “Item 7A.
Quantitative and Qualitative Disclosures about Market Risk.”

37

 
 
 
 
 
The following chart summarizes our ARR (in millions):

The ARR chart includes:

▪

▪

Proprietary  market  data  subscriptions  and  annual  listing  fees
within  our  Data  &  Listing  Services  business,  index  data
subscriptions  and  guaranteed  minimum  on  futures  contracts
within  our  Index  business  and  subscription  contracts  under  our
Workflow & Insights business.
SaaS  subscription  and  support  contracts  related  to  Verafin,
surveillance,  market  technology,  AxiomSL,  Calypso  and  trade
management services, excluding one-time service requests.

The  following  chart  summarizes  our  quarterly  annualized  SaaS  revenues  for
Solutions,  which  comprises  our  Capital  Access  Platforms  and  Financial
Technology segments, for December 31, 2023, 2022 and 2021 (in millions):

ARR  for  a  given  period  is  the  current  annualized  value  derived  from
subscription  contracts  with  a  defined  contract  value.  This  excludes  contracts
that  are  not  recurring,  are  one-time  in  nature,  or  where  the  contract  value
fluctuates  based  on  defined  metrics.  ARR  is  currently  one  of  our  key
performance  metrics  to  assess  the  health  and  trajectory  of  our  recurring
business.  ARR  does  not  have  any  standardized  definition  and  is  therefore
unlikely  to  be  comparable  to  similarly  titled  measures  presented  by  other
companies.  ARR  should  be  viewed  independently  of  revenue  and  deferred
revenue and is not intended to be combined with or to replace either of those
items. For Adenza recurring revenue contracts, the amount included in ARR is
consistent  with  the  amount  that  we  invoice  the  customer  during  the  current
period.  Additionally,  for  Adenza  recurring  revenue  contracts  that  include
annual values that increase over time, we include in ARR only the annualized
value of components of the contract that are considered active as of the date of
the ARR calculation. We do not include the future committed increases in the
contract value as of the date of the ARR calculation. ARR is not a forecast and
the active contracts at the end of a reporting period used in calculating ARR
may or may not be extended or renewed by our customers.

38

Segment Operating Results

CAPITAL ACCESS PLATFORMS

The following table presents our revenues by segment:

The  following  table  presents  revenues  from  our  Capital  Access  Platforms
segment:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

Year Ended December 31,

Percentage Change

(in millions)

2023

2022

2021

2023 vs. 2022 2022 vs. 2021

Capital Access
Platforms
Financial
Technology
Market
Services, net
Other revenues
Total revenues
less
transaction-
based
expenses

$1,770

$1,682

$1,566

5.2 %

7.4 %

1,099 

987 
39 

864 

988 
48 

772 

27.2 %

11.9 %

1,005 
77 

(0.1)%
(1.7)%
(18.8)% (37.7)%

Data & Listing
Services
Index
Workflow &
Insights
Total Capital
Access
Platforms

(in millions)

$

749  $
528 

727  $
486 

493 

469 

678 
459 

429 

3.0 %
8.6 %

7.2 %
5.9 %

5.1 %

9.3 %

$

1,770  $

1,682  $

1,566 

5.2 %

7.4 %

$

3,895  $

3,582  $

3,420 

8.7 %

4.7 %

Data & Listing Services Revenues

The  following  chart  presents  our  Capital  Access  Platforms,  Financial
Technology  and  Market  Services  segments  as  a  percentage  of  our  total
expenses. 
revenues, 

transaction-based 

less 

The  following  table  presents  key  drivers  from  our  Data  &  Listing  Services
business:

IPOs
The Nasdaq Stock Market - operating
companies
The Nasdaq Stock Market - SPACs
Exchanges that comprise Nasdaq
Nordic and Nasdaq Baltic
Total new listings
The Nasdaq Stock Market
Exchanges that comprise Nasdaq
Nordic and Nasdaq Baltic
Number of listed companies
The Nasdaq Stock Market
Exchanges that comprise Nasdaq
Nordic and Nasdaq Baltic

Year Ended December 31,

2023

2022

2021

103 
27 

7 

330 

23 

87 
74 

38 

366 

63 

319
433

174

1,000 

207

4,044 

4,230 

4,178 

1,218 

1,251 

1,235 

As of December 31,

2023

2022

2021

ARR (in millions)

$

682  $

664  $

627 

In the tables above:

• Number of total listed companies on The Nasdaq Stock Market for the years
ended December 31, 2023, 2022 and 2021 included 600, 528 and 441 ETPs,
respectively.

• IPOs,  new  listings  (which  includes  IPOs)  and  total  listed  companies  for
exchanges  that  comprise  Nasdaq  Nordic  and  Nasdaq  Baltic  represent
companies  listed  on  the  Nasdaq  Nordic  and  Nasdaq  Baltic  exchanges  and
companies on the alternative markets of Nasdaq First North.

39

 
 
 
 
 
 
 
 
Data  &  Listing  Services  revenues  increased  in  2023  compared  with  2022
primarily  due  to  an  increase  in  proprietary  data  revenues  driven  largely  by
higher international demand and annual listing fee growth, partially offset by
lower initial listings fees.

Index Revenues

The following table presents key drivers from our Index business:

As of or 
Three Months Ended December 31,

2023

2022

2021

Number of licensed ETPs
TTM change in period end ETP AUM tracking Nasdaq
indices (in billions)
Beginning balance

388 

$

Net appreciation (depreciation)
Net impact of ETP sponsor
switches
Net inflows
Ending balance
Quarterly average ETP AUM
tracking Nasdaq indices (in billions) $
$
ARR

$

379 

362

424  $
(142)

(1)
34 
315  $

326  $
68  $

359 
83 

(92)
74 
424 

400 
67 

315  $
128 

(1)
31 
473  $

436  $
72  $

In the table above, TTM represents trailing twelve months.

Index revenues increased in 2023 compared with 2022 primarily due to higher
AUM in exchange traded products linked to Nasdaq indices.

Workflow & Insights Revenues

The  following  table  presents  key  drivers  from  our  Workflow  &  Insights
business:

As of or
Three Months Ended December 31

2023

2022

(in millions)

2021

FINANCIAL TECHNOLOGY

The  following  table  presents  revenues  from  our  Financial  Technology
segment:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions)

Financial Crime
Management
Technology
Regulatory
Technology
Capital Markets
Technology
Total Financial
Technology

$

223  $

176  $

104 

26.7 %

69.2 %

212 

664 

130 

558 

$

1,099  $

864  $

127 

541 

772 

63.1 %

2.4 %

19.0 %

3.1 %

27.2 %

11.9 %

Financial Crime Management Technology Revenues

The  following  table  presents  key  drivers  for  Financial  Crime  Management
Technology business:

As of or 
Twelve Months Ended December 31,

2023

2022

(in millions)

2021

ARR
Quarterly annualized SaaS
revenues

$

226  $

182  $

226 

182 

149 

149 

Financial  Crime  Management  Technology  revenues  increased  in  2023
compared  with  2022  and  2022  compared  with  2021  due  to  an  increase  in
demand related to new sales to existing clients and new customer acquisitions.
The 2022 increase was also driven by a $28 million purchase price adjustment
from the Verafin acquisition on deferred revenue in 2021 and the inclusion of
a full year of Verafin revenues in 2022.

ARR
Quarterly annualized SaaS revenues

$

481  $
411 

458  $
388 

417 
356 

Regulatory Technology Revenues

The following table presents key drivers for Regulatory Technology business:

Workflow & Insights revenues increased in 2023 compared with 2022 due to
an increase in both analytics and corporate solutions revenues. The increase in
analytics  revenues  was  primarily  due  to  the  growth  in  our  eVestment  and
Solovis  product  offerings.  The  increase  in  our  corporate  solutions  revenues
was primarily due to continued demand for our ESG solutions.

As of or 
Twelve Months Ended December 31,

2023

2022

(in millions)

2021

ARR
Quarterly annualized SaaS
revenues

$

325  $

130  $

165 

116 

120 

104 

Regulatory  Technology  revenues  increased  in  2023  compared  with  2022
primarily due to the inclusion of revenues from our acquisition of Adenza and
strong  performance  from  our  surveillance  offerings  in  new  sales  to  existing
clients  and  new  customer  acquisitions.  The  strong  performance  of  our
surveillance  offerings  was  also  the  key  driver  of  the  increase  in  2022
compared with 2021.

40

 
 
 
 
Capital Markets Technology Revenues

The  following  table  presents  key  drivers  for  Capital  Markets  Technology
business:

ARR
Quarterly annualized SaaS
revenues

As of or 
Three Months Ended December 30,

2023

2022

(in millions)

2021

$

799  $

499  $

475 

108 

39 

31 

Capital Markets Technology revenues increased in 2023 compared with 2022
and 2022 compared with 2021. The increase in 2023 was primarily due to the
inclusion  of  revenues  from  our  acquisition  of  Adenza,  higher  trade
management  services  revenues  mainly  driven  by  demand  for  colocation  and
connectivity  services  and  higher  market  technology  revenues  due  to  higher
support revenues and higher professional services fees. The increase in 2022
was  primarily  due  to  higher  trade  management  services  revenues  associated
with  increased  demand  for  connectivity  services,  partially  offset  by  lower
market technology revenues. The decrease in market technology revenues in
2022 was due to the successful completion of long-term contracts in 2021 and
the  unfavorable  impact  of  changes  in  foreign  exchange  rates  of  $10  million,
partially offset by growth in SaaS-based revenues.

MARKET SERVICES

The following table presents revenues from our Market Services segment:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

Market Services $
Transaction-based expenses:

3,156  $

3,632  $

3,471 

(13.1)%

4.6 %

(in millions)

Transaction
rebates
Brokerage,

clearance and
exchange fees

Total Market
Services, net

(1,838)

(2,092)

(2,168)

(12.1)%

(3.5)%

(331)

(552)

(298)

(40.0)%

85.2 %

$

987  $

988  $

1,005 

(0.1)%

(1.7)%

Our Market Services segment includes equity derivatives trading, cash equity
trading,  Nordic  fixed  income  trading  &  clearing,  U.S.  Tape  plans  and  other
revenues.  The  following  tables  present  net  revenues  by  product  from  our
Market Services segment:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions)

$

U.S. Equity
Derivative
Trading
Cash Equity
Trading
U.S. Tape
plans
Other
Total Market
Services, net $

374  $

371  $

397 

141 
75 

397 

149 
71 

343 

429 

155 
78 

0.8 %

8.2 %

— %

(7.5)%

(5.4)%
5.6 %

(3.9)%
(9.0)%

987  $

988  $

1,005 

(0.1)%

(1.7)%

In  the  table  above,  Other  includes  Nordic  fixed  income  trading  &  clearing,
Nordic derivatives and Canadian cash equities trading.

U.S. Equity Derivative Trading

The  following  tables  present  total  revenues,  transaction-based  expenses,  and
total revenues less transaction-based expenses as well as key drivers from our
U.S. Equity Derivative Trading business:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions)

U.S. Equity
Derivative
Trading
Revenues

$

1,257  $

1,252  $

1,367 

0.4 %

(8.4)%

Section 31 fees

55 

89 

32 

(38.2)%

178.1 %

Transaction-based expenses:
Transaction
rebates

(879)

Section 31 fees
Brokerage and
clearance fees

U.S. Equity
derivative
trading
revenues, net

(55)

(4)

(878)

(89)

(3)

(1,018)

0.1 %

(13.8)%

(32)

(6)

(38.2)%

178.1 %

33.3 %

(50.0)%

$

374  $

371  $

343 

0.8 %

8.2 %

in 

Section 31 fees are recorded as U.S. equity derivative and cash equity trading
revenues  with  a  corresponding  amount  recorded 
transaction-based
expenses. We are assessed these fees from the SEC and pass them through to
our customers in the form of incremental fees. Pass-through fees can increase
or  decrease  due  to  rate  changes  by  the  SEC,  our  percentage  of  the  overall
industry  volumes  processed  on  our  systems,  and  differences  in  actual  dollar
value traded. Section 31 fees decreased in 2023 compared with 2022 primarily
due to lower average SEC fee rates. Since the amount recorded in revenues is
equal to the amount recorded as Section 31 fees, there is no impact on our net
revenues.

41

 
 
 
 
 
 
 
 
 
 
 
 
U.S. equity options
Total industry average daily

volume (in millions)

Nasdaq PHLX matched market

share

The Nasdaq Options Market

matched market share

Nasdaq BX Options matched

market share

Nasdaq ISE Options matched

market share

Nasdaq GEMX Options matched

market share

Nasdaq MRX Options matched

market share

Total matched market share

executed on Nasdaq’s exchanges

Year Ended December 31,

2023

2022

2021

40.4 

38.2 

37.2 

11.3 %

11.6 %

12.4 %

6.1 %

3.3 %

5.9 %

2.4 %

2.0 %

8.0 %

2.8 %

5.7 %

2.3 %

1.6 %

8.1 %

1.4 %

6.6 %

4.3 %

1.6 %

31.0 %

32.0 %

34.4 %

U.S. equity derivative trading revenues, transaction rebates, in which we credit
a  portion  of  the  execution  charge  to  the  market  participant,  and  U.S.  equity
derivative 
transaction-based  expenses  remained
relatively  flat  in  2023  compared  with  2022  primarily  due  to  higher  industry
trading  volumes,  partially  offset  by  lower  overall  matched  market  share
executed on Nasdaq’s exchanges and lower gross capture rate.

trading  revenues 

less 

Cash Equity Trading Revenues

The  following  tables  present  total  revenues,  transaction-based  expenses,  and
total revenues less transaction-based expenses as well as key drivers and other
metrics from our Cash Equity Trading business:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions)

Cash Equity
Trading
Revenues

$ 1,355  $

1,605 

1,578 

(15.6)%

1.7 %

Section 31 fees

Transaction-
based expenses:  
Transaction
rebates

Section 31 fees

Brokerage and
clearance fees

Cash equity
trading
revenues, net

253 

436 

229 

(42.0)%

90.4 %

(939)

(1,184)

(1,118)

(20.7)%

5.9 %

(253)

(436)

(229)

(42.0)%

90.4 %

(19)

(24)

(31)

(20.8)%

(22.6)%

$

397  $

397  $

429 

— %

(7.5)%

See the discussion in "U.S. Equity Derivative Trading" for an explanation of
Section 31 fees for 2023 as compared to 2022. Since the amount recorded in
revenues is equal to the amount recorded as Section 31 fees, there is no impact
on our net revenues.

Year Ended December 31,

2023

2022

2021

Total U.S.-listed securities
Total industry average daily
share volume (in billions)
Matched share volume (in
billions)
The Nasdaq Stock Market
matched market share
Nasdaq BX matched market
share
Nasdaq PSX matched market
share
Total matched market share
executed on Nasdaq’s
exchanges
Market share reported to the
FINRA/Nasdaq Trade
Reporting Facility

Total market share

11.0 

455.6 

11.9 

522.8 

11.4 

491.9 

15.8 %

16.2 %

15.8 %

0.4 %

0.3 %

0.5 %

0.8 %

0.6 %

0.7 %

16.5 %

17.5 %

17.1 %

36.7 %
53.2 %

35.2 %
52.7 %

34.9 %
52.0 %

Nasdaq Nordic and Nasdaq Baltic securities
Average daily number of
equity trades executed on
Nasdaq’s exchanges
Total average daily value of
shares traded (in billions)
Total market share executed
on Nasdaq’s exchanges

666,411

$

4.5 

71.0 %

908,813

1,036,523 

$

5.4 

$

6.4 

71.5 %

76.9 %

In the tables above, total market share includes transactions executed on The
Nasdaq Stock Market’s, Nasdaq BX’s and Nasdaq PSX’s systems plus trades
reported through the FINRA/Nasdaq Trade Reporting Facility.

Cash equity trading revenues decreased in 2023 compared with 2022 primarily
due  to  lower  industry  trading  volumes,  lower  overall  U.S.  matched  market
share executed on Nasdaq’s exchanges, as well as lower gross capture rates.

Cash equity trading revenues less transaction-based expenses remained flat in
2023  compared  with  2022  primarily  due  to  lower  industry  trading  volumes
and  lower  overall  U.S.  matched  market  share  executed  on  Nasdaq’s
exchanges, partially offset by higher U.S. capture rate.

Transaction rebates decreased in 2023 compared with 2022. For The Nasdaq
Stock Market and Nasdaq PSX, we credit a portion of the per share execution
charge  to  the  market  participant  that  provides  the  liquidity,  and  for  Nasdaq
BX,  we  credit  a  portion  of  the  per  share  execution  charge  to  the  market
participant  that  takes  the  liquidity.  The  decrease  was  primarily  due  to  lower
rebate capture rate, lower U.S.

42

 
 
 
 
 
 
 
 
industry volumes, and lower U.S. matched market share executed on Nasdaq's
exchanges.

U.S. Tape Plans

The following table presents revenues from our U.S. Tape plans business:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions)

U.S. Tape
plans

$

141  $

149  $

155 

(5.4)%

(3.9)%

U.S.  Tape  plans  revenues  decreased  in  2023  compared  with  2022  primarily
due to lower market share and usage.

Other

Other  includes  Nordic  fixed  income  trading  and  clearing,  Nordic  derivatives
and Canadian cash equities trading. The following tables present revenue and
a key driver from our Other business:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions)

Other

$

75  $

71  $

78 

5.6 %

(9.0)%

In  the  table  above,  other  includes  transaction  rebates  of  $20  million,
$30 million, and $32 million in 2023, 2022, and 2021 respectively.

Year Ended December 31,

2023

2022

2021

Nasdaq Nordic and Nasdaq Baltic options and futures
Total average daily volume of options

and futures contracts

301,320

296,626

287,182 

In  the  tables  above,  Nasdaq  Nordic  and  Nasdaq  Baltic  total  average  daily
volume  of  options  and  futures  contracts  include  Finnish  option  contracts
traded  on  Eurex  for  which  Nasdaq  and  Eurex  have  a  revenue  sharing
arrangement.

Other  revenues  increased  in  2023  compared  with  2022  primarily  due  to
increased  revenues  in  our  Nordic  derivatives  trading,  higher  collateral
management  services  revenues,  partially  offset  by  lower  revenue  from
Canadian cash equities trading.

OTHER REVENUES

For  the  years  ended  December  31,  2023,  2022  and  2021,  other  revenues
include revenues related to our European power trading and clearing business,
following our announcement in June 2023 to sell this business to the European
Energy  Exchange,  subject  to  regulatory  approval.  Prior  to  June  2023,  these
revenues were included in our Market Services and Capital Access Platforms
segments. Also for the years ended December 31, 2023, 2022 and 2021, other
revenues include a transitional services agreement associated with a divested
business.  For  the  year  ended  December  31,  2022  and  2021,  other  revenues
also include

revenues  related  to  our  Nordic  broker  services  business  for  which  we
completed  the  wind-down  in  June  2022.  Prior  to  June  2022,  these  revenues
were  included  in  our  Market  Services  segment.  Additionally,  for  the  year
ended  December  31,  2021,  other  revenues  include  revenues  associated  with
the  NPM  business  which  we  contributed  in  July  2021  to  a  standalone,
independent company, of which we own the largest minority interest, together
with a consortium of third-party financial institutions. Prior to July 2021, these
revenues were included in our Capital Access Platforms segment.

EXPENSES

Operating Expenses

The following table presents our operating expenses:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs.
2022

2022 vs.
2021

(in millions)

$

1,082  $

1,003  $

938 

7.9%

6.9%

128 

140 

144 

(8.6)%

(2.8)%

233 
129 

113 

47 

323 
34 

148 
80 

207 
104 

125 

51 

258 
33 

82 
15 

186 
109 

12.6%
24.0%

11.3%
(4.6)%

85 

(9.6)%

47.1%

57 

(7.8)%

(10.5)%

278 
64 

87 
31 

25.2%
3.0%

80.5%
433.3%

(7.2)%
(48.4)%

(5.7)%
(51.6)%

$

2,317  $

2,018  $

1,979 

14.8%

2.0%

Compensation and
benefits
Professional and
contract services
Computer operations
and data
communications
Occupancy
General, administrative
and other
Marketing and
advertising
Depreciation and
amortization
Regulatory
Merger and strategic
initiatives
Restructuring charges
Total operating
expenses

The  increase  in  compensation  and  benefits  expense  for  the  year  ended
December  31,  2023  compared  with  the  same  period  in  2022  was  primarily
driven by increased headcount. The increase in the year ended December 31,
2023 was partially offset by a favorable impact from foreign exchange rates of
$12 million.

Headcount, 
including  employees  of  non-wholly  owned  consolidated
subsidiaries,  increased  to  8,525  employees  as  of  December  31,  2023  from
6,377 as of December 31, 2022, primarily due to our acquisition of Adenza.

Professional and contract services expense decreased in 2023 compared with
2022 primarily due to reduced consulting costs and reduced legal fees.

Computer  operations  and  data  communications  expense  increased  in  2023
compared  with  2022  primarily  due  to  higher  costs  related  to  our  cloud
initiatives.

43

 
 
 
 
 
 
 
 
 
 
 
 
Occupancy expense increased in 2023 compared with 2022 primarily due to a
review of our real estate and facility capacity requirements due to our new and
evolving work models initiated in the first quarter of 2023. As a result of this
ongoing  review,  for  the  year  ended  December  31,  2023,  we  recorded
$18  million  in  impairment  charges  and  exit  related  costs  following  the
abandonment of leased office space.

General,  administrative  and  other  expense  decreased  in  2023  compared  with
the  same  period  in  2022  primarily  due  to  an  insurance  recovery  related  to  a
legal matter in 2023 and a loss on extinguishment of debt recorded in 2022.

Marketing  and  advertising  expense  decreased  in  2023  compared  with  2022
primarily due to lower client incentives resulting from lower IPO activity.

Depreciation and amortization expense increased in 2023 compared with 2022
primarily  due  to  an  increase  in  amortization  due  to  the  intangible  assets
acquired as part of the Adenza acquisition.

Regulatory expense remained relatively flat in 2023 compared with 2022.

We have pursued various strategic initiatives and completed acquisitions and
divestitures in recent years, which have resulted in expenses which would not
have  otherwise  been  incurred.  These  expenses  generally  include  integration
costs, as well as legal, due diligence and other third-party transaction costs and
vary  based  on  the  size  and  frequency  of  the  activities  described  above.  The
increase for the year ended December 31, 2023 compared with 2022 primarily
reflects higher expenses related to the Adenza acquisition.

Restructuring  charges  increased  in  2023  compared  with  2022  as  a  result  of
charges from our 2022 divisional alignment program as well as the launch of
our  2023  Adenza  restructuring  program.  See  Note  20,  “Restructuring
Charges,”  to  the  consolidated  financial  statements  for  further  discussion.  By
2025, we expect to achieve benefits of the 2022 divisional alignment program
through  combined  annual  run-rate  operating  efficiencies  and  revenue
synergies  of  approximately  $30  million  annually.  We  expect  to  achieve  $80
million  of  net  expense  synergies  two  years  following  the  closing  of  the
Adenza acquisition.

Non-operating Income and Expenses

The following table presents our non-operating income and expenses:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions)

$

115  $
(284)

7  $

(129)

1 
(125)

1,542.9 %
120.2 %

600.0 %
3.2 %

(169)

(122)

(124)

38.5 %

(1.6)%

— 

(1)

— 

2 

84 

81 

— %

(100.0)%

(150.0)%

(97.5)%

(7)

31 

52 

(122.6)%

(40.4)%

$

(177) $

(89) $

93 

98.9 %

(195.7)%

Interest income
Interest expense
Net interest
expense
Net gain on
divestiture of
business
Other income
(loss)

Net income (loss)
from
unconsolidated
investees
Total non-
operating income
(expenses)

The following table presents our interest expense:

Year Ended December 31,

Percentage Change

2023

2022

2021

2023 vs. 2022

2022 vs. 2021

(in millions)

272  $

120  $

115 

126.7 %

4.3 %

9 
3 
284  $

7 
2 
129  $

7 
3 
125 

28.6 %
50.0 %

120.2 %

— %
(33.3)%

3.2 %

$

Interest expense
on debt
Accretion of debt
issuance costs
and debt
discount
Other fees
Interest expense $

Interest  income  increased  in  2023  compared  with  2022  primarily  due  to  a
higher  average  cash  balance  during  the  period  between  the  issuance  of  the
senior unsecured notes in June 2023 and the closing of the Adenza acquisition,
and an increase in interest rates.

Interest expense increased in 2023 compared with 2022 primarily due to debt
issued in June 2023 to finance the Adenza acquisition as well as an increase in
interest  rates.  See  “Financing  of  the  Adenza  Acquisition,”  of  Note  9,  “Debt
Obligations,” to the consolidated financial statements for further discussion.

The net gain on divestiture of business in 2021 relates to the sale of our U.S.
Fixed  Income  business,  which  was  part  of  our  FICC  business  within  our
Market  Services  segment.  We  recognized  a  pre-tax  gain  on  the  sale  of  $84
million, net of disposal costs.

44

 
 
 
 
 
 
 
 
Other  income  (loss)  primarily  represents  realized  and  unrealized  gains  and
losses from strategic investments related to our corporate venture program.

Net income (loss) from unconsolidated investees decreased in 2023 compared
with 2022 primarily due to lower income recognized from our equity method
investments in OCC and NPM. See “Equity Method Investments,” of Note 6,
“Investments,” to the consolidated financial statements for further discussion.

Tax Matters

The following table presents our income tax provision and effective tax rate:

Year Ended December 31,

Percentage Change

2023

2022

(in millions)

2021

2023 vs. 2022 2022 vs. 2021

Income tax
provision
Effective tax
rate

$

344

$

352

$

347 

(2.3)%

1.4 %

24.6 %

23.9 %

22.6 %

For further discussion of our tax matters, see Note 17, “Income Taxes,” to the
consolidated financial statements.

NON-GAAP FINANCIAL MEASURES

information 

this  non-GAAP 

In  addition  to  disclosing  results  determined  in  accordance  with  U.S.  GAAP,
we also provide non-GAAP net income attributable to Nasdaq and non-GAAP
diluted earnings per share in this Annual Report on Form 10-K. Management
uses 
internally,  along  with  U.S.  GAAP
information,  in  evaluating  our  performance  and  in  making  financial  and
operational decisions. We believe our presentation of these measures provides
investors  with  greater  transparency  and  supplemental  data  relating  to  our
financial  condition  and  results  of  operations.  In  addition,  we  believe  the
presentation  of  these  measures  is  useful  to  investors  for  period-to-period
comparisons of our ongoing operating performance.

These measures are not in accordance with, or an alternative to, U.S. GAAP,
and may be different from non-GAAP measures used by other companies. In
addition, other companies, including companies in our industry, may calculate
such  measures  differently,  which  reduces  their  usefulness  as  comparative
measures.  Investors  should  not  rely  on  any  single  financial  measure  when
evaluating our business. This non-GAAP information should be considered as
supplemental  in  nature  and  is  not  meant  as  a  substitute  for  our  operating
results  in  accordance  with  U.S.  GAAP.  We  recommend  investors  review  the
U.S. GAAP financial measures included in this Annual Report on Form 10-K,
including  our  consolidated  financial  statements  and  the  notes  thereto.  When
viewed  in  conjunction  with  our  U.S.  GAAP  results  and  the  accompanying
reconciliation,  we  believe  these  non-GAAP  measures  provide  greater
transparency  and  a  more  complete  understanding  of  factors  affecting  our
business than U.S. GAAP measures alone.

We  understand  that  analysts  and  investors  regularly  rely  on  non-GAAP
financial measures, such as non-GAAP net income attributable to Nasdaq and
non-GAAP  diluted  earnings  per  share,  to  assess  operating  performance.  We
use  non-GAAP  net  income  attributable  to  Nasdaq  and  non-GAAP  diluted
earnings per share because they highlight trends more clearly in our business
that  may  not  otherwise  be  apparent  when  relying  solely  on  U.S.  GAAP
financial  measures,  since  these  measures  eliminate  from  our  results  specific
financial items that have less bearing on our ongoing operating performance.
We believe that excluding the following items from the non-GAAP net income
attributable  to  Nasdaq  provides  a  more  meaningful  analysis  of  Nasdaq’s
ongoing  operating  performance  and  comparisons  in  Nasdaq’s  performance
between periods:

• Amortization expense of acquired intangible assets: We amortize intangible
assets  acquired  in  connection  with  various  acquisitions.  Intangible  asset
amortization  expense  can  vary  from  period  to  period  due  to  episodic
acquisitions  completed,  rather  than  from  our  ongoing  business  operations.
As  such,  if  intangible  asset  amortization  is  included  in  performance
measures, it is more difficult to assess the day-to-day operating performance
of  the  businesses  and  the  relative  operating  performance  of  the  businesses
between periods.

• Merger and strategic initiatives expense: We have pursued various strategic
initiatives  and  completed  acquisitions  and  divestitures  in  recent  years  that
have  resulted  in  expenses  which  would  not  have  otherwise  been  incurred.
The frequency and the amount of such expenses vary significantly based on
the size, timing and complexity of the transaction. These expenses primarily
include  integration  costs,  as  well  as  legal,  due  diligence  and  other  third-
party transaction costs. The increase for the year ended December 31, 2023
compared to 2022 primarily reflects costs related to the Adenza acquisition.

• Restructuring charges: In the fourth quarter of 2023, following the closing
of  the  Adenza  acquisition,  our  management  approved,  committed  to  and
initiated  a  restructuring  program,  “Adenza  Restructuring”  to  optimize  our
efficiencies  as  a  combined  organization.  In  October  2022,  following  our
September 2022 announcement to realign our segments and leadership, we
initiated  a  divisional  alignment  program  with  a  focus  on  realizing  the  full
potential  of  this  structure.  In  2019,  we  initiated  the  transition  of  certain
technology platforms to advance our strategic opportunities as a technology
and  analytics  provider  and  continue  the  realignment  of  certain  business
areas.  The  2019  restructuring  plan  was  completed  in  June  2021.  See  Note
20,  “Restructuring  Charges,”  to  the  consolidated  financial  statements  for
further  discussion  of  our  2023  Adenza  restructuring  program,  our  2022
divisional alignment program and our 2019 restructuring plan.

45

• Net  loss  (income)  from  unconsolidated  investees:  We  exclude  our  share  of
the  earnings  and  losses  of  our  equity  method  investments,  primarily  our
equity interest in OCC and NPM. This provides a more meaningful analysis
of  Nasdaq’s  ongoing  operating  performance  or  comparisons  in  Nasdaq’s
performance between periods. See “Equity Method Investments,” of Note 6,
“Investments,” 
the  consolidated  financial  statements  for  further
discussion.

to 

• Other  items:  We  have  excluded  certain  other  charges  or  gains,  including
certain  tax  items,  that  are  the  result  of  other  non-comparable  events  to
measure operating performance. We believe the exclusion of such amounts
allows management and investors to better understand the ongoing financial
results of Nasdaq. Other significant items include:

◦ Lease  asset  impairments:  For  2023,  this  includes  impairment  charges
related  to  our  operating  lease  assets  and  leasehold  improvements
associated with vacating certain leased office space, which are recorded in
occupancy  and  depreciation  and  amortization  expense 
in  our
Consolidated Statements of Income.

◦ Extinguishment  of  debt:  For  2022  and  2021  this  includes  a  loss  on
extinguishment  of  debt,  which  is  recorded  under  general,  administrative
and other expense in our Consolidated Statements of Income.

◦ Legal and regulatory matters: For 2023 and 2022, this includes accruals
related  to  certain  legal  matters.  For  2023,  these  charges  were  partially
offset by insurance recoveries related to certain legal matters. The charges
and related insurance recoveries are recorded in professional and contract
services  and  general,  administrative  and  other  expense 
the
Consolidated Statements of Income. For 2022 and 2021, this also includes
a charge related to an administrative fine imposed by the SFSA. related to
the  clearing  default  that  occurred  in  2018.  This  charge  was  included  in
regulatory expense in the Consolidated Statements of Income.

in 

◦ Net gain on divestiture of business: For 2021, this represents our pre-tax
net gain of $84 million on the sale of our U.S. Fixed Income business.

◦ Pension  settlement  charge:  For  2023,  we  terminated  our  U.S.  pension
plan  and  recorded  a  partial  settlement  charge  under  compensation  and
benefits  in  the  Consolidated  Statements  of  Income.  See  Note  10,
“Retirement  Plans,”  to  the  consolidated  financial  statements  for  further
discussion.

◦ Other  loss  (income):  For  2023,  this  includes  certain  financing  costs
related  to  the  Adenza  acquisition.  For  2023,  2022  and  2021  this  also
includes  net  gains  and  losses  from  strategic  investments  entered  into
through  our  corporate  venture  program,  which  are  included  in  other
income (loss) in our Consolidated Statements of Income.

• Significant  tax  items:  The  non-GAAP  adjustment  to  the  income  tax
provision  for  all  periods  primarily  includes  the  tax  impact  of  each  non-
GAAP adjustment. In addition, for the year ended December 31, 2021, the
non-GAAP  adjustment  to  the  income  tax  provision  includes  adjustments
related to return-to-provision.

The following tables present reconciliations between U.S. GAAP net income
attributable  to  Nasdaq  and  diluted  earnings  per  share  and  non-GAAP  net
income attributable to Nasdaq and diluted earnings per share:

Year Ended December 31,

2023

2022

2021

(in millions, except per share amounts)

$

1,059 

$

1,125 

$

1,187 

206 

148 
80 
25 
— 

7 
12 

— 
9 
21 
508 

(134)

374 

153 

170 

82 
15 
— 
16 

(29)
26 

— 
— 
2 
265 

(66)

199 

87 
31 
— 
33 

(52)
44 

(84)
— 
(82)
147 

(61)

86 

$

1,433 

$

1,324 

$

1,273 

24.6 %

23.9 %

22.6 %

0.4 %
25.0 %

0.1 %
24.0 %

1.7 %
24.3 %

508.4 

497.9 

505.1 

$

2.08 

$

2.26 

$

2.35 

0.74 

0.40 

0.17 

2.82 

$

2.66 

$

2.52 

U.S. GAAP net income
attributable to Nasdaq
Non-GAAP adjustments:
Amortization expense of
acquired intangible assets
Merger and strategic initiatives
expense
Restructuring charges
Lease asset impairments
Extinguishment of debt
Net loss (income) from
unconsolidated investees
Legal and regulatory matters
Net gain on divestiture of
business
Pension settlement charge
Other
Total non-GAAP adjustments
Total non-GAAP tax
adjustments

Total non-GAAP adjustments,
net of tax

Non-GAAP net income
attributable to Nasdaq

U.S. GAAP effective tax rate
Total adjustments from non-
GAAP tax rate

Non-GAAP effective tax rate

Weighted-average common shares
outstanding for diluted earnings
per share

U.S. GAAP diluted earnings per
share
Total adjustments from non-
GAAP net income

Non-GAAP diluted earnings per
share

$

46

 
LIQUIDITY AND CAPITAL RESOURCES

Repatriation of Cash

Historically,  we  have  funded  our  operating  activities  and  met  our
commitments  through  cash  generated  by  operations,  augmented  by  the
periodic  issuance  of  debt.  Currently,  our  cost  and  availability  of  funding
remain  healthy.  We  continue  to  prudently  assess  our  capital  deployment
strategy 
investments,  debt
repayments,  and  shareholder  return  activity,  including  share  repurchases  and
dividends.

through  balancing  acquisitions, 

internal 

We  expect  that  our  current  cash  and  cash  equivalents  combined  with  cash
flows  provided  by  operating  activities,  supplemented  with  our  borrowing
capacity  and  access  to  additional  financing,  including  our  revolving  credit
facility and our commercial paper program, provides us additional flexibility
to meet our ongoing obligations and the capital deployment strategic actions
described  above,  while  allowing  us  to  invest  in  activities  and  product
development that support the long-term growth of our operations.

Principal  factors  that  could  affect  the  availability  of  our  internally-generated
funds include:

•    deterioration of our revenues in any of our business segments;

•    changes in regulatory and working capital requirements; and

• an increase in our expenses.

Principal  factors  that  could  affect  our  ability  to  obtain  cash  from  external
sources include:

•        operating  covenants  contained  in  our  credit  facilities  that  limit  our  total

borrowing capacity;

•    credit rating downgrades, which could limit our access to additional debt;

•    a significant decrease in the market price of our common stock; and

•    volatility or disruption in the public debt and equity markets.

The following table summarizes selected measures of our liquidity and capital
resources:

Cash and cash equivalents
Financial investments
Working capital

$

Cash and Cash Equivalents

December 31, 2023

December 31, 2022

(in millions)
453  $
188 
71 

502 
181 
(231)

Cash and cash equivalents includes all non-restricted cash in banks and highly
liquid  investments  with  original  maturities  of  90  days  or  less  at  the  time  of
purchase.  The  balance  retained  in  cash  and  cash  equivalents  is  a  function  of
anticipated  or  possible  short-term  cash  needs,  prevailing  interest  rates,  our
investment  policy,  and  alternative  investment  choices.  As  of  December  31,
2023, our cash and cash equivalents of $453 million were primarily invested
in  money  market  funds,  commercial  paper,  municipal  bonds  and  bank
deposits.

Our  cash  and  cash  equivalents  held  outside  of  the  U.S.  in  various  foreign
subsidiaries totaled $236 million as of December 31, 2023 and $275 million as
of December 31, 2022. The remaining balance held in the U.S. totaled $217
million as of December 31, 2023 and $227 million as of December 31, 2022.

Cash Flow Analysis

The following table summarizes the changes in cash flows:

Net cash provided by (used in):
Operating activities
Investing activities
Financing activities

Year Ended December 31,

2023

2022

(in millions)

2021

$

1,696  $
(5,994)
4,220 

1,706  $
49 
1,036 

1,083 
(2,653)
1,418 

Net Cash Provided by Operating Activities

Net  cash  provided  by  operating  activities  primarily  consists  of  net  income
adjusted  for  certain  non-cash  items,  including  depreciation  and  amortization
expense, expense associated with share-based compensation, deferred income
taxes  and  the  effects  of  changes  in  working  capital.  Changes  in  working
capital include changes in accounts receivable and deferred revenue which are
impacted by the timing of customer billings and related collections from our
customers; accounts payable and accrued expenses due to timing of payments;
accrued personnel costs, which are impacted by employee performance targets
and the timing of payments related to employee bonus incentives; and Section
31 fees payable to the SEC, which is impacted by the changes in SEC fee rates
and the timing of collections from customers and payments to the SEC.

Net  cash  provided  by  operating  activities  decreased  $10  million  for  2023
compared with 2022, excluding the impact of the Adenza acquisition, which is
reflected  in  net  cash  provided  by  (used  in)  investing  activities.  The  decrease
was primarily driven by changes in our working capital and timing of various
payments  and  receipts  of  $(129)  million,  partially  offset  by  an  increase  of
$119 million driven by the increase in net income adjusted for certain noncash
operating  activities.  The  changes  in  working  capital  primarily  included  a
decrease  in  Section  31  fees  payable  to  the  SEC,  partially  offset  by  lower
receivables largely due to a decrease in Section 31 fees receivable as well as
timing of collection and an increase in accounts payable and accrued expenses
primarily due to an increase in our accrued interest payable from issuances of
senior  unsecured  notes  in  connection  with  the  Adenza  acquisition.  Non-cash
charges  in  2023  primarily  included  $323  million  of  depreciation  and
amortization and $122 million of share-based compensation.

Net Cash Provided by (Used in) Investing Activities

Net  cash  used  in  investing  activities  for  the  year  ended  December  31,  2023
primarily related to $5,766 million paid for the acquisition of Adenza, net of
cash and cash equivalents acquired, purchases of property and equipment of

47

 
 
 
 
$158 million, net purchases of investments related to default funds and margin
deposits of $74 million and $3 million from other investing activities, partially
offset by proceeds from the sales and redemptions of trading securities, net of
$7 million.

Net  cash  provided  by  investing  activities  for  the  year  ended  December  31,
2022 primarily related to net proceeds from sales and redemptions of default
funds and margin deposits of $211 million and proceeds of $33 million from
other  investing  activities,  partially  offset  by  purchases  of  property  and
equipment of $152 million and $41 million cash used for acquisitions, net of
cash and cash equivalents acquired.

Net Cash Provided by Financing Activities

Net  cash  provided  by  financing  activities  for  the  year  ended  December  31,
2023  primarily  related  to  $5,608  million  proceeds  from  issuances  of  senior
unsecured  notes  and  the  2023  Term  Loan,  in  connection  with  the  Adenza
acquisition,  net  of  debt  issuance  costs,  partially  offset  by  $441  million  of
dividend payments to our shareholders, $371 million from repayments of our
commercial  paper,  net,  $269  million  in  repurchases  of  common  stock  and
$260 million relating to partial repayment of the 2023 Term Loan.

Net  cash  provided  by  financing  activities  for  the  year  ended  December  31,
2022 primarily related to an increase in default funds and margin deposits of
$2,440 million, proceeds of $541 million from the issuances of long-term-debt
and proceeds of $238 million from the issuances of our commercial paper, net,
partially  offset  by  $1,097  million  related  to  the  repayment  of  our  2022  and
2024  Notes,  $383  million  of  dividend  payments  to  our  shareholders,  $325
million of repurchases of common stock pursuant to the ASR agreement and
$308 million in other repurchases of common stock.

See Note 4, “Acquisitions,” to the consolidated financial statements for further
discussion.

Regulatory Capital Requirements

Clearing Operations Regulatory Capital Requirements

We  are  required  to  maintain  minimum  levels  of  regulatory  capital  for  the
clearing  operations  of  Nasdaq  Clearing.  The  level  of  regulatory  capital
required to be maintained is dependent upon many factors, including market
conditions and creditworthiness of the counterparty. As of December 31, 2023,
our  required  regulatory  capital  of  $123  million  was  primarily  comprised  of
highly  rated  European  government  debt  securities  that  are  included  in
financial investments in the Consolidated Balance Sheets.

Broker-Dealer Net Capital Requirements

Our  broker-dealer  subsidiaries,  Nasdaq  Execution  Services,  NFSTX,  LLC,
and Nasdaq Capital Markets Advisory, are subject to regulatory requirements
intended  to  ensure  their  general  financial  soundness  and  liquidity.  These
requirements obligate these subsidiaries to comply with minimum net capital
requirements. As of December 31, 2023, the combined required minimum net
capital totaled $1 million and the combined excess capital totaled $27 million,
substantially  all  of  which  is  held  in  cash  and  cash  equivalents  in  the
Consolidated Balance Sheets. The required minimum net capital is included in
restricted cash and cash equivalents in the Consolidated Balance Sheets.

Nordic and Baltic Exchange Regulatory Capital Requirements

The entities that operate trading venues in the Nordic and Baltic countries are
each  subject  to  local  regulations  and  are  required  to  maintain  regulatory
capital  intended  to  ensure  their  general  financial  soundness  and  liquidity.  As
of  December  31,  2023,  our  required  regulatory  capital  of  $37  million  was
primarily  invested  in  European  government  bills  and  mortgage  bonds  and
Icelandic government bonds that are included in financial investments in the
Consolidated  Balance  Sheets  and  cash,  which  is  included  in  restricted  cash
and cash equivalents in the Consolidated Balance Sheets.

See  Note  9,  “Debt  Obligations,”  to  the  consolidated  financial  statements  for
further discussion of our debt obligations.

Other Capital Requirements

See “Share Repurchase Program,” and “Cash Dividends on Common Stock,”
of  Note  12,  “Nasdaq  Stockholders’  Equity,”  to  the  consolidated  financial
statements  for  further  discussion  of  our  share  repurchase  program  and  cash
dividends declared and paid on our common stock.

Financial Investments

Our financial investments totaled $188 million as of December 31, 2023 and
$181 million as of December 31, 2022. Of these securities, $168 million as of
December  31,  2023  and  $161  million  as  of  December  31,  2022  are  assets
primarily  utilized  to  meet  regulatory  capital  requirements,  mainly  for  our
clearing  operations  at  Nasdaq  Clearing.  See  Note  6,  “Investments,”  to  the
consolidated financial statements for further discussion.

We operate several other businesses which are subject to local regulation and
are required to maintain certain levels of regulatory capital. As of December
31, 2023, other required regulatory capital of $16 million, primarily related to
Nasdaq  Central  Securities  Depository,  was  primarily  invested  in  European
government  debt  securities  that  are  included  in  financial  investments  in  the
Consolidated Balance Sheets.

Equity and dividends

Share Repurchase Program

See “Share Repurchase Program,” of Note 12, “Nasdaq Stockholders’ Equity,”
to  the  consolidated  financial  statements  for  further  discussion  of  our  share
repurchase program.

48

Cash Dividends on Common Stock

The  following  table  presents  our  quarterly  cash  dividends  paid  per  common
share on our outstanding common stock:

First quarter
Second quarter
Third quarter
Fourth quarter

Total

2023

2022

$

$

0.20  $
0.22 
0.22 
0.22 
0.86  $

0.18 
0.20 
0.20 
0.20 
0.78 

See “Cash Dividends on Common Stock,” of Note 12, “Nasdaq Stockholders’
Equity,” to the consolidated financial statements for further discussion of the
dividends.

Debt Obligations

The following table summarizes our debt obligations by contractual maturity:

Maturity Date

December 31, 2023

December 31, 2022

Short-term debt:
Commercial paper

Total short-term debt
Long-term debt - senior unsecured notes:
June 2025
June 2026
June 2028
March 2029
February 2030
January 2031
February 2032
July 2033
February 2034
December 2040
April 2050
March 2052
August 2053
June 2063
November 2026

2025 Notes
2026 Notes
2028 Notes
2029 Notes
2030 Notes
2031 Notes
2032 Notes
2033 Notes
2034 Notes
2040 Notes
2050 Notes
2052 Notes
2053 Notes
2063 Notes
2023 Term Loan
2022 Revolving Credit

Facility
Total long-term debt

Total debt obligations

(in millions)

291  $
291  $

$
$

497 
499 
991 
658 
658 
645 
819 
674 
1,239 
644 
487 
541 
738 
738 
339 

664 
664 

— 
498 
— 
637 
637 
644 
— 
653 
— 
644 
486 
541 
— 
— 
— 

December 2027

(4)
10,163  $
10,454  $

$
$

(5)
4,735 
5,399 

49

For the year ended December 31, 2023, the weighted average interest rate on
our debt obligations was approximately 3.5%. This rate can fluctuate based on
changes  in  interest  rates  for  our  variable  rate  debts,  changes  in  foreign
currency  exchange  rates  and  changes  in  the  amount  and  duration  of
outstanding debt.

In December 2022, Nasdaq amended and restated its previously issued $1.25
billion  five-year  revolving  credit  facility,  with  a  new  maturity  date  of
December 16, 2027. In addition to the 2022 Revolving Credit Facility, we also
have  other  credit  facilities  primarily  to  support  our  Nasdaq  Clearing
operations  in  Europe,  as  well  as  to  provide  a  cash  pool  credit  line  for  one
subsidiary.  These  European  credit  facilities,  which  are  available  in  multiple
currencies, totaled $191 million as of December 31, 2023 and $184 million as
of December 31, 2022 in available liquidity, none of which was utilized.

Financing of the Adenza Acquisition

In  June  2023,  Nasdaq  issued  six  series  of  notes  for  total  proceeds  of  $5,016
million, net of debt issuance costs of $38 million, with various maturity dates
ranging  from  2025  to  2063.  During  the  second  half  of  2023,  we  incurred  an
additional $6 million in debt issuance costs, for a total net proceeds from the
issuance of the six series of notes of $5,010 million as of December 31, 2023.
The  net  proceeds  from  these  notes  were  used  to  finance  the  majority  of  the
cash consideration due in connection with the Adenza acquisition.

In  addition,  in  connection  with  the  financing  of  the  Adenza  acquisition,  we
entered into the 2023 Term Loan agreement. The 2023 Term Loan provided us
with the ability to borrow up to $600 million to finance a portion of the cash
consideration  for  the  Adenza  acquisition  and  other  amounts  incurred  in
connection with this transaction. Under the 2023 Term Loan, borrowings bear
interest on the principal amount outstanding at a variable interest rate based on
the SOFR plus an applicable margin that varies with Nasdaq’s debt rating. On
November  1,  2023,  we  borrowed  $599  million,  net  of  fees,  under  this  term
loan  towards  payment  of  the  cash  consideration  due  in  connection  with  the
Adenza acquisition. We made a partial repayment during the fourth quarter of
$260  million.  As  of  December  31,  2023,  we  had  $339  million  outstanding
under this term loan.

As of December 31, 2023, we were in compliance with the covenants of all of
our debt obligations.

See  Note  9,  “Debt  Obligations,”  to  the  consolidated  financial  statements  for
further discussion of our debt obligations.

 
 
 
Contractual Obligations and Contingent Commitments

Quantitative and Qualitative Disclosures About Market Risk

Nasdaq  has  contractual  obligations  to  make  future  payments  under  debt
obligations  by  contract  maturity,  minimum  rental  commitments  under  non-
cancelable operating leases and other obligations. The following table shows
these contractual obligations as of December 31, 2023:

Payments Due by Period

Total

<1 year

1-3 years

3-5 years

5+ years

$

16,759  $

714  $

2,103  $

1,651  $

12,291 

616 
442 
17,817  $

$

84 
92 
890  $

133 
130 
2,366  $

113 
92 
1,856  $

286 
128 
12,705 

(in millions)
Debt obligation by

contractual maturity

Operating lease
obligations

Purchase obligations

Total

In the preceding table:

• Debt obligations by contractual maturity include both principal and interest
obligations. As of December 31, 2023, an interest rate of 4.8% was used to
compute the amount of the contractual obligations for interest on the 2022
Revolving Credit Facility and 6.7% was used to compute the amount of the
contractual  obligations  for  interest  on  the  2023  Term  Loan.  For  our  Euro
denominated  notes  interest  is  calculated  on  an  actual  basis  while  all  other
debt is calculated on a 360-day basis at the contractual fixed rate multiplied
by  the  aggregate  principal  amount  as  of  December  31,  2023.  See  Note  9,
“Debt  Obligations,”  to  the  consolidated  financial  statements  for  further
discussion.

• Operating  lease  obligations  represent  our  undiscounted  operating  lease
liabilities  as  of  December  31,  2023,  as  well  as  legally  binding  minimum
lease  payments  for  leases  signed  but  not  yet  commenced.  See  Note  16,
“Leases,” to the consolidated financial statements for further discussion of
our leases.

• Purchase  obligations  primarily  represent  minimum  outstanding  obligations
due under software license agreements, of which the majority relates to our
multi-year AWS partnership contract.

Off-Balance Sheet Arrangements

For discussion of off-balance sheet arrangements see:

•        Note  15,  “Clearing  Operations,”  to  the  consolidated  financial  statements
for further discussion of our non-cash default fund contributions and margin
deposits received for clearing operations; and

•        Note  18,  “Commitments,  Contingencies  and  Guarantees,”  to  the

consolidated financial statements for further discussion of:

◦ Guarantees issued and credit facilities available;

◦ Other guarantees; and

◦ Routing brokerage activities.

As a result of our operating, investing and financing activities, we are exposed
to  market  risks  such  as  interest  rate  risk  and  foreign  currency  exchange  rate
risk.  We  are  also  exposed  to  credit  risk  as  a  result  of  our  normal  business
activities.

We  have  implemented  policies  and  procedures  to  measure,  manage,  monitor
and report risk exposures, which are reviewed regularly by management and
the  board  of  directors.  We  identify  risk  exposures  and  monitor  and  manage
such risks on a daily basis.

We  perform  sensitivity  analyses  to  determine  the  effects  of  market  risk
exposures. We may use derivative instruments solely to hedge financial risks
related to our financial positions or risks that are incurred during the normal
course  of  business.  We  do  not  use  derivative  instruments  for  speculative
purposes.

Interest Rate Risk

We are subject to the risk of fluctuating interest rates in the normal course of
business.  Our  exposure  to  market  risk  for  changes  in  interest  rates  relates
primarily  to  our  financial  investments  and  debt  obligations,  which  are
discussed below.

Financial Investments

As of December 31, 2023, our investment portfolio was primarily comprised
of highly rated European government debt securities, which pay a fixed rate of
interest. These securities are subject to interest rate risk and the fair value of
these  securities  will  decrease  if  market  interest  rates  increase.  If  market
interest  rates  were  to  increase  immediately  and  uniformly  by  a  hypothetical
100  basis  points  from  levels  as  of  December  31,  2023,  the  fair  value  of  this
portfolio would decline by $3 million.

Debt Obligations

As of December 31, 2023, substantially all of our debt obligations were fixed-
rate  obligations.  Interest  rates  on  certain  tranches  of  notes  are  subject  to
adjustment  to  the  extent  our  debt  rating  is  downgraded  below  investment
grade, as further discussed in Note 9, “Debt Obligations,” to the consolidated
financial  statements.  While  changes  in  interest  rates  will  have  no  impact  on
the  interest  we  pay  on  fixed-rate  obligations,  we  are  exposed  to  changes  in
interest  rates  as  a  result  of  the  borrowings  under  our  2022  Revolving  Credit
Facility,  our  commercial  paper  program  and  the  2023  Term  Loan  as  these
facilities have a variable interest rate. As of December 31, 2023, we have $291
million  outstanding  borrowings  under  our  commercial  paper  program  and
$339 million outstanding under the 2023 Term Loan. A hypothetical 100 basis
points increase in interest rates on our outstanding commercial paper and our
2023 Term Loan would increase our annual interest expense by approximately
$6 million based on borrowings as of December 31, 2023.

We  may  utilize  interest  rate  swap  agreements  to  achieve  a  desired  mix  of
variable and fixed rate debt.

50

Foreign Currency Exchange Rate Risk

We  are  subject  to  foreign  currency  exchange  rate  risk.  Our  primary
transactional  exposure  to  foreign  currency  denominated  revenues  less
transaction-based  expenses  and  operating  income  for  the  years  ended
December 31, 2023 and 2022 are presented in the following tables:

Euro

Swedish
Krona

Canadian
Dollar

Other Foreign
Currencies

U.S. Dollar

Total

(in millions, except currency rate)

Year Ended December 31, 2023
Average foreign
currency rate to
the U.S. dollar

1.081

0.094

0.741

#

N/A

N/A

6.6%

4.0%

0.8%

3.0%

85.6%

100.0%

10.7%

(3.8)%

(7.0)%

(8.3)%

108.4%

100.0%

$(26)

$(15)

$(3)

$(12)

$—

Percentage of
revenues less
transaction-based
expenses
Percentage of

operating income

Impact of a 10%

adverse currency
fluctuation on
revenues less
transaction-based
expenses

Impact of a 10%

adverse currency
fluctuation on
operating income

Our  investments  in  foreign  subsidiaries  are  exposed  to  volatility  in  currency
exchange  rates  through  translation  of  the  foreign  subsidiaries’  net  assets  or
equity to U.S. dollars. Substantially all of our foreign subsidiaries operate in
functional  currencies  other  than  the  U.S.  dollar.  The  financial  statements  of
these  subsidiaries  are  translated  into  U.S.  dollars  for  consolidated  reporting
using  a  current  rate  of  exchange,  with  net  gains  or  losses  recorded  in
accumulated  other  comprehensive  loss  within  stockholders’  equity  in  the
Consolidated Balance Sheets.

Our primary exposure to net assets in foreign currencies as of December 31,
2023 is presented in the following table:

$

Swedish Krona
Norwegian Krone
British Pound
Canadian Dollar
Australian Dollar
Euro

Net Assets

Impact of a 10% Adverse
Currency Fluctuation

(in millions)

3,012  $
144 
140 
102 
96 
60 

301 
14 
14 
10 
10 
6 

$(17)

$(6)

$(11)

$(13)

$—

In  the  table  above,  Swedish  Krona  includes  goodwill  of  $2,230  million  and
intangible assets, net of $498 million.

Euro

Swedish
Krona

Canadian
Dollar

Other Foreign
Currencies

U.S. Dollar

Total

Credit Risk

Year Ended December 31, 2022
Average foreign
currency rate to
the U.S. dollar

1.054

0.099

(in millions, except currency rate)

0.768

#

N/A

N/A

Percentage of
revenues less
transaction-based
expenses
Percentage of

operating income

Impact of a 10%

adverse currency
fluctuation on
revenues less
transaction-based
expenses

Impact of a 10%

adverse currency
fluctuation on
operating income

6.2%

5.1%

0.9%

3.2%

84.6%

100.0%

10.1%

(2.8)%

(5.9)%

(4.7)%

103.3%

100.0%

$(22)

$(18)

$(3)

$(12)

$—

$(16)

$(4)

$(9)

$(8)

$—

__________
#    Represents multiple foreign currency rates.
N/A    Not applicable.

The adverse impacts shown above should be viewed individually by currency
and not in aggregate due to the correlation between changes in exchanges rates
for certain currencies.

Credit  risk  is  the  potential  loss  due  to  the  default  or  deterioration  in  credit
quality  of  customers  or  counterparties.  We  are  exposed  to  credit  risk  from
third  parties,  including  customers,  counterparties  and  clearing  agents.  These
parties  may  default  on  their  obligations  to  us  due  to  bankruptcy,  lack  of
liquidity, operational failure or other reasons. We limit our exposure to credit
risk  by  evaluating  the  counterparties  with  which  we  make  investments  and
execute agreements. For our investment portfolio, our objective is to invest in
securities to preserve principal while maximizing yields, without significantly
increasing  risk.  Credit  risk  associated  with  investments  is  minimized
substantially  by  ensuring  that  these  financial  assets  are  placed  with
governments  which  have  investment  grade  ratings,  well-capitalized  financial
institutions and other creditworthy counterparties.

Our subsidiary, Nasdaq Execution Services, may be exposed to credit risk due
to the default of trading counterparties in connection with the routing services
it provides for our trading customers. System trades in cash equities routed to
other market centers for members of our cash equity exchanges are routed by
Nasdaq Execution Services for clearing to the NSCC. In this function, Nasdaq
Execution Services is to be neutral by the end of the trading day, but may be
exposed to intraday risk if a trade extends beyond the trading day and into the
next  day, 
to
counterparty  risk  in  the  period  between  accepting  the  trade  and  routing  it  to
the  clearinghouse.  In  this  interim  period,  Nasdaq  Execution  Services  is  not
novating like a clearing broker but instead is subject to the short-term risk of
counterparty failure before

leaving  Nasdaq  Execution  Services  susceptible 

thereby 

51

 
 
the  clearinghouse  enters  the  transaction.  Once  the  clearinghouse  officially
accepts the trade for novation, Nasdaq Execution Services is legally removed
from  trade  execution  risk.  However,  Nasdaq  has  membership  obligations  to
NSCC independent of Nasdaq Execution Services’ arrangements.

Pursuant  to  the  rules  of  the  NSCC  and  Nasdaq  Execution  Services’  clearing
agreement, Nasdaq Execution Services is liable for any losses incurred due to
a  counterparty  or  a  clearing  agent’s  failure  to  satisfy  its  contractual
obligations,  either  by  making  payment  or  delivering  securities.  Adverse
movements in the prices of securities that are subject to these transactions can
increase our credit risk. However, we believe that the risk of material loss is
limited,  as  Nasdaq  Execution  Services’  customers  are  not  permitted  to  trade
on margin and NSCC rules limit counterparty risk on self-cleared transactions
by  establishing  credit  limits  and  capital  deposit  requirements  for  all  brokers
that  clear  with  NSCC.  Historically,  Nasdaq  Execution  Services  has  never
incurred  a  liability  due  to  a  customer’s  failure  to  satisfy  its  contractual
obligations as counterparty to a system trade. Credit difficulties or insolvency,
or the perceived possibility of credit difficulties or insolvency, of one or more
larger  or  visible  market  participants  could  also  result  in  market-wide  credit
difficulties or other market disruptions.

We have credit risk related to transaction and subscription-based revenues that
are  billed  to  customers  on  a  monthly  or  quarterly  basis,  in  arrears.  Our
potential exposure to credit losses on these transactions is represented by the
receivable  balances  in  our  Consolidated  Balance  Sheets.  We  review  and
evaluate changes in the status of our counterparties’ creditworthiness. Credit
losses such as those described above could adversely affect our consolidated
financial position and results of operations.

We  also  are  exposed  to  credit  risk  through  our  clearing  operations  with
Nasdaq  Clearing.  See  Note  15,  “Clearing  Operations,”  to  the  consolidated
financial  statements  for  further  discussion.  Our  clearinghouse  holds  material
amounts  of  clearing  member  cash  deposits,  which  are  held  or  invested
primarily  to  provide  security  of  capital  while  minimizing  credit,  market  and
liquidity  risks.  While  we  seek  to  achieve  a  reasonable  rate  of  return,  we  are
primarily  concerned  with  preservation  of  capital  and  managing  the  risks
associated  with  these  deposits.  As  the  clearinghouse  may  pass  on  interest
revenues (minus costs) to the members, this could include negative or reduced
yield  due  to  market  conditions.  The  following  is  a  summary  of  the  risks
associated with these deposits and how these risks are mitigated.

• Liquidity Risk. Liquidity risk is the risk a clearinghouse may not be able to
meet its payment obligations in the right currency, in the right place and the
right  time.  To  mitigate  this  risk,  the  clearinghouse  monitors  liquidity
requirements  closely  and  maintains  funds  and  assets  in  a  manner  which
minimizes  the  risk  of  loss  or  delay  in  the  access  by  the  clearinghouse  to
such  funds  and  assets.  For  example,  holding  funds  with  a  central  bank
where  possible  or  investing  in  highly  liquid  government  debt  instruments
serves to reduce liquidity risks.

• Interest Rate Risk. Interest rate risk is the risk that interest rates rise causing
the  value  of  purchased  securities  to  decline.  If  we  were  required  to  sell
securities  prior  to  maturity,  and  interest  rates  had  risen,  the  sale  of  the
securities  might  be  made  at  a  loss  relative  to  the  latest  market  price.  Our
clearinghouse seeks to manage this risk by making short term investments
of  members’  cash  deposits.  In  addition,  the  clearinghouse  investment
guidelines  allow  for  direct  purchases  or  repurchase  agreements  with  short
dated  maturities  of  high  quality  sovereign  debt  (for  example,  European
government  and  U.S.  Treasury  securities),  central  bank  certificates  and
multilateral development bank debt instruments.

• Security  Issuer  Risk.  Security  issuer  risk  is  the  risk  that  an  issuer  of  a
security  defaults  on  its  payment  when  the  security  matures.  This  risk  is
mitigated  by  limiting  allowable  investments  and  collateral  under  reverse
repurchase  agreements  to  high  quality  sovereign,  government  agency  or
multilateral development bank debt instruments.

Critical Accounting Policies and Estimates 

The preparation of financial statements and related disclosures in conformity
with U.S. GAAP requires management to make judgments, assumptions, and
estimates  that  affect  the  amounts  reported  in  the  consolidated  financial
statements  and  accompanying  notes.  Note  2,  “Summary  of  Significant
Accounting  Policies,”  to  the  consolidated  financial  statements  describes  the
significant  accounting  policies  and  methods  used  in  the  preparation  of  the
consolidated  financial  statements.  The  accounting  policies  described  below
are  significantly  affected  by  critical  accounting  estimates.  Such  accounting
policies require significant judgments, assumptions, and estimates used in the
preparation  of  the  consolidated  financial  statements,  and  actual  results  could
differ materially from the amounts reported based on these policies.

Revenue Recognition

• Credit Risk. When the clearinghouse has the ability to hold cash collateral at
a  central  bank,  the  clearinghouse  utilizes  its  access  to  the  central  bank
system  to  minimize  credit  risk  exposures.  When  funds  are  not  held  at  a
central  bank,  we  seek  to  substantially  mitigate  credit  risk  by  ensuring  that
investments are primarily placed in large, highly rated financial institutions,
highly  rated  government  debt 
instruments  and  other  creditworthy
counterparties.

As part of our market technology product offering, we enter into certain long-
term  contracts  with  customers  to  develop  customized  technology  solutions,
license the right to use software and provide support and other services to our
customers  which  results  in  these  contracts  containing  multiple  performance
obligations.  We  allocate  the  contract  transaction  price  to  each  performance
obligation  using  our  best  estimate  of  the  standalone  selling  price  of  each
distinct

52

good or service in the contract. In instances where standalone selling price is
not  directly  observable,  such  as  when  we  do  not  sell  the  product  or  service
separately,  we  determine  the  standalone  selling  price  predominantly  through
an expected cost plus a margin approach.

We  generally  recognize  revenue  over  time  as  our  customers  simultaneously
receive  and  consume  the  benefits  provided  by  our  performance  because  our
customer controls the asset for which we are creating, our performance does
not  create  an  asset  with  alternative  use,  and  we  have  a  right  to  payment  for
performance completed to date. For these services, we recognize revenue over
time using costs incurred to date relative to total estimated costs at completion
to  measure  progress  toward  satisfying  our  performance  obligation.  Incurred
costs represent work performed, which corresponds with, and thereby depicts,
the transfer of control to the customer.

Accounting for our long-term contracts requires judgment relative to assessing
risks and their impact on the estimate of revenues and costs. Our estimates are
impacted  by  factors  such  as  the  potential  for  schedule  and  technical  issues,
productivity  and  the  complexity  of  work  performed.  Revenue  and  cost
estimates  for  our  long-term  contracts  are  reviewed  and  reassessed  at  least
quarterly. When adjustments in estimated total contract costs are required, any
changes in the estimated revenues from prior estimates are recognized in the
current  period  for  the  effect  of  such  change.  If  estimates  of  total  costs  to  be
incurred on a contract exceed estimates of total revenues, a provision for the
entire estimated loss on the contract is recorded in the period in which the loss
is determined.

Due  to  the  significance  of  judgment  in  the  estimation  process,  as  discussed
above,  changes  in  assumptions  and  estimates  may  adversely  or  positively
affect financial performance in future periods.

For further discussion related to recognition of these revenues, see “Revenue
From  Contracts  with  Customers 
-  Market
Technology,” of Note 2, “Summary of Significant Accounting Policies,” to the
consolidated financial statements.

-  Revenue  Recognition 

Business combination

We  account  for  business  acquisitions  under  the  acquisition  method  of
accounting.  The  assets  acquired  and  liabilities  assumed  in  connection  with
business acquisitions are recorded at the date of acquisition at their estimated
fair  values,  with  any  excess  of  the  purchase  price  over  the  estimated  fair
values of the net assets acquired recorded as goodwill. Within one year from
the  date  of  acquisition,  we  may  update  the  value  allocated  to  the  assets
acquired and liabilities assumed, and the resulting goodwill balance, based on
information received regarding the valuation of such assets and liabilities that
was not available at the time of purchase.

We  use  various  methods  to  determine  fair  value  depending  on  the  type  of
assets  acquired  and  liabilities  assumed.  We  make  estimates  and  assumptions
about  projected  future  cash  flows  including,  but  not  limited  to,  forecasted
revenue,  cash  flows,  attrition  rates,  long  term  growth  rates,  royalty  rates,
EBITDA margin and discount rates.

Significant judgment is required in estimating the fair value of assets acquired
and  liabilities  assumed  and  in  assigning  useful  lives  to  certain  definite-lived
intangible  and  tangible  assets.  Accordingly,  we  may  engage  third-party
valuation specialists to assist in these determinations. The fair value estimates
are based on available information as of the acquisition date and assumptions
deemed reasonable by management but are inherently uncertain.

See Note 4, “Acquisitions,” to the consolidated financial statements for further
discussion of the Adenza Acquisition.

During 2023, 2022 and 2021, we have not recorded any material measurement
period adjustments to purchase price allocations.

Goodwill,  Indefinite-Lived  Intangible  Assets  and  Related  Impairment
Testing

identifiable 

intangibles,  such  as  customer 

Goodwill  represents  the  excess  of  purchase  price  over  the  value  assigned  to
the net assets, including identifiable intangible assets, of a business acquired.
Goodwill is allocated to our reporting units based on the assignment of the fair
values  of  each  reporting  unit  of  the  acquired  company.  We  recognize
specifically 
relationships,
technology,  exchange  and  clearing  registrations,  trade  names  and  licenses
when  a  specific  right  or  contract  is  acquired.  Goodwill  and  intangible  assets
deemed  to  have  indefinite  useful  lives,  primarily  exchange  and  clearing
registrations,  are  not  amortized  but  instead  are  tested  for  impairment  at  least
annually as of October 1 and more frequently whenever events or changes in
circumstances  indicate  that  the  fair  value  of  the  asset  may  be  less  than  its
carrying  amount,  such  as  changes  in  the  business  climate,  poor  indicators  of
operating performance or the sale or disposition of a significant portion of a
reporting unit.

In  November  2023,  following  the  acquisition  of  Adenza,  we  refined  our
divisional  structure.  Our 
three  previous  reportable  segments,  Market
Platforms,  Capital  Access  Platforms  and  Anti-Financial  Crime,  have  been
changed to align with our new corporate structure that includes the following
three  segments:  Capital  Access  Platforms,  Financial  Technology  and  Market
Services.  Under  ASC  350-20,  “Intangibles  Goodwill  and  Other,”  when  a
company  reorganizes  its  reporting  structure,  an  impairment  test  must  be
performed both before and after the change, and goodwill must be reassigned
to reporting units. Accordingly, goodwill was reassigned based on relative fair
value of each reporting unit.

53

We perform our goodwill impairment test at the reporting unit level. For 2023,
we performed the goodwill impairment test under our previous organizational
structure  which  included  three  reporting  units:  Market  Platforms,  Capital
Access  Platforms  and  Anti-Financial  Crime  segments  and  under  our  current
organization  structure,  which  includes  the  following  three  reporting  units:
Capital  Access  Platforms,  Financial  Technology  and  Market  Services
segments.

When  testing  goodwill  and  indefinite-lived  intangible  assets  for  impairment,
we  have  the  option  of  first  performing  a  qualitative  assessment  to  determine
whether  it  is  more  likely  than  not  that  the  fair  value  of  a  reporting  unit  or
indefinite-lived intangible asset is less than their respective carrying amounts
as  the  basis  to  determine  if  it  is  necessary  to  perform  a  quantitative
impairment test. If we choose not to complete a qualitative assessment, or if
the initial assessment indicates that it is more likely than not that the carrying
amount  of  a  reporting  unit  or  the  carrying  amount  of  an  indefinite-lived
intangible  asset  exceeds  their  respective  estimated  fair  values,  a  quantitative
test is required. Our decision to perform a qualitative impairment assessment
in a given year is influenced by a number of factors, including but not limited
to, the size of the reporting unit’s goodwill, the significance of the excess of
the  reporting  unit’s  estimated  fair  value  or  the  indefinite-lived  intangible
asset’s fair value over their respective carrying amounts at the last quantitative
assessment  date,  and  the  amount  of  time  in  between  quantitative  fair  value
assessments.

In  performing  a  quantitative  impairment  test,  we  compare  the  fair  value  of
each  reporting  unit  and  indefinite-lived  intangible  asset  with  their  respective
carrying  amounts.  The  fair  value  of  each  reporting  unit  is  estimated  using  a
combination  of  a  discounted  cash  flow  valuation,  which  incorporates
assumptions regarding future growth rates, terminal values, and discount rates,
as  well  as  guideline  public  company  valuations,  which  incorporates  relevant
trading  multiples  of  comparable  companies  and  other  factors.  The  estimates
and assumptions used consider historical performance and are consistent with
the assumptions used in determining future profit plans for each reporting unit,
which  are  approved  by  our  board  of  directors.  The  fair  value  of  indefinite-
lived  intangible  assets  is  primarily  determined  on  the  basis  of  estimated
discounted  value,  using  the  Greenfield  Approach  for  exchange  and  clearing
registrations  and  licenses,  and  the  relief  from  royalty  approach  or  excess
earnings  approach  for  trade  names,  both  of  which  incorporate  assumptions
regarding  future  revenue  projections  and  discount  rates.  If  the  carrying
amounts  of  the  reporting  unit  or  the  indefinite-lived  intangible  asset  exceed
their respective fair values, an impairment charge is recognized in an amount
equal  to  the  difference,  limited  to  the  total  amount  of  goodwill  allocated  to
that reporting unit or the total carrying value of the indefinite-lived intangible
asset.

The  following  table  presents  the  balances  of  goodwill  for  our  reportable
segments pre-segment realignment at the time of our 2023 annual impairment
test:

Market Platforms
Capital Access Platforms
Anti-Financial Crime

October 1, 2023

(in millions)

2,845 
4,138 
1,005 
7,988 

$

$

The  following  table  presents  the  balances  of  goodwill  for  our  reportable
segments  post  segment  realignment,  excluding  the  goodwill  acquired  as  part
of the Adenza acquisition. The carrying value of goodwill was reassigned to
our  new  reportable  segments  based  on  a  relative  fair  value  allocation
approach.

Capital Access Platforms
Financial Technology
Market Services

October 1, 2023

(in millions)

4,138 
1,922 
1,928 
7,988 

$

$

In  2023  and  2022,  we  elected  to  perform  a  quantitative  impairment  test  for
goodwill and indefinite-lived intangible assets. In conducting the quantitative
assessment, we determined that the fair value of our goodwill for each of our
reporting  units  and  the  fair  value  of  our  indefinite-lived  intangible  assets
sufficiently exceed their respective carrying amounts. As a result, there were
no goodwill or indefinite-lived intangible assets impairment charges recorded
in any of those years.

Although  we  believe  our  estimates  of  fair  value  are  reasonable,  the
determination  of  certain  valuation  inputs  is  subject  to  management’s
judgment.  Changes  in  these  inputs  could  materially  affect  the  results  of  our
impairment  review.  If  our  forecasts  of  cash  flows  or  other  key  inputs  are
negatively revised in the future, the estimated fair value of each reporting unit
and  of  our  indefinite-lived  intangible  assets  would  be  adversely  impacted,
potentially leading to an impairment in the future that could materially affect
our operating results.

Subsequent to our annual impairment test, no indications of impairment were
identified.

Other Long-Lived Assets and Related Impairment

We  review  our  other  long-lived  assets,  such  as  finite-lived  intangible  assets,
property  and  equipment,  and  operating  lease  assets  for  potential  impairment
when  there  is  evidence  that  events  or  changes  in  circumstances  indicate  that
the carrying amount of an asset may not be recoverable. The carrying amount
of an asset is not recoverable if it exceeds the sum of the undiscounted cash
flows  expected  to  result  from  the  use  and  eventual  disposition  of  the  asset.
Fair  value  of  finite-lived  intangible  assets  and  property  and  equipment  is
based  on  various  valuation  techniques.  Any  required  impairment  loss  is
measured as the amount by which the carrying amount of the asset exceeds its
fair value and is recorded as a reduction in the carrying amount of the related
asset and a charge to operating results.

54

 
 
 
 
There  were  no  material  finite-lived  intangible  assets  impairment  charges  in
2023  and  2022.  We  recorded  an  impairment  charge  of  $14  million  in  2021
related to a finite-lived intangible asset for customer relationships associated
with  the  wind  down  of  a  previous  acquisition  included  in  depreciation  and
amortization expense in the Consolidated Statements of Income.

We  recorded  pre-tax,  non-cash  property  and  equipment  asset  impairment
charges of $12 million in 2023, $14 million in 2022 and $4 million in 2021.
See Note 20, “Restructuring Charges,” to the consolidated financial statements
for a discussion of these plans.

In the first quarter of 2023, we initiated a review of our real estate and facility
capacity requirements due to our new and evolving work models. As a result
of  this  ongoing  review,  we  recorded  impairment  charges  of  $23  million  in
2023 of which $18 million related to operating lease asset impairment and exit
costs and is included in occupancy expense in the Consolidated Statements of
Income  and  $5  million  related  to  impairment  of  leasehold  improvements,
which  are  recorded  in  depreciation  and  amortization  expense  in  the
Consolidated  Statements  of  Income.  We  fully  impaired  our  lease  assets  for
locations that we vacated with no intention to sublease. Substantially all of the
property, equipment and leasehold improvements associated with the vacated
leased  office  space  were  fully  impaired  as  there  are  no  expected  future  cash
flows for these items.

No  material  impairments  were  recorded  to  reduce  the  carrying  value  of  our
other long-lived assets during 2023, 2022 or 2021.

Income Taxes

Estimates  and  judgments  are  required  in  the  calculation  of  certain  tax
liabilities and in the determination of the recoverability of certain deferred tax
assets,  which  arise  from  net  operating  loss  carryforwards,  tax  credit
carryforwards  and  temporary  differences  between  the  tax  and  financial
statement  recognition  of  revenues  and  expenses.  Our  deferred  tax  assets  are
reduced by a valuation allowance if it is more likely than not that some portion
or all of the recorded deferred tax assets will not be realized in future periods.
Management  is  required  to  determine  whether  a  tax  position  is  more  likely
than not to be sustained upon examination, including resolution of any related
appeals  or  litigation  processes,  based  on  the  technical  merits  of  the  position.
Once  it  is  determined  that  a  position  meets  the  recognition  thresholds,  the
position  is  measured  to  determine  the  amount  of  benefit  to  be  recognized  in
the consolidated financial statements.

In  assessing  the  need  for  a  valuation  allowance,  we  consider  all  available
evidence including past operating results, the existence of cumulative losses in
the  most  recent  fiscal  years,  estimates  of  future  taxable  income  and  the
feasibility  of  tax  planning  strategies.  In  the  event  that  we  change  our
determination as to the amount of deferred tax assets that can be realized, we
will  adjust  our  valuation  allowance  with  a  corresponding  impact  to  the
provision for income taxes in the period in which such determination is made.

In  addition,  the  calculation  of  our  tax  liabilities  involves  uncertainties  in  the
application  of  tax  regulations  in  the  U.S.  and  other  tax  jurisdictions.  We
recognize  potential  liabilities  for  anticipated  tax  audit  issues  in  such
jurisdictions  based  on  our  estimate  of  whether,  and  the  extent  to  which,
additional  taxes  and  interest  may  be  due.  While  we  believe  that  our  tax
liabilities  reflect  the  probable  outcome  of  identified  tax  uncertainties,  it  is
reasonably  possible  that  the  ultimate  resolution  of  any  tax  matter  may  be
greater  or  less  than  the  amount  accrued.  If  events  occur  and  the  payment  of
these  amounts  ultimately  proves  unnecessary,  the  reversal  of  the  liabilities
would result in tax benefits being recognized in the period when we determine
the liabilities are no longer necessary. If our estimate of tax liabilities proves
to  be  less  than  the  ultimate  assessment,  a  further  charge  to  expense  would
result.

Item 7A. Quantitative and Qualitative Disclosures About Market Risk

Information about quantitative and qualitative disclosures about market risk is
incorporated herein by reference from “Item 7. Management’s Discussion and
Analysis of Financial Condition and Results of Operations - Quantitative and
Qualitative Disclosures About Market Risk.”

Item 8. Financial Statements and Supplementary Data

Nasdaq’s  consolidated  financial  statements,  including  Consolidated  Balance
Sheets  as  of  December  31,  2023  and  2022,  Consolidated  Statements  of
Income for the years ended December 31, 2023, 2022 and 2021, Consolidated
Statements of Comprehensive Income for the years ended December 31, 2023,
2022 and 2021, Consolidated Statements of Changes in Stockholders’ Equity
for  the  years  ended  December  31,  2023,  2022  and  2021,  Consolidated
Statements of Cash Flows for the years ended December 31, 2023, 2022 and
2021 and notes to our consolidated financial statements, together with a report
thereon of Ernst & Young LLP, dated February 21, 2024, are attached hereto
as pages F-1 through F-45 and incorporated by reference herein.

Item  9.  Changes  in  and  Disagreements  with  Accountants  on  Accounting
and Financial Disclosure

None.

55

Item 9A. Controls and Procedures

Disclosure controls and procedures.

Nasdaq’s  management,  with  the  participation  of  Nasdaq’s  Chief  Executive
Officer  and  Executive  Vice  President  and  Chief  Financial  Officer,  has
evaluated the effectiveness of Nasdaq’s disclosure controls and procedures (as
defined in Rule 13a-15(e) and Rule 15d-15(e) under the Exchange Act) as of
the  end  of  the  period  covered  by  this  report.  In  November  2023,  Nasdaq
completed  the  acquisition  of  Adenza.  We  accounted  for  this  acquisition  as  a
business  combination.  The  scope  of  management’s  assessment  of  the
effectiveness  of  the  Company’s  disclosure  controls  and  procedures  did  not
include  the  internal  controls  over  financial  reporting  of  Adenza.  This
exclusion  is  in  accordance  with  the  SEC  staff’s  general  guidance  that  an
assessment of a recently acquired business may be omitted from the scope of
management’s  assessment  for  one  year  following  the  acquisition.  The
recognition  of  goodwill  and  intangible  assets,  however,  is  covered  by  our
internal  controls  over  mergers  and  acquisitions,  which  were  included  in
management’s  assessment  of  the  effectiveness  of  the  Company’s  internal
control  over  financial  reporting  as  of  December  31,  2023.  Based  upon  that
evaluation,  Nasdaq’s  Chief  Executive  Officer  and  Executive  Vice  President
and Chief Financial Officer, have concluded that, as of the end of such period,
Nasdaq’s disclosure controls and procedures are effective.

Changes  in  internal  control  over  financial  reporting.  Based  on  the
evaluation  completed  by  management,  in  which  our  Chief  Executive  Officer
and Chief Financial Officer participated, our management has concluded that,
except as noted above with respect to the acquisition of Adenza, there were no
changes  in  Nasdaq’s  internal  control  over  financial  reporting  (as  defined  in
Rule  13a-15(f)  and  Rule  15d-15(f)  under  the  Exchange  Act)  that  occurred
during the quarter ended December 31, 2023 that have materially affected, or
are  reasonably  likely  to  materially  affect,  Nasdaq’s  internal  control  over
financial reporting.

Management’s Report on Internal Control Over Financial Reporting

is  responsible  for 

Management 
the
consolidated financial statements appearing in the reports that we file with the
SEC. The consolidated financial statements were prepared in conformity with
U.S. generally accepted accounting principles and include amounts based on
management’s estimates and judgments.

the  preparation  and 

integrity  of 

Management  is  also  responsible  for  establishing  and  maintaining  adequate
internal control over Nasdaq’s financial reporting. Although there are inherent
limitations in the effectiveness of any system of internal control over financial
reporting, or ICFR, we maintain a system of internal control that is designed
to  provide  reasonable  assurance  as  to  the  fair  and  reliable  preparation  and
presentation of the consolidated financial statements, as well as to safeguard
assets  from  unauthorized  use  or  disposition  that  could  have  a  material  effect
on the financial statements.

Our  management  assessed  the  effectiveness  of  our  internal  control  over
financial reporting as of December 31, 2023, based on criteria established in
the  Committee  of
Internal  Control—Integrated  Framework 
Sponsoring  Organizations  of  the  Treadway  Commission  (COSO)  (2013
framework).  This  evaluation  included  review  of  the  documentation  of
controls,  evaluation  of  the  design  effectiveness  of  controls,  testing  of  the
operating effectiveness of controls and a conclusion on this evaluation.

issued  by 

Our  management  has  excluded  the  ICFR  of  Adenza,  which  we  acquired  on
November 1, 2023 as discussed in Note 4 “Acquisitions,” to the Consolidated
Financial Statements included elsewhere in this Annual Report on Form 10-K.
Total revenues subject to Adenza’s ICFR represented 4% and 3% of revenues
less  transaction-based  expenses  and  operating  income,  respectively,  for  the
fiscal year ended December 31, 2023. Total assets subject to Adenza’s ICFR
represented 36% of our consolidated total assets as of December 31, 2023 (of
which  $11  billion,  or  34%  of  our  consolidated  total  assets,  represents
intangible  assets  acquired  and  the  goodwill  resulting  from  the  Adenza
acquisition, which were subject to our ICFR as of December 31, 2023) and net
assets  of  Adenza  represented  3%  of  our  consolidated  net  assets,  excluding
intangible assets acquired and the corresponding deferred tax liability as well
as the goodwill resulting from the Adenza acquisition, which were subject to
our ICFR as of December 31, 2023. Under guidelines established by the SEC,
companies  are  permitted  to  exclude  acquisitions  from  their  assessment  of
ICFR for a period of up to one year following an acquisition while integrating
the acquired company.

Based  on  its  assessment,  our  management  believes  that,  as  of  December  31,
2023, our internal control over financial reporting is effective. Ernst & Young
LLP,  an  independent  registered  public  accounting  firm,  has  issued  an
attestation report on Nasdaq’s internal control over financial reporting, which
is included herein.

56

Report of Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of Nasdaq, Inc.

Opinion on Internal Control over Financial Reporting

We have audited Nasdaq, Inc.’s internal control over financial reporting as of
December  31,  2023,  based  on  criteria  established  in  Internal  Control—
Integrated Framework issued by the Committee of Sponsoring Organizations
of  the  Treadway  Commission  (2013  framework)  (the  COSO  criteria).  In  our
opinion,  Nasdaq,  Inc.  (the  Company)  maintained,  in  all  material  respects,
effective  internal  control  over  financial  reporting  as  of  December  31,  2023,
based on the COSO criteria.

As indicated in the accompanying Management’s Report on Internal Control
Over Financial Reporting, management’s assessment of and conclusion on the
effectiveness  of  internal  control  over  financial  reporting  did  not  include  the
internal  controls  of  Adenza,  which  is  included  in  the  2023  consolidated
financial statements of the Company and constituted 2% and 3% of total and
net assets, respectively, as of December 31, 2023 and 4% and 3% of revenues
less  transaction-based  expenses  and  operating  income,  respectively,  for  the
year then ended. Our audit of internal control over financial reporting of the
Company  also  did  not  include  an  evaluation  of  the  internal  control  over
financial reporting of Adenza.

We also have audited, in accordance with the standards of the Public Company
Accounting  Oversight  Board  (United  States)  (PCAOB),  the  consolidated
balance sheets of the Company as of December 31, 2023 and 2022, the related
consolidated  statements  of  income,  comprehensive  income,  changes  in
stockholders’ equity and cash flows for each of the three years in the period
ended December 31, 2023, and the related notes and our report dated February
21, 2024 expressed an unqualified opinion thereon.

Basis for Opinion

The Company’s management is responsible for maintaining effective internal
control over financial reporting and for its assessment of the effectiveness of
internal  control  over  financial  reporting  included  in  the  accompanying
Management’s  Report  on  Internal  Control  Over  Financial  Reporting.  Our
responsibility is to express an opinion on the Company’s internal control over
financial  reporting  based  on  our  audit.  We  are  a  public  accounting  firm
registered with the PCAOB and are required to be independent with respect to
the  Company  in  accordance  with  the  U.S.  federal  securities  laws  and  the
applicable rules and regulations of the Securities and Exchange Commission
and the PCAOB.

We  conducted  our  audit  in  accordance  with  the  standards  of  the  PCAOB.
Those  standards  require  that  we  plan  and  perform  the  audit  to  obtain
reasonable  assurance  about  whether  effective  internal  control  over  financial
reporting was maintained in all material respects.

Our  audit  included  obtaining  an  understanding  of  internal  control  over
financial reporting, assessing the risk that a material weakness exists, testing
and evaluating the design and operating effectiveness of internal control based
on the assessed risk, and performing such other procedures as we considered
necessary  in  the  circumstances.  We  believe  that  our  audit  provides  a
reasonable basis for our opinion.

Definition and Limitations of Internal Control Over Financial Reporting

A company’s internal control over financial reporting is a process designed to
provide  reasonable  assurance  regarding  the  reliability  of  financial  reporting
and the preparation of financial statements for external purposes in accordance
with  generally  accepted  accounting  principles.  A  company’s  internal  control
over financial reporting includes those policies and procedures that (1) pertain
to the maintenance of records that, in reasonable detail, accurately and fairly
reflect  the  transactions  and  dispositions  of  the  assets  of  the  company;  (2)
provide  reasonable  assurance  that  transactions  are  recorded  as  necessary  to
permit  preparation  of  financial  statements  in  accordance  with  generally
accepted  accounting  principles,  and  that  receipts  and  expenditures  of  the
company  are  being  made  only  in  accordance  with  authorizations  of
management  and  directors  of  the  company;  and  (3)  provide  reasonable
assurance  regarding  prevention  or 
timely  detection  of  unauthorized
acquisition,  use,  or  disposition  of  the  company’s  assets  that  could  have  a
material effect on the financial statements.

Because  of  its  inherent  limitations,  internal  control  over  financial  reporting
may not prevent or detect misstatements. Also, projections of any evaluation
of  effectiveness  to  future  periods  are  subject  to  the  risk  that  controls  may
become  inadequate  because  of  changes  in  conditions,  or  that  the  degree  of
compliance with the policies or procedures may deteriorate.

/s/ Ernst & Young LLP

New York, New York
February 21, 2024

57

 
 
Item 9B. Other Information

During  the  three  months  ended  December  31,  2023,  none  of  the  Company’s
directors  or  officers  adopted,  terminated  or  modified  a  “Rule  10b5-1  trading
arrangement”  or  “non-Rule  10b5-1  trading  arrangement”  (as  such  terms  are
defined in Item 408 of Regulation S-K).

Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections

Not applicable.

PART III

Item 10. Directors, Executive Officers and Corporate Governance

Information about Nasdaq’s directors, as required by Item 401 of Regulation
S-K, is incorporated by reference, if applicable, from the discussion under the
caption “Director Nominees” in Nasdaq’s Proxy Statement. Information about
Nasdaq’s  executive  officers,  as  required  by  Item  401  of  Regulation  S-K,  is
incorporated by reference from the discussion under the caption “Other Items-
Executive  Officers”  in  the  Proxy  Statement.  Information  about  Section  16
reports,  as  required  by  Item  405  of  Regulation  S-K,  is  incorporated  by
reference  from  the  discussion  under  the  caption  “Other  Items-Delinquent
Section  16(a)  Reports”  in  the  Proxy  Statement.  Information  about  Nasdaq’s
code of ethics, as required by Item 406 of Regulation S-K, is incorporated by
reference from the discussion under the caption “Operating with Integrity” in
the  Proxy  Statement.  Information  about  Nasdaq’s  nomination  procedures,
Audit  &  Risk  Committee  and  Audit  &  Risk  Committee  financial  experts,  as
required  by  Items  407(c)(3),  407(d)(4)  and  407(d)(5)  of  Regulation  S-K,  is
incorporated  by  reference  from  the  discussions  under  the  headings  “Director
Nominees” and “Board Committees” in the Proxy Statement.

Item 11. Executive Compensation

Information about Nasdaq’s director and executive compensation, as required
by Items 402, 407(e)(4) and 407(e)(5) of Regulation S-K, is incorporated by
reference  from  the  discussions  under  the  headings  “Director  Compensation”
and “Executive Compensation” in the Proxy Statement.

Item  12.  Security  Ownership  of  Certain  Beneficial  Owners  and
Management and Related Stockholder Matters

Information  about  security  ownership  of  certain  beneficial  owners  and
management,  as  required  by  Item  403  of  Regulation  S-K,  is  incorporated  by
reference  from  the  discussion  under  the  heading  “Other  Items-Security
Ownership  of  Certain  Beneficial  Owners  and  Management”  in  the  Proxy
Statement.

Equity Compensation Plan and ESPP Information

Nasdaq’s Equity Plan provides for the issuance of our equity securities to all
employees and directors as part of their compensation plan.

In  addition,  in  jurisdictions  where  participation  in  the  ESPP  is  permitted,  all
our employees are eligible. The employees that joined us from Adenza are not
yet  eligible  for  participation  in  the  ESPP,  as  payroll  and  benefits  integration
efforts remain ongoing following the consummation of the Adenza acquisition
in November 2023. Employees may purchase shares of our common stock at a
15% discount to the lesser of the closing price of our common stock on (i) the
first  trading  day  of  the  offering  period  or  (ii)  the  last  trading  day  of  the
offering period. Offering periods under the ESPP are six months in duration.
As of December 31, 2023, all our employees are eligible to participate.

The  Equity  Plan  and  the  ESPP  have  been  previously  approved  by  our
stockholders. The following table sets forth information regarding outstanding
options  and  shares  reserved  for  future  issuance  under  all  of  Nasdaq’s
compensation plans as of December 31, 2023.

Number of 
shares
to be issued upon
exercise of
outstanding 
options, warrants 
and rights(a)

Weighted-average
 exercise price of
outstanding 
options,
warrants and 
rights(b)

Number of 
shares remaining 
available
for future issuance
under equity
compensation 
plans (excluding
shares reflected in 
column(a))(c)

1,420,323  $

41.79 

36,014,602 

— 

1,420,323  $

— 

41.79 

— 
36,014,602 

Plan Category
Equity compensation
plans approved by
stockholders
Equity compensation
plans not approved
by stockholders

Total

In the table above:

• The  number  of  shares  to  be  issued  upon  exercise  of  outstanding  options,
warrants  and  rights  include  only  the  number  of  shares  to  be  issued  upon
exercise  of  outstanding  options,  warrants  and  rights.  As  of  December  31,
2023, we also had 6,217,621 shares to be issued upon vesting of outstanding
restricted stock and PSUs.

• The number of shares remaining available for future issuance under equity
compensation  plans  (excluding  shares  reflected  in  column  (a)  includes
24,598,016  shares  of  common  stock  that  may  be  awarded  pursuant  to  the
Equity Plan and (b) 11,416,586 shares of common stock that may be issued
pursuant to the ESPP.

58

 
 
 
 
 
 
 
Item 13. Certain Relationships and Related Transactions, and Director
Independence

Information about certain relationships and related transactions, as required by
Item  404  of  Regulation  S-K,  is  incorporated  herein  by  reference  from  the
discussion under the heading “Other Items-Certain Relationships and Related
Transactions” 
Information  about  director
independence, as required by Item 407(a) of Regulation S-K, is incorporated
herein  by  reference  from  the  discussion  under  the  heading  “Director
Nominees” in the Proxy Statement.

the  Proxy  Statement. 

in 

Item 14. Principal Accountant Fees and Services

Information  about  principal  accountant  fees  and  services,  as  required  by
Item  9(e)  of  Schedule  14A,  is  incorporated  herein  by  reference  from  the
discussion  under  the  heading  “Annual  Evaluation  and  2024  Selection  of  the
Independent Auditors” in the Proxy Statement.

PART IV

Item 15. Exhibits and Financial Statement Schedules

(a)(1) Financial Statements

See “Index to Consolidated Financial Statements.”

(a)(2) Financial Statement Schedules

All  schedules  are  omitted  because  they  are  not  applicable  or  the  required
information is included in the consolidated financial statements or notes.

(a)(3) Exhibits
Exhibit
Number

2.1

2.2

Share Purchase Agreement, dated as of November 18, 2020,
by and among Osprey Acquisition Corporation, a wholly
owned subsidiary of Nasdaq, Verafin Holdings Inc., certain
shareholders of Verafin (the “Sellers”), and Shareholder
Representative Services LLC, solely in its capacity as the
representative of the Sellers (incorporated herein by reference
to Exhibit 2.2 to the Annual Report on Form 10-K for the year
ended December 31, 2020 filed on February 23, 2021).†

Amendment to Share Purchase Agreement, dated as of
February 11, 2021, by and among Osprey Acquisition
Corporation, a wholly owned subsidiary of Nasdaq, Verafin
Holdings Inc., certain shareholders of Verafin (the “Sellers”),
and Shareholder Representative Services LLC, solely in its
capacity as the representative of the Sellers (incorporated
herein by reference to Exhibit 2.3 to the Annual Report on
Form 10-K for the year ended December 31, 2020 filed on
February 23, 2021).

59

2.3

3.1

3.1.1

3.1.2

3.1.3

3.1.4

3.2

4.1

4.2

4.2.1

4.3

Agreement and Plan of Merger, dated as of June 10, 2023, by
and among Nasdaq, Inc., Argus Merger Sub 1, Inc., Argus
Merger Sub 2, LLC, Adenza Holdings, Inc. and Adenza
Parent, LP. (incorporated herein by reference to Exhibit 2.1 to
the Current Report on Form 8-K filed on June 12, 2023).†

Amended and Restated Certificate of Incorporation of Nasdaq
(incorporated herein by reference to Exhibit 3.1 to the Current
Report on Form 8-K filed on January 28, 2014).

Certificate of Elimination of Nasdaq’s Series A Convertible
Preferred Stock (incorporated herein by reference to Exhibit
3.1.1 to the Current Report on Form 8-K filed on January 28,
2014).

Certificate of Amendment of Nasdaq’s Amended and Restated
Certificate of Incorporation (incorporated herein by reference
to Exhibit 3.1 to the Current Report on Form 8-K filed on
November 19, 2014).

Certificate of Amendment of Nasdaq’s Amended and Restated
Certificate of Incorporation (incorporated herein by reference
to Exhibit 3.1 to the Current Report on Form 8-K filed on
September 8, 2015).

Certificate of Amendment of Nasdaq’s Amended and Restated
Certificate of Incorporation (incorporated herein by reference
to Exhibit 3.1 to the Current Report on Form 8-K filed on July
20, 2022).

Nasdaq’s By-Laws (incorporated herein by reference to
Exhibit 3.2 to the Current Report on Form 8-K filed on
November 21, 2016).

Form of Common Stock certificate (incorporated herein by
reference to Exhibit 4.1 to the Quarterly Report on Form 10-Q
for the quarter ended September 30, 2015 filed on November
4, 2015).

Stockholders’ Agreement, dated as of February 27, 2008,
between Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, Inc.)
and Borse Dubai Limited (incorporated herein by reference to
Exhibit 10.2 to the Current Report on Form 8-K filed on
March 3, 2008).

First Amendment to Stockholders’ Agreement, dated as of
February 19, 2009, between Nasdaq, Inc. (f/k/a The NASDAQ
OMX Group, Inc.) and Borse Dubai Limited (incorporated
herein by reference to Exhibit 4.10.1 to the Annual Report on
Form 10-K for the year ended December 31, 2008 filed on
February 27, 2009).

Registration Rights Agreement, dated as of February 27, 2008,
among Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, Inc.),
Borse Dubai Limited and Borse Dubai Nasdaq Share Trust
(incorporated herein by reference to Exhibit 10.3 to the
Current Report on Form 8-K filed on March 3, 2008).

 
4.3.1

4.4

4.4.1

4.5

4.6

4.7

4.8

4.9

4.10

First Amendment to Registration Rights Agreement, dated
as of February 19, 2009, among Nasdaq, Inc. (f/k/a The
NASDAQ OMX Group, Inc.), Borse Dubai Limited and
Borse Dubai Nasdaq Share Trust (incorporated herein by
reference to Exhibit 4.11.1 to the Annual Report on Form
10-K for the year ended December 31, 2008 filed on
February 27, 2009).

Stockholders’ Agreement, dated as of December 16, 2010,
between Nasdaq, Inc. (f/k/a The NASDAQ OMX Group,
Inc.) and Investor AB (incorporated herein by reference to
Exhibit 4.12 to the Annual Report on Form 10-K for the year
ended December 31, 2010 filed on February 24, 2011).

First Amendment to Nasdaq Stockholders’ Agreement, dated
as of December 14, 2022, between Nasdaq, Inc. and Investor
AB (incorporated herein by reference to Exhibit 4.1 to the
Current Report on Form 8-K filed on December 16, 2022).

Stockholders’ Agreement, dated as of November 1, 2023, by
and among Nasdaq, Inc., Adenza Parent, LP and Thoma
Bravo, L.P. (incorporated herein by reference to Exhibit 4.1
to the Current Report on Form 8-K filed on November 3,
2023).

Registration Rights Agreement, dated as of November 1,
2023, by and among Nasdaq, Inc. and Adenza Parent, LP.
(incorporated herein by reference to Exhibit 4.2 to the
Current Report on Form 8-K filed on November 3, 2023).

Indenture, dated as of June 7, 2013, between Nasdaq, Inc.
(f/k/a The NASDAQ OMX Group, Inc.) and Wells Fargo
Bank, National Association, as Trustee (incorporated herein
by reference to Exhibit 4.1 to the Current Report on Form 8-
K filed on June 10, 2013).

Sixth Supplemental Indenture, dated as of April 1, 2019,
among Nasdaq, Inc., Wells Fargo Bank, National
Association, as Trustee, and HSBC Bank USA, National
Association, as paying agent and as registrar and transfer
agent (incorporated by reference to Exhibit 4.2 to the Form
8-A filed on April 1, 2019).

Seventh Supplemental Indenture, dated February 13, 2020,
among Nasdaq, Inc., Wells Fargo Bank, National
Association, as Trustee, and HSBC Bank USA, National
Association, as paying agent and as registrar and transfer
agent (incorporated herein by reference to Exhibit 4.2 to the
Company’s Form 8-A filed on February 13, 2020).

Eighth Supplemental Indenture, dated April 28, 2020, by and
between Nasdaq, Inc. and Wells Fargo Bank, National
Association, as Trustee (incorporated herein by reference to
Exhibit 4.2 to the Current Report on Form 8-K filed on April
28, 2020).

4.11

4.12

4.13

4.14

4.15

4.16

4.17

4.18

4.19

Tenth Supplemental Indenture, dated December 21, 2020, by
and between Nasdaq, Inc. and Wells Fargo Bank, National
Association, as Trustee (incorporated herein by reference to
Exhibit 4.3 to the Current Report on Form 8-K filed on
December 21, 2020).

Eleventh Supplemental Indenture, dated December 21, 2020,
by and between Nasdaq, Inc. and Wells Fargo Bank, National
Association, as Trustee (incorporated herein by reference to
Exhibit 4.4 to the Current Report on Form 8-K filed on
December 21, 2020).

Twelfth Supplemental Indenture, dated July 30, 2021, by and
among Nasdaq, Inc., Wells Fargo Bank, National Association,
as Trustee and HSBC Bank USA, National Association, as
registrar and transfer agent (incorporated herein by reference
to Exhibit 4.2 to the Company’s 8-A filed on July 30, 2021).

Thirteenth Supplemental Indenture, dated as of March 7, 2022,
by and between Nasdaq, Inc. and Computershare Trust
Company, N.A. (as successor to Wells Fargo Bank, National
Association), as trustee (incorporated herein by reference to
Exhibit 4.2 to the Company’s Current Report on Form 8-K
filed on March 7, 2022).

Fourteenth Supplemental Indenture, dated as of June 28, 2023,
by and between Nasdaq, Inc. and Computershare Trust
Company, N.A. (as successor to Wells Fargo Bank, National
Association), as trustee (incorporated herein by reference to
Exhibit 4.2 to the Current Report on Form 8-K filed on June
28, 2023).

Fifteenth Supplemental Indenture, dated as of June 28, 2023,
by and between Nasdaq, Inc. and Computershare Trust
Company, N.A. (as successor to Wells Fargo Bank, National
Association), as trustee (incorporated herein by reference to
Exhibit 4.3 to the Current Report on Form 8-K filed on June
28, 2023).

Sixteenth Supplemental Indenture, dated as of June 28, 2023,
by and between Nasdaq, Inc. and Computershare Trust
Company, N.A. (as successor to Wells Fargo Bank, National
Association), as trustee (incorporated herein by reference to
Exhibit 4.4 to the Current Report on Form 8-K filed on June
28, 2023).

Seventeenth Supplemental Indenture, dated as of June 28,
2023, by and between Nasdaq, Inc. and Computershare Trust
Company, N.A. (as successor to Wells Fargo Bank, National
Association), as trustee (incorporated herein by reference to
Exhibit 4.5 to the Current Report on Form 8-K filed on June
28, 2023).

Eighteenth Supplemental Indenture, dated as of June 28, 2023,
by and between Nasdaq, Inc. and Computershare Trust
Company, N.A. (as successor to Wells Fargo Bank, National
Association), as trustee (incorporated herein by reference to
Exhibit 4.6 to the Current Report on Form 8-K filed on June
28, 2023).

60

     
4.20

Nineteenth Supplemental Indenture, dated as of June 28, 2023,
by and between Nasdaq, Inc. and Computershare Trust
Company, N.A. (as successor to Wells Fargo Bank, National
Association), as trustee and HSBC Bank USA, National
Association, as paying agent, registrar and transfer agent
(incorporated herein by reference to Exhibit 4.7 to the Current
Report on Form 8-K filed on June 28, 2023).

4.21

Description of Securities.

10.1

10.2

10.3

10.4

10.5

10.6

10.7

10.8

10.9

Amended and Restated Board Compensation Policy, effective
on June 16, 2023 (incorporated herein by reference to Exhibit
10.1 to the Quarterly Report on Form 10-Q for the quarter
ended June 30, 2023 filed on August 2, 2023).*

Nasdaq Executive Corporate Incentive Plan, effective as of
January 1, 2015 (incorporated herein by reference to Exhibit
10.1 to the Current Report on Form 8-K filed on May 11,
2015).*

Nasdaq, Inc. Equity Incentive Plan (as amended and restated
as of April 24, 2018) (incorporated herein by reference to
Exhibit 10.1 to the Form S-8 filed on May 25, 2018).*

Form of Nasdaq Non-Qualified Stock Option Award
Certificate (incorporated herein by reference to Exhibit 10.3 to
the Annual Report on Form 10-K for the year ended
December 31, 2010 filed on February 24, 2011).*

Form of Nasdaq Restricted Stock Unit Award Certificate
(employees) (incorporated herein by reference to Exhibit 10.2
to the Quarterly Report on Form 10-Q for the quarter ended
June 30, 2023 filed on August 2, 2023).*

Form of Nasdaq Restricted Stock Unit Award Certificate
(directors) (incorporated herein by reference to Exhibit 10.3 to
the Quarterly Report on Form 10-Q for the quarter ended June
30, 2023 filed on August 2, 2023).*

Form of Nasdaq Three-Year Performance Share Unit
Agreement (incorporated herein by reference to Exhibit 10.4
to the Quarterly Report on Form 10-Q for the quarter ended
June 30, 2023 filed on August 2, 2023).*

Form of Nasdaq Continuing Obligations Agreement
(incorporated by reference to Exhibit 10.9 to the Company’s
Annual Report on Form 10-K for the year ended December
31, 2021 filed on February 23, 2022).

Amended and Restated Supplemental Executive Retirement
Plan, dated as of December 17, 2008 (incorporated herein by
reference to Exhibit 10.6 to the Annual Report on Form 10-K
for the year ended December 31, 2008 filed on February 27,
2009).*

10.10

10.11

10.12

10.13

10.14

10.15

10.17

10.18

10.19

10.20

Amendment No. 1 to Amended and Restated Supplemental
Executive Retirement Plan, effective as of December 31, 2008
(incorporated herein by reference to Exhibit 10.6.1 to the
Annual Report on Form 10-K for the year ended December
31, 2008 filed on February 27, 2009).*

Nasdaq Supplemental Employer Retirement Contribution
Plan, dated as of December 17, 2008 (incorporated herein by
reference to Exhibit 10.7 to the Annual Report on Form 10-K
for the year ended December 31, 2008 filed on February 27,
2009).*

Nasdaq, Inc. Deferred Compensation Plan (incorporated by
reference to Exhibit 10.1 to the Company’s Current Report on
Form 8-K filed on June 16, 2022).*

Nonqualified Stock Option Award Certificate to Adena T.
Friedman from Nasdaq, Inc. in connection with grant made on
January 3, 2017 (incorporated herein by reference to Exhibit
10.1 to the Quarterly Report on Form 10-Q for the quarter
ended September 30, 2017 filed on November 7, 2017).*

Employment Agreement between Nasdaq and Adena
Friedman, made and entered into on November 19, 2021 and
effective as of January 1, 2022 (incorporated herein by
reference to Exhibit 10.14 to the Company’s Annual Report on
Form 10-K for the year ended December 31, 2021 filed on
February 23, 2022).*

Nonqualified Stock Option Award Certificate to Adena T.
Friedman from Nasdaq, Inc. in connection with grant made on
January 3, 2022 (incorporated herein by reference to Exhibit
10.15 to the Company’s Annual Report on Form 10-K for the
year ended December 31, 2021 filed on February 23, 2022).*

Employment Agreement by and between Nasdaq, Inc. and
Bradley J. Peterson, dated June 22, 2022 (incorporated herein
by reference to Exhibit 10.5 to the Quarterly Report on Form
10-Q for the quarter ended June 30, 2022 filed on August 3,
2022).*

Employment Offer Letter by and between Nasdaq, Inc. and
Michelle Daly (incorporated by reference to Exhibit 10.1 to
the Current Report on Form 8-K filed on May 3, 2021).*

General Release and Separation Agreement by and between
Nasdaq, Inc. and Ann M. Dennison, dated as of August 31,
2023 (incorporated herein by reference to Exhibit 10.1 to the
Quarterly Report on Form 10-Q for the quarter ended
September 30, 2023 filed on November 3, 2023).*

Employment Offer Letter by and between Nasdaq, Inc. and
Sarah Youngwood, dated as of August 31, 2023 (incorporated
herein by reference to Exhibit 10.2 to the Quarterly Report on
Form 10-Q for the quarter ended September 30, 2023 filed on
November 3, 2023).*

61

10.21

10.22

10.23

10.24

10.25

10.26

10.27

10.28

11

Nasdaq Change in Control Severance Plan for Executive Vice
Presidents and Senior Vice Presidents, effective November 26,
2013, as amended December 6, 2022 (incorporated by
reference herein to Exhibit 10.19 to the Annual Report on
Form 10-K for the year ended December 31, 2022, filed on
February 22, 2023.*

Amended and Restated Credit Agreement, dated as of
December 16, 2022, among Nasdaq, Inc., the various lenders
and issuing bank party thereto and Bank of America, N.A., as
administrative agent (incorporated herein by reference to
Exhibit 10.1 to the Current Report on Form 8-K filed on
December 16, 2022). †

Amendment No. 1 to Amended and Restated Credit
Agreement, dated as of March 29, 2023, among Nasdaq, Inc.,
the Lenders party hereto, Bank of America, N.A., as
administrative agent and BofA Securities, Inc., as
Sustainability Coordinator (incorporated herein by reference to
Exhibit 10.1 to the Quarterly Report on Form 10-Q for the
quarter ended March 30, 2023 filed on May 4, 2023).†

Amendment No. 2 to Amended and Restated Credit
Agreement, dated as of June 16, 2023, among Nasdaq, Inc., a
Delaware corporation, the lenders party thereto and Bank of
America, N.A., as administrative agent (incorporated herein
by reference to Exhibit 10.1 to the Current Report on Form 8-
K filed on June 20, 2023).

Term Loan Credit Agreement, dated as of June 28, 2023,
among Nasdaq, Inc., the lenders and other parties party
thereto, and Bank of America, N.A., as Administrative Agent
(incorporated herein by reference to Exhibit 10.1 to the
Current Report on Form 8-K filed on June 28, 2023).†

Form of Commercial Paper Dealer Agreement between
Nasdaq, Inc., as Issuer, and the Dealer party thereto
(incorporated herein by reference to Exhibit 10.3 to the
Current Report on Form 8-K filed on April 26, 2017).

Verafin Holdings Inc. Amended and Restated Management
Incentive Plan (incorporated by reference herein to Exhibit
10.24 to the Annual Report on Form 10-K for the year ended
December 31, 2022, filed on February 22, 2023.)*

Verafin Holdings Inc. Amended and Restated Management
Incentive Plan Award Agreement, by and between Verafin
Solutions ULC and Brendan Brothers, dated as of January 11,
2023 (incorporated by reference herein to Exhibit 10.25 to the
Annual Report on Form 10-K for the year ended December
31, 2022, filed on February 22, 2023.)*

Statement regarding computation of per share earnings
(incorporated herein by reference from Note 13 to the
consolidated financial statements under Part II, Item 8 of this
Form 10-K).

21.1

23.1

24.1

31.1

31.2

32.1

97.1

101

List of all subsidiaries.

Consent of Ernst & Young LLP.

Powers of Attorney.

Certification of Chief Executive Officer pursuant to Section
302 of the Sarbanes-Oxley Act of 2002 (“Sarbanes-Oxley”).

Certification of Executive Vice President and
Chief Financial Officer pursuant to Section 302 of Sarbanes-
Oxley.

Certifications Pursuant to 18 U.S.C. Section 1350, as adopted
pursuant to Section 906 of Sarbanes-Oxley.

Supplemental Executive Officer Recoupment Policy.*

The following materials from the Nasdaq, Inc. Annual Report
on Form 10-K for the year ended December 31, 2023,
formatted in iXBRL (Inline eXtensible Business Reporting
Language): (i) Consolidated Balance Sheets as of December
31, 2023 and December 31, 2022; (ii) Consolidated Statements
of Income for the years ended December 31, 2023, 2022 and
2021 (iii) Consolidated Statements of Comprehensive Income
for the years ended December 31, 2023, 2022 and 2021; (iv)
Consolidated Statements of Changes in Stockholders’ Equity
for the years ended December 31, 2023, 2022 and 2021; (v)
Consolidated Statements of Cash Flows for the years ended
December 31, 2023, 2022 and 2021; and (vi) notes to
consolidated financial statements.

104

Cover Page Interactive Data File, formatted in iXBRL and
contained in Exhibit 101.

____________

*    Management contract or compensatory plan or arrangement.

†     Schedules have been omitted pursuant to Item 601(b)(2) of Regulation S-

K.

(b)     Exhibits:

    See Item 15(a)(3) above.

(c)     Financial Statement Schedules:

    All schedules are omitted because they are not applicable or the required

information is included in the consolidated financial statements or notes.

Item 16. Form 10-K Summary

None.

62

 
By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

*
Thomas A. Kloet
Director

*
Holden Spaht
Director

*
Johan Torgeby
Director

*
Toni Townes-Whitley
Director

*
Jeffery W. Yabuki
Director

*
Alfred W. Zollar
Director

* Pursuant to Power of Attorney
By:
Name:

Title:

/s/ John A. Zecca
John A. Zecca
Attorney-in-Fact

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange
Act  of  1934,  the  registrant  has  duly  caused  this  report  to  be  signed  on  its
behalf by the undersigned, thereunto duly authorized, on February 21, 2024.

Nasdaq, Inc.
(Registrant)

By:
Name:
Title:
Date:

/s/ Adena T. Friedman
Adena T. Friedman
Chief Executive Officer
February 21, 2024

Pursuant  to  the  requirements  of  the  Securities  Exchange  Act  of  1934,  this
report  has  been  signed  below  by  the  following  persons  on  behalf  of  the
registrant and in the capacities indicated as of February 21, 2024.

By:
Name:
Title:

By:
Name:
Title:

By:
Name:
Title:

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

By:
Name:

Title:

/s/ Adena T. Friedman
Adena T. Friedman
Chief Executive Officer and Chair of the Board

/s/ Sarah Youngwood
Sarah Youngwood
Executive Vice President and Chief Financial Officer

/s/ Michelle Daly
Michelle Daly
Senior Vice President, Controller and Principal
Accounting Officer

*
Michael R. Splinter
Director

*
Melissa M. Arnoldi
Director

*
Charlene T. Begley
Director

*
Steven D. Black
Director

*
Essa Kazim
Director

63

Nasdaq, Inc.

INDEX TO CONSOLIDATED FINANCIAL STATEMENTS

The following consolidated financial statements of Nasdaq, Inc. and its subsidiaries are presented herein on the page indicated:

Report of Independent Registered Public Accounting Firm (PCAOB ID 42)

Consolidated Balance Sheets

Consolidated Statements of Income

Consolidated Statements of Comprehensive Income

Consolidated Statements of Changes in Stockholders’ Equity

Consolidated Statements of Cash Flows

Notes to Consolidated Financial Statements

F-1

F-2
F-4

F-5

F-6

F-7

F-8

F-9

 
Critical Audit Matter

The  critical  audit  matter  communicated  below  is  a  matter  arising  from  the
current  period  audit  of  the  financial  statements  that  was  communicated  or
required  to  be  communicated  to  the  audit  committee  and  that:  (1)  relates  to
accounts  or  disclosures  that  are  material  to  the  financial  statements  and  (2)
involved  our  especially  challenging,  subjective  or  complex  judgments.  The
communication  of  the  critical  audit  matter  does  not  alter  in  any  way  our
opinion on the consolidated financial statements, taken as a whole, and we are
not,  by  communicating  the  critical  audit  matter  below,  providing  a  separate
opinion on the critical audit matter or on the accounts or disclosures to which
it relates.

Report of Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of Nasdaq, Inc. 

Opinion on the Financial Statements

We  have  audited  the  accompanying  consolidated  balance  sheets  of  Nasdaq,
Inc.  (the  Company)  as  of  December  31,  2023  and  2022,  the  related
consolidated  statements  of  income,  comprehensive  income,  changes  in
stockholders’ equity and cash flows for each of the three years in the period
ended December 31, 2023, and the related notes (collectively referred to as the
“consolidated financial statements”). In our opinion, the consolidated financial
statements present fairly, in all material respects, the financial position of the
Company  at  December  31,  2023  and  2022,  and  the  results  of  its  operations
and  its  cash  flows  for  each  of  the  three  years  in  the  period  ended  December
31, 2023, in conformity with U.S. generally accepted accounting principles.

We also have audited, in accordance with the standards of the Public Company
Accounting  Oversight  Board  (United  States)  (PCAOB),  the  Company’s
internal  control  over  financial  reporting  as  of  December  31,  2023,  based  on
criteria  established  in  Internal  Control-Integrated  Framework  issued  by  the
Committee of Sponsoring Organizations of the Treadway Commission (2013
framework), and our report dated February 21, 2024 expressed an unqualified
opinion thereon.

Basis for Opinion

the  responsibility  of 

These  financial  statements  are 
the  Company’s
management.  Our  responsibility  is  to  express  an  opinion  on  the  Company’s
financial  statements  based  on  our  audits.  We  are  a  public  accounting  firm
registered with the PCAOB and are required to be independent with respect to
the  Company  in  accordance  with  the  U.S.  federal  securities  laws  and  the
applicable rules and regulations of the Securities and Exchange Commission
and the PCAOB.

We  conducted  our  audits  in  accordance  with  the  standards  of  the  PCAOB.
Those  standards  require  that  we  plan  and  perform  the  audit  to  obtain
reasonable  assurance  about  whether  the  financial  statements  are  free  of
material  misstatement,  whether  due  to  error  or  fraud.  Our  audits  included
performing  procedures  to  assess  the  risks  of  material  misstatement  of  the
financial statements, whether due to error or fraud, and performing procedures
that  respond  to  those  risks.  Such  procedures  included  examining,  on  a  test
basis,  evidence  regarding  the  amounts  and  disclosures  in  the  financial
statements. Our audits also included evaluating the accounting principles used
and  significant  estimates  made  by  management,  as  well  as  evaluating  the
overall  presentation  of  the  financial  statements.  We  believe  that  our  audits
provide a reasonable basis for our opinion.

F-2

 
 
 
 
 
 
 
 
 
 
Description of
the Matter

the  Company  completed 

Accounting for the Acquisition of Adenza
As  described  in  Note  4  to  the  consolidated  financial
statements,  during  2023 
its
acquisition  of  Adenza,  which  was  accounted  for  as  a
business  combination  for  total  purchase  consideration  of
$5,750  million  in  cash  consideration  (subject  to  customary
post-closing  adjustments)  and  the  issuance  of  85,608,414
shares  of  Nasdaq  common  stock  at  a  price  of  $48.71  per
share.  The  transaction  resulted  in  the  recognition  of  $5,933
million of goodwill and $5,050 million of intangible assets.
Intangible  assets  consisted  of  customer  relationships  of
$3,740 million, technology of $950 million and trade names
of $360 million.

Auditing  the  Company’s  accounting  for  its  acquisition  of
Adenza  was  complex  due  to  the  significant  estimation
uncertainty in the Company’s determination of the fair value
of  identified  intangible  assets.  The  significant  estimation
uncertainty  was  primarily  due  to  the  sensitivity  of  the  fair
value of the customer relationships intangible asset to certain
underlying  assumptions.  The  Company  used  the  income
approach,  specifically  the  excess  earnings  method,  to
measure  the  fair  value  of  the  customer  relationships
intangible  asset,  and  the  significant  assumptions  used  in
estimating  its  fair  value  included  customer  attrition  rate,
revenue  growth,  EBITDA  margin,  and  the  discount  rate.
These significant assumptions are forward looking and could
be affected by future economic and market conditions.

How We
Addressed the
Matter in Our
Audit

We  obtained  an  understanding,  evaluated  the  design  and
tested  the  operating  effectiveness  of  controls  over  the
Company’s  processes  with  respect  to  estimates  that  impact
the  accounting  for  the  Adenza  acquisition.  For  example,  we
tested  controls  over  the  estimation  process  supporting  the
recognition  and  measurement  of  the  identified  intangible
assets,  including  the  customer  relationships  intangible  asset,
which  encompassed  testing  controls  over  management’s
review of assumptions used in the valuation model.

the  underlying  data  supporting 

To  test  the  estimated  fair  value  of  the  customer  relationship
intangible asset, we performed audit procedures that included,
among  others,  evaluating  the  Company’s  use  of  valuation
methodologies, evaluating significant assumptions utilized by
the Company, and evaluating the completeness and accuracy
of 
those  significant
assumptions.  We  involved  our  valuation  specialists  to  assist
with our evaluation of the methodology used by the Company
and  significant  assumptions  included  in  the  fair  value
estimate, including testing the customer attrition rate, revenue
growth, EBITDA margin that form the basis of the forecasted
results, and the discount rate. Additionally, we compared the
significant  assumptions  to  current  industry,  market  and
economic  trends,  to  the  historical  results  of  the  acquired
business,  and  to  the  Company’s  budgets  and  forecasts,  in
these
addition 
assumptions.  We  also  evaluated 
the
Company’s disclosures included in Note 4 in relation to these
acquisition matters.

to  performing  sensitivity  analyses  over 

the  adequacy  of 

/s/ Ernst & Young LLP

We have served as the Company’s auditor since 1986.

New York, New York
February 21, 2024

F-3

 
 
 
 
 
 
 
 
 
 
 
 
 
Nasdaq, Inc.
Consolidated Balance Sheets
(in millions, except share and par value amounts)

December 31, 2023

December 31, 2022

Assets
Current assets:

Cash and cash equivalents
Restricted cash and cash equivalents
Default funds and margin deposits (including restricted cash and cash equivalents of $6,645 and $6,470,

respectively)

Financial investments
Receivables, net
Other current assets

Total current assets
Property and equipment, net
Goodwill
Intangible assets, net
Operating lease assets
Other non-current assets

Total assets

Liabilities
Current liabilities:

Accounts payable and accrued expenses
Section 31 fees payable to SEC
Accrued personnel costs
Deferred revenue
Other current liabilities
Default funds and margin deposits
Short-term debt
Total current liabilities
Long-term debt
Deferred tax liabilities, net
Operating lease liabilities
Other non-current liabilities
Total liabilities

Commitments and contingencies

Equity
Nasdaq stockholders’ equity:

Common stock, $0.01 par value, 900,000,000 shares authorized, shares issued: 598,014,520 at December 31, 2023
and 513,157,630 at December 31, 2022; shares outstanding: 575,159,336 at December 31, 2023 and 491,592,491
at December 31, 2022
Additional paid-in capital
Common stock in treasury, at cost: 22,855,184 shares at December 31, 2023 and 21,565,139 shares at December
31, 2022
Accumulated other comprehensive loss
Retained earnings

Total Nasdaq stockholders’ equity
Noncontrolling interests

Total equity

Total liabilities and equity

See accompanying notes to consolidated financial statements.

F-4

$

$

$

$

453  $
20 

7,275 
188 
929 
231 
9,096 
576 
14,112 
7,443 
402 
665 
32,294  $

332  $
84 
303 
594 
146 
7,275 
291 
9,025 
10,163 
1,642 
417 
220 
21,467 

6 
5,496 

(587)
(1,924)
7,825 
10,816 
11 
10,827 
32,294  $

502 
22 

7,021 
181 
677 
201 
8,604 
532 
8,099 
2,581 
444 
608 
20,868 

185 
243 
243 
357 
122 
7,021 
664 
8,835 
4,735 
456 
452 
226 
14,704 

5 
1,445 

(515)
(1,991)
7,207 
6,151 
13 
6,164 
20,868 

Revenues:
Capital Access Platforms
Financial Technology
Market Services
Other revenues
Total revenues

Transaction-based expenses:
Transaction rebates
Brokerage, clearance and exchange fees
Revenues less transaction-based expenses

Operating expenses:
Compensation and benefits
Professional and contract services
Computer operations and data communications
Occupancy
General, administrative and other
Marketing and advertising
Depreciation and amortization
Regulatory
Merger and strategic initiatives
Restructuring charges
Total operating expenses
Operating income
Interest income
Interest expense
Net gain on divestiture of business
Other income (loss)
Net income (loss) from unconsolidated investees
Income before income taxes
Income tax provision
Net income
Net loss attributable to noncontrolling interests

Net income attributable to Nasdaq

Per share information:
Basic earnings per share

Diluted earnings per share

Cash dividends declared per common share

Nasdaq, Inc.

Consolidated Statements of Income
(in millions, except per share amounts)

Year Ended December 31,

2023

2022

2021

$

1,770  $
1,099 
3,156 
39 
6,064 

1,682  $
864 
3,632 
48 
6,226 

(1,838)
(331)
3,895 

(2,092)
(552)
3,582 

1,082 
128 
233 
129 
113 
47 
323 
34 
148 
80 
2,317 
1,578 
115 
(284)
— 
(1)
(7)
1,401 
344 
1,057 
2 
1,059  $

2.10  $

2.08  $

0.86  $

1,003 
140 
207 
104 
125 
51 
258 
33 
82 
15 
2,018 
1,564 
7 
(129)
— 
2 
31 
1,475 
352 
1,123 
2 
1,125  $

2.28  $

2.26  $

0.78  $

$

$

$

$

1,566 
772 
3,471 
77 
5,886 

(2,168)
(298)
3,420 

938 
144 
186 
109 
85 
57 
278 
64 
87 
31 
1,979 
1,441 
1 
(125)
84 
81 
52 
1,534 
347 
1,187 
— 
1,187 

2.38 

2.35 

0.70 

See accompanying notes to consolidated financial statements.

F-5

 
 
 
 
 
 
 
 
 
Nasdaq, Inc.
Consolidated Statements of Comprehensive Income
(in millions)

Net income

Other comprehensive income (loss):
Foreign currency translation gains (losses)
Income tax benefit (expense)
Foreign currency translation, net

(1)

Net unrealized gain from cash flow hedges

Employee benefit plan adjustment gains (losses)
Employee benefit plan income tax provision

Employee benefit plan, net

Total other comprehensive income (loss), net of tax

Comprehensive income
Comprehensive loss attributable to noncontrolling interests
Comprehensive income attributable to Nasdaq

____________
(1)    

Primarily relates to the tax effect of unrealized gains and losses on Euro denominated notes.

Year Ended December 31,

2023

2022

2021

$

1,057  $

1,123  $

1,187 

39 
18 
57 

2 

11 
(3)
8 

(375)
(32)
(407)

— 

5 
(2)
3 

67 
1,124 
2 
1,126  $

(404)
719 
2 
721  $

$

(176)
(42)
(218)

— 

(1)
— 
(1)

(219)
968 
— 
968 

See accompanying notes to consolidated financial statements.

F-6

 
 
 
Consolidated Statements of Changes in Stockholders’ Equity
(in millions)

Nasdaq, Inc. 

2023

Shares

492 
86 

(5)

— 
3 
—
—
1

(2)

$

5 
1 
6 

1,445 
(269)

— 
122 
— 
4,169 
29 
5,496 

(515)
(72)
(587)

(1,991)
67 
(1,924)

7,207 
1,059 
(441)
7,825 

10,816 

13 
(2)
11 

Year Ended December 31,

2022

Shares

2021

$

Shares

495 
— 

(9)

(7)
3 
—
—
19

(1)

500 
— 

(5)

(6)
3 
—
—
1

(1)

5 
— 
5 

1,949 
(308)

(325)
106 
— 
— 
23 
1,445 

(437)
(78)
(515)

(1,587)
(404)
(1,991)

6,465 
1,125 
(383)
7,207 

6,151 

10 
3 
13 

$

5 
— 
5 

2,544 
(468)

(475)
90 
1 
— 
257 
1,949 

(376)
(61)
(437)

(1,368)
(219)
(1,587)

5,628 
1,187 
(350)
6,465 

6,395 

3 
7 
10 

Common stock
Beginning balance

Acquisition-related stock issuance

Ending balance

Additional paid-in capital
Beginning balance

Share repurchase program

ASR agreement
Share-based compensation
Stock option exercises, net
Acquisition-related stock issuance
Other issuances of common stock, net

Ending balance

Common stock in treasury, at cost
Beginning balance

Other employee stock activity

Ending balance

Accumulated other comprehensive loss
Beginning balance

Other comprehensive income (loss)

Ending balance

Retained earnings
Beginning balance

Net income attributable to Nasdaq
Cash dividends declared and paid
Ending balance

Total Nasdaq stockholders’ equity

Noncontrolling interests
Beginning balance
Net activity related to noncontrolling interests
Ending balance

Total Equity

575  $

10,827 

492  $

6,164 

500  $

6,405 

See accompanying notes to consolidated financial statements.

F-7

Nasdaq, Inc.
Consolidated Statements of Cash Flows
(in millions)

Cash flows from operating activities:
Net income
Adjustments to reconcile net income to net cash provided by operating activities:

Depreciation and amortization
Share-based compensation
Deferred income taxes
Extinguishment of debt and bridge fees
Net gain on divestiture of business
Non-cash restructuring charges
Net (income) loss from unconsolidated investees
Operating lease asset impairments
Other reconciling items included in net income

Net change in operating assets and liabilities, net of effects of acquisitions:

Receivables, net
Other assets
Accounts payable and accrued expenses
Section 31 fees payable to SEC
Accrued personnel costs
Deferred revenue
Other liabilities

Net cash provided by operating activities
Cash flows from investing activities:
Purchases of securities
Proceeds from sales and redemptions of securities
Proceeds from divestiture of business, net of cash divested
Acquisition of businesses, net of cash and cash equivalents acquired
Purchases of property and equipment
Investments related to default funds and margin deposits, net
Other investing activities

(1)

Net cash provided by (used in) investing activities
Cash flows from financing activities:
Proceeds from (repayments of) commercial paper, net
Repayments of debt and credit commitment
Payment of debt extinguishment cost and bridge fees
Proceeds from issuances of debt, net of issuance costs

Repurchases of common stock
ASR agreement
Dividends paid

Proceeds received from employee stock activity and other issuances
Payments related to employee shares withheld for taxes
Default funds and margin deposits
Other financing activities

Net cash provided by financing activities

Effect of exchange rate changes on cash and cash equivalents and restricted cash and cash equivalents

Net increase (decrease) in cash and cash equivalents and restricted cash and cash equivalents
Cash and cash equivalents, restricted cash and cash equivalents at beginning of period

Cash and cash equivalents, restricted cash and cash equivalents at end of period
Reconciliation of Cash, Cash Equivalents and Restricted Cash and Cash Equivalents
Cash and cash equivalents
Restricted cash and cash equivalents
Restricted cash and cash equivalents (default funds and margin deposits)

Total
Supplemental Disclosure Cash Flow Information

Interest paid
Income taxes paid, net of refund

Year Ended December 31,

2023

2022

2021

$

1,057  $

1,123  $

1,187 

323 
122 
68 
25 
— 
12 
7 
13 
30 

3 
9 
149 
(160)
13 
88 
(63)

1,696 

(712)
719 
— 
(5,766)
(158)
(74)
(3)

(5,994)

(371)
(260)
(25)
5,608 
(269)
— 
(441)
29 
(72)
22 
(1)

4,220 

202 

258 
106 
38 
16 
— 
— 
(31)
— 
28 

(101)
98 
19 
181 
— 
16 
(45)

1,706 

(322)
320 
— 
(41)
(152)
211 
33 

49 

238 
(1,097)
(16)
541 
(308)
(325)
(383)
23 
(78)
2,440 
1 

1,036 

(1,293)

124 
6,994 
7,118  $

453  $
20 
6,645 
7,118  $

177  $
254  $

1,498 
5,496 
6,994  $

502  $
22 
6,470 
6,994  $

116  $
274  $

$

$

$

$
$

278 
90 
94 
33 
(84)
— 
(52)
— 
6 

(6)
(140)
(17)
(162)
28 
106 
(278)
1,083 

(316)
285 
190 
(2,430)
(163)
(132)
(87)
(2,653)

420 
(804)
(33)
826 
(468)
(475)
(350)
26 
(61)
2,330 
7 
1,418 
(331)
(483)
5,979 
5,496 

393 
29 
5,074 
5,496 

118 
501 

__________________________
(1)

    Includes purchases and proceeds from sales and redemptions related to the default funds and margin deposits of our clearing operations. For further information, see "Default Fund Contributions and

Margin Deposits," within Note 15, "Clearing Operations."

See accompanying notes to consolidated financial statements.

F-8

Nasdaq, Inc.

Notes to Consolidated Financial Statements

1. ORGANIZATION AND NATURE OF OPERATIONS

Nasdaq is a global technology company serving corporate clients, investment
managers,  banks,  brokers,  and  exchange  operators  as  they  navigate  and
interact with the global capital markets and the broader financial system. We
aspire 
liquidity,
transparency,  and  integrity  of  the  global  economy.  Our  diverse  offering  of
data,  analytics,  software,  exchange  capabilities,  and  client-centric  services
enables clients to optimize and execute their business vision with confidence.

to  deliver  world-leading  platforms 

improve 

that 

the 

Our organizational structure aligns our businesses with the foundational shifts
that  are  driving  the  evolution  of  the  global  financial  system.  Following  the
acquisition  of  Adenza,  we  further  refined  the  divisional  structure  into  three
business  segments:  Capital  Access  Platforms,  Financial  Technology  and
Market Services.

For further discussion of our businesses, see “Products and Services,” of “Part
1, Item 1. Business.”

Capital Access Platforms

Our  Capital  Access  Platforms  segment  includes  Data  &  Listing  Services,
Index and Workflow & Insights.

Our Data business distributes historical and real-time market data to the sell-
side,  the  institutional  investing  community,  retail  online  brokers,  proprietary
trading firms and other venues, as well as internet portals and data distributors.
Our  data  products  can  enhance  transparency  of  market  activity  within  our
exchanges  and  provide  critical  information  to  professional  and  non-
professional investors globally.

Our Listing Services business operates in the U.S. and Europe on a variety of
listing  platforms  around  the  world  to  provide  multiple  global  capital  raising
solutions  for  public  companies.  Our  main  listing  markets  are  The  Nasdaq
Stock Market and the Nasdaq Nordic and Nasdaq Baltic exchanges. Through
Nasdaq  First  North,  our  Nordic  and  Baltic  operations  also  offer  alternative
marketplaces for smaller companies and growth companies.

As of December 31, 2023, there were 4,044 total listings on The Nasdaq Stock
Market,  including  600  ETPs.  The  combined  market  capitalization  was
approximately $27.2 trillion. In Europe, the Nasdaq Nordic and Nasdaq Baltic
exchanges,  together  with  Nasdaq  First  North,  were  home  to  1,218  listed
companies  with  a  combined  market  capitalization  of  approximately  $2.1
trillion.

Our  Index  business  develops  and  licenses  Nasdaq-branded  indices  and
financial products. We also license cash-settled options, futures and options on
futures  on  our  indices.  As  of  December  31,  2023,  388  ETPs  listed  on  27
exchanges  in  over  20  countries  tracked  a  Nasdaq  index  and  accounted  for
$473 billion in AUM.

investment  decisions,  deploy 

Workflow  &  Insights 
includes  our  analytics  and  corporate  solutions
businesses.  Our  analytics  business  provides  asset  managers,  investment
consultants  and  institutional  asset  owners  with  information  and  analytics  to
their  resources  more
make  data-driven 
productively,  and  provide  liquidity  solutions  for  private  funds.  Through  our
eVestment and Solovis solutions, we provide a suite of cloud-based solutions
that  help  institutional  investors  and  consultants  conduct  pre-investment  due
diligence,  and  monitor  their  portfolios  post-investment.  The  eVestment
platform  also  enables  asset  managers  to  efficiently  distribute  information
about their firms and funds to asset owners and consultants worldwide.

Through our Solovis platform, endowments, foundations, pensions and family
offices  transform  how  they  collect  and  aggregate  investment  data,  analyze
portfolio  performance,  model  and  predict  future  outcomes,  and  share
meaningful  portfolio  insights  with  key  stakeholders.  The  Nasdaq  Fund
Network  and  Nasdaq  Data  Link  are  additional  platforms  in  our  suite  of
investment data analytics offerings and data management tools.

Our corporate solutions business includes our Investor Relations Intelligence,
ESG  Solutions  and  Governance  Solutions  products,  which  serve  both  public
and private companies and organizations. Our public company clients can be
companies  listed  on  our  exchanges  or  other  U.S.  and  global  exchanges.  Our
private company clients include a diverse group of organizations ranging from
family-owned companies, government organizations, law firms, privately held
entities,  and  various  non-profit  organizations  to  hospitals  and  healthcare
systems. We help organizations enhance their ability to understand and expand
their global shareholder base, improve corporate governance, and navigate the
evolving ESG landscape through our suite of advanced technology, analytics,
reporting and consulting services.

Financial Technology

Financial  Technology  comprises  Financial  Crime  Management  Technology,
Regulatory Technology and Capital Markets Technology solutions.

Financial  Crime  Management  Technology  includes  our  Verafin  solution,  a
cloud-based anti-financial crime management platform, which helps financial
institutions  detect,  investigate,  and  report  money  laundering  and  financial
fraud.

F-9

Regulatory  Technology  comprises  our  surveillance  solutions  and  AxiomSL.
Our  surveillance  solutions  are  designed  for  brokers  and  other  market
participants to assist them in complying with market rules, regulations as well
as  regulators  and  exchanges  for  surveillance.  AxiomSL  is  a  global  leader  in
risk  data  management  and  regulatory  reporting  solutions  for  the  financial
industry,  including  banks,  broker  dealers  and  asset  managers.  Its  unique
enterprise  data  management  platform  delivers  data  lineage,  risk  aggregation,
reconciliation,  validation  and  audit
analytics,  workflow  automation, 
functionality, as well as disclosures. AxiomSL’s platform supports compliance
across a wide range of global and local regulations.

solutions  provider  and  partner 

Capital  Markets  Technology  includes  market  technology,  trade  management
services  and  Calypso.  Our  market  technology  business  is  a  leading  global
to  exchanges,  clearing
technology 
organizations, central securities depositories, regulators, banks, brokers, buy-
side  firms  and  corporate  businesses.  Our  market  technology  solutions  are
utilized  by  leading  markets  in  North  America,  Europe  and  Asia  as  well  as
emerging  markets  in  the  Middle  East,  Latin  America,  and  Africa.  Our  trade
management  services  provides  market  participants  with  a  wide  variety  of
alternatives  for  connecting  to  and  accessing  our  markets  for  a  fee.  Our
marketplaces  may  be  accessed  via  a  number  of  different  protocols  used  for
quoting, order entry, trade reporting and connectivity to various data feeds. We
also  provide  colocation  services  to  market  participants,  whereby  we  offer
firms  cabinet  space  and  power  to  house  their  own  equipment  and  servers
within  our  data  centers.  Additionally,  we  offer  a  number  of  wireless
connectivity offerings between select data centers using millimeter wave and
microwave  technology.  In  June  2022,  we  completed  the  wind-down  of  our
Nordic  broker  services  business.  Calypso  is  a  leading  provider  of  front-to-
back  technology  solutions  for  the  financial  markets.  The  Calypso  platform
provides customers with a single platform designed from the outset to enable
consolidation, innovation and growth.

Market Services

Our  Market  Services  segment  includes  revenues  from  equity  derivatives
trading, cash equity trading, Nordic fixed income trading & clearing, Nordic
commodities  and  U.S.  Tape  plans  data.  We  operate  multiple  exchanges  and
other marketplace facilities across several asset classes, including derivatives,
commodities, cash equity, debt, structured products and ETPs. In addition, in
certain  countries  where  we  operate  exchanges,  we  also  provide  clearing,
settlement  and  central  depository  services.  In  June  2023,  we  entered  into  an
agreement to sell our European energy trading and clearing business, subject
to regulatory approval. Beginning in the third quarter of 2023, revenues from
this business are reflected in Other Revenues in the Consolidated Statements
of  Income  for  all  periods,  and  in  our  Corporate  segment  for  our  segment
disclosures.  Additionally,  certain  data  revenues  from  this  business  that  were
previously included in our Capital Access Platforms segment are also reflected
in Other Revenues in the Consolidated Statements of Income for all

periods, and in our Corporate segment for our segment disclosures.

Our transaction-based platforms provide market participants with the ability to
access, process, display and integrate orders and quotes. The platforms allow
the  routing  and  execution  of  buy  and  sell  orders  as  well  as  the  reporting  of
transactions, providing fee-based revenues.

2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Basis of Presentation and Principles of Consolidation

The  consolidated  financial  statements  are  prepared  in  accordance  with  U.S.
GAAP and include the accounts of Nasdaq, its wholly-owned subsidiaries and
other  entities  in  which  Nasdaq  has  a  controlling  financial  interest.  When  we
do not have a controlling interest in an entity but exercise significant influence
over the entity’s operating and financial policies, such investment is accounted
for under the equity method of accounting. We recognize our share of earnings
or  losses  of  an  equity  method  investee  based  on  our  ownership  percentage.
See  “Equity  Method  Investments,”  of  Note  6,  “Investments,”  for  further
discussion of our equity method investments.

The  accompanying  consolidated  financial  statements  reflect  all  adjustments
which are, in the opinion of management, necessary for a fair statement of the
results.  These  adjustments  are  of  a  normal  recurring  nature.  All  significant
intercompany  accounts  and 
in
consolidation.

transactions  have  been  eliminated 

Certain  prior  year  amounts  have  been  reclassified  to  conform  to  the  current
year presentation.

Use of Estimates

In  preparing  our  consolidated  financial  statements,  we  make  assumptions,
judgments  and  estimates  that  can  have  a  significant  impact  on  our  revenue,
operating income and net income, as well as on the value of certain assets and
liabilities  in  our  consolidated  balance  sheets.  At  least  quarterly,  we  evaluate
our  assumptions,  judgments  and  estimates,  and  make  changes  as  deemed
necessary.

Foreign Currency

Foreign denominated assets and liabilities are remeasured into the functional
currency  at  exchange  rates  in  effect  at  the  balance  sheet  date  and  recorded
through the income statement. Gains or losses resulting from foreign currency
transactions  are  remeasured  using  the  rates  on  the  dates  on  which  those
elements  are  recognized  during  the  period,  and  are  included  in  general,
administrative and other expense in the Consolidated Statements of Income.

Translation  gains  or  losses  resulting  from  translating  our  subsidiaries’
financial  statements  from  the  local  functional  currency  to  the  reporting
currency,  net  of  tax,  are  included  in  accumulated  other  comprehensive  loss
within  stockholders’  equity  in  the  Consolidated  Balance  Sheets.  Assets  and
liabilities are translated at the balance sheet date while revenues and expenses
are  translated  at  the  date  the  transaction  occurs  or  at  an  applicable  average
rate.

F-10

Cash and Cash Equivalents

Cash and cash equivalents include all non-restricted cash in banks and highly
liquid  investments  with  original  maturities  of  90  days  or  less  at  the  time  of
purchase. Such equivalent investments included in cash and cash equivalents
in  the  Consolidated  Balance  Sheets  were  $122  million  as  of  December  31,
2023 and $242 million as of December 31, 2022. Cash equivalents are carried
at  cost  plus  accrued  interest,  which  approximates  fair  value  due  to  the  short
maturities of these investments.

Restricted Cash

Restricted cash and cash equivalents, which was $20 million as of December
31,  2023  and  $22  million  as  of  December  31,  2022,  is  restricted  from
withdrawal due to a contractual or regulatory requirement or not available for
general use and as such is classified as restricted in the Consolidated Balance
Sheets.  As  of  December  31,  2023  and  2022,  restricted  cash  and  cash
equivalents primarily includes funds held for regulatory capital for our trading
and clearing businesses.

Default Funds and Margin Deposits

Nasdaq  Clearing  members’  cash  contributions  are  included  in  default  funds
and margin deposits in the Consolidated Balance Sheets as both a current asset
and a current liability. These balances may fluctuate over time due to changes
in  the  amount  of  deposits  required  and  whether  members  choose  to  provide
cash  or  non-cash  contributions.  Non-cash  contributions  include  highly  rated
government  debt  securities  that  must  meet  specific  criteria  approved  by
Nasdaq  Clearing.  Non-cash  contributions  are  pledged  assets  that  are  not
recorded in the Consolidated Balance Sheets as Nasdaq Clearing does not take
legal  ownership  of  these  assets  and  the  risks  and  rewards  remain  with  the
clearing members.

Receivables, net

Our receivables are concentrated with our customers which primarily include
corporate  clients,  investment  managers,  banks,  brokers,  and  exchange
operators.  Receivables  are  shown  net  of  allowance  for  credit  losses.  The
allowance is maintained at a level that management believes to be sufficient to
absorb expected losses over the life of our accounts receivable portfolio. The
allowance  is  increased  by  the  provision  for  bad  debts,  which  is  included  in
general,  administrative  and  other  expense  in  the  Consolidated  Statements  of
Income, and decreased by the amount of charge-offs, net of recoveries.

The  allowance  is  primarily  based  on  an  aging  methodology.  This  method
applies loss rates based on historical loss information which is disaggregated
by  business  segment  and,  as  deemed  necessary,  is  adjusted  for  other  factors
and  considerations  that  could  impact  collectibility. Additionally,  we  consider
corporate  default  rate  averages  over  an  extended  period  as  compared  to  the
period  covered  by  our  historical  loss  data  and  include  an  adjustment  to
historical  loss  percentages  for  current  conditions  and  expected  future
conditions if necessary.

In  circumstances  where  a  specific  customer’s  inability  to  meet  its  financial
obligations  is  known  (i.e.,  bankruptcy  filings),  we  determine  whether  a
specific provision for bad debts is required. Accounts receivable are written-
off  against  the  allowance  when  collection  efforts  cease.  Due  to  changing
economic, business and market conditions, we review the allowance quarterly
and  make  changes  to  the  allowance  through  the  provision  for  bad  debts  as
appropriate. If circumstances change (i.e., higher than expected defaults or an
unexpected material adverse change in a major customer’s ability to pay), our
estimates of recoverability could be reduced by a material amount. The total
allowance netted against receivables in the Consolidated Balance Sheets was
$18  million  as  of  December  31,  2023  and  $15  million  as  of  December  31,
2022.  Any  provision  for  bad  debt  or  write-off  recorded  during  the  year  was
immaterial.

Investments

Purchases and sales of investment securities are recognized on settlement date.

Financial Investments

Financial investments are comprised of trading securities bought principally to
meet  regulatory  capital  requirements  mainly  for  our  clearing  operations  at
Nasdaq Clearing. These investments are classified as trading securities as they
are generally sold in the near term, with changes in fair value included in other
income in the Consolidated Statements of Income.

Fair  value  is  generally  obtained  from  third-party  pricing  sources.  When
available,  quoted  market  prices  are  used  to  determine  fair  value.  If  quoted
market prices are not available, fair values are estimated using pricing models
with observable market inputs. The inputs to the valuation models vary by the
type  of  security  being  priced  but  are  typically  benchmark  yields,  reported
trades,  broker-dealer  quotes,  and  prices  of  similar  assets.  Pricing  models
generally  do  not  entail  material  subjectivity  because  the  methodologies
employed  use  inputs  observed  from  active  markets.  See  “Fair  Value
Measurements” below for further discussion of fair value measures.

Equity Securities

Investments  in  equity  securities  with  readily  determinable  fair  values  (other
than  those  accounted  for  under  the  equity  method  or  those  that  result  in
consolidation  of  the  investee)  are  measured  at  fair  value  and  any  changes  in
fair  value  are  recognized  in  other  income  in  the  Consolidated  Statements  of
Income.

Equity investments without readily determinable fair values are accounted for
under the measurement alternative, under which investments are measured at
cost,  less  any  impairment,  plus  or  minus  changes  resulting  from  observable
price changes in orderly transactions for the identical or a similar investment
of the same issuer on a prospective basis. We assess relevant transactions that
occur on or before the balance sheet date to identify observable price changes,
and

F-11

we  regularly  monitor  these  investments  to  evaluate  whether  there  is  an
indication that the investment is impaired, based on the  share  price  from  the
investee’s latest financing round, the performance of the investee in relation to
its  own  operating  targets,  the  investee’s  liquidity  and  cash  position,  and
general  market  conditions.  If  a  qualitative  assessment  indicates  that  the
security is impaired, Nasdaq will estimate the fair value of the security and, if
the fair value is less than the carrying amount of the security, will recognize an
impairment  loss  in  net  income  equal  to  the  difference  in  the  period  the
impairment occurs. See  Note  6,  “Investments,”  for  further  discussion  of  our
equity securities.

For  the  years  ended  December  31,  2023,  2022  and  2021,  no  material
adjustments were made to the carrying value of our equity securities.

Our investments in equity securities are included in other non-current assets in
the  Consolidated  Balance  Sheets,  as  we  intend  to  hold  these  investments  for
more than one year.

Equity Method Investments

In general, the equity method of accounting is used when we own 20% to 50%
of the outstanding voting stock of a company or when we are able to exercise
significant  influence  over  the  operating  and  financial  policies  of  a  company.
We  have  certain  investments  in  which  we  have  determined  that  we  have
significant influence and as such account for the investments under the equity
method of accounting. We record our estimated pro-rata share of earnings or
losses  each  reporting  period  and  record  any  dividends  as  a  reduction  in  the
investment  balance.  We  evaluate  our  equity  method  investments  for  other-
than-temporary  declines  in  value  by  considering  a  variety  of  factors  such  as
the  earnings  capacity  of  the  investment  and  the  fair  value  of  the  investment
compared  to  its  carrying  amount.  In  addition,  for  investments  where  the
market value is readily determinable, we consider the underlying stock price.
If the estimated fair value of the investment is less than the carrying amount
and management considers the decline in value to be other than temporary, the
excess  of  the  carrying  amount  over  the  estimated  fair  value  is  recognized  in
net  income  in  the  period  the  impairment  occurs. See  Note  6,  “Investments,”
for further discussion of our equity method investments.

No  material  impairments  were  recorded  to  reduce  the  carrying  value  of  our
equity method investments in 2023, 2022 or 2021.

Derivative Financial Instruments and Hedging Activities

Non-Designated Derivatives

We  use  foreign  exchange  forward  contracts  to  manage  foreign  currency
exposure  of  intercompany  loans,  accounts  receivable,  accounts  payable  and
other  balance  sheet  items.  These  contracts  are  not  designated  as  hedges  for
financial  reporting  purposes.  The  change  in  fair  value  of  these  contracts  is
recognized in general, administrative and other

expense  in  the  Consolidated  Statements  of  Income  and  offsets  the  foreign
currency exposure.

As of December 31, 2023 and 2022, the fair value amounts of our derivative
instruments were immaterial.

Net Investment Hedges

Net  assets  of  our  foreign  subsidiaries  are  exposed  to  volatility  in  foreign
currency  exchange  rates.  We  may  utilize  net  investment  hedges  to  offset  the
translation  adjustment  arising  from  re-measuring  our  investment  in  foreign
subsidiaries.

Our 2029, 2030, 2032 and 2033 Notes have been designated as a hedge of our
net investment in certain foreign subsidiaries to mitigate the foreign exchange
risk associated with certain investments in these subsidiaries. Any increase or
decrease  related  to  the  remeasurement  of  the  2029,  2030,  2032  and  2033
Notes into U.S. dollars is recorded in accumulated other comprehensive loss
within  stockholders’  equity  in  the  Consolidated  Balance  Sheets.  See  “Net
Investment Hedge” of Note 9, “Debt Obligations,” for further discussion.

Property and Equipment, net

Property and equipment, including leasehold improvements, are carried at cost
less asset impairment charges and accumulated depreciation and amortization.
Depreciation  and  amortization  are  recognized  using  the  straight-line  method
over the estimated useful lives of the related assets, which range from 10 to 40
years  for  buildings  and  improvements,  3  to  5  years  for  data  processing
equipment, and 5 to 10 years for furniture and equipment.

Leasehold improvements are amortized using the straight-line method over the
shorter  of  their  estimated  useful  lives  or  the  remaining  term  of  the  related
lease.

We develop systems solutions for both internal and external use. Certain costs
incurred in connection with developing or obtaining internal use software are
capitalized. In addition, certain costs of computer software to be sold, leased,
or otherwise marketed as a separate product or as part of a product or process
are capitalized beginning when a product’s technological feasibility has been
established  and  ending  when  a  product  is  available  for  general  release.
Technological feasibility is established upon completion of a detailed program
design  or,  in  its  absence,  completion.  Prior  to  reaching  technological
feasibility, all costs are charged to expense. Unamortized capitalized costs are
included  in  data  processing  equipment  and  software,  within  property  and
equipment, net in the Consolidated Balance Sheets. Capitalized software costs
are  amortized  on  a  straight-line  basis  over  the  estimated  useful  lives  of  the
software,  generally  5  to  10  years.  Amortization  of  these  costs  is  included  in
depreciation  and  amortization  expense  in  the  Consolidated  Statements  of
Income.

Implementation  costs  incurred  in  a  cloud  computing  arrangement  that  is  a
service contract are capitalized as a prepaid asset, included in other assets in
our Consolidated Balance Sheets, and are amortized over the expected service

F-12

period  in  the  relevant  expense  category  in  the  Consolidated  Statements  of
Income.

Property  and  equipment  are  subject  to  impairment  testing  when  events  or
conditions  indicate  that  the  carrying  amount  of  an  asset  may  not  be
recoverable. The carrying amount of an asset is not recoverable if it exceeds
the  sum  of  the  undiscounted  cash  flows  expected  to  result  from  the  use  and
eventual disposition of the asset, or for internal use software, the fair value of
the asset. Any required impairment loss is measured as the amount by which
the  carrying  amount  of  the  asset  exceeds  its  fair  value  and  is  recorded  as  a
reduction in the carrying amount of the related asset and a charge to operating
results.

See Note 7, “Property and Equipment, net,” for further discussion.

Leases

At inception, we determine whether a contract is or contains a lease. We have
operating  leases  which  are  primarily  real  estate  leases  for  our  U.S.  and
European  headquarters  and  for  general  office  space.  As  of  December  31,
2023, these leases have varying lease terms with remaining maturities ranging
up to 13 years. Operating lease balances are included in operating lease assets,
other  current  liabilities,  and  operating  lease  liabilities  in  our  Consolidated
Balance Sheets. We do not have any leases classified as finance leases.

Operating  lease  assets  represent  our  right  to  use  an  underlying  asset  for  the
lease  term  and  lease  liabilities  represent  our  obligation  to  make  lease
payments  arising  from  the  lease.  Operating  lease  assets  and  liabilities  are
recognized  at  commencement  date  based  on  the  present  value  of  lease
payments over the lease term. Since our leases do not provide an implicit rate,
we use our incremental borrowing rate based on the estimated rate of interest
for  collateralized  borrowing  over  a  similar  term  of  the  lease  payments  at
commencement date in determining the present value of lease payments. The
operating  lease  asset  also  includes  any  lease  payments  made  and  excludes
lease  incentives.  Our  lease  terms  include  options  to  extend  or  terminate  the
lease when we are reasonably certain that we will exercise that option. Lease
expense for lease payments is recognized on a straight-line basis over the lease
term.  Certain  of  our  lease  agreements  include  rental  payments  adjusted
periodically  for  inflation  based  on  an  index  or  rate.  These  payments  are
included  in  the  initial  measurement  of  the  operating  lease  liability  and
operating lease asset. However, rental payments that are based on a change in
an index or a rate are considered variable lease payments and are expensed as
incurred.

We  have  lease  agreements  with  lease  and  non-lease  components,  which  are
accounted for as a single performance obligation to the extent that the timing
and pattern of transfer are similar for the lease and non-lease components and
the lease component qualifies as an operating lease. We do not recognize lease
liabilities  and  operating  lease  assets  for  leases  with  a  term  of  12  months  or
less. We recognize these lease payments on a straight-line basis over the lease
term.

We  review  our  operating  lease  assets  for  potential  impairment  when  there  is
evidence  that  events  or  changes  in  circumstances  indicate  that  the  carrying
amount of the asset may not be recoverable. We fully impair our lease assets
for locations that we vacate with no intention to sublease.

See Note 16, “Leases,” for further discussion.

Goodwill and Indefinite-Lived Intangible Assets

identifiable 

intangibles,  such  as  customer 

Goodwill  represents  the  excess  of  purchase  price  over  the  value  assigned  to
the net assets, including identifiable intangible assets, of a business acquired.
Goodwill is allocated to our reporting units based on the assignment of the fair
values  of  each  reporting  unit  of  the  acquired  company.  We  recognize
specifically 
relationships,
technology,  exchange  and  clearing  registrations,  trade  names  and  licenses
when  a  specific  right  or  contract  is  acquired.  Goodwill  and  intangible  assets
deemed  to  have  indefinite  useful  lives,  primarily  exchange  and  clearing
registrations,  are  not  amortized  but  instead  are  tested  for  impairment  at  least
annually as of October 1 and more frequently whenever events or changes in
circumstances  indicate  that  the  fair  value  of  the  asset  may  be  less  than  its
carrying  amount,  such  as  changes  in  the  business  climate,  poor  indicators  of
operating performance or the sale or disposition of a significant portion of a
reporting unit. When testing goodwill and indefinite-lived intangible assets for
impairment, we have the option of first performing a qualitative assessment to
determine whether it is more likely than not that the fair value of a reporting
unit  or  indefinite-lived  intangible  asset  is  less  than  their  respective  carrying
amounts as the basis to determine if it is necessary to perform a quantitative
impairment test. If we choose not to complete a qualitative assessment, or if
the initial assessment indicates that it is more likely than not that the carrying
amount  of  a  reporting  unit  or  the  carrying  amount  of  an  indefinite-lived
intangible  asset  exceeds  their  respective  estimated  fair  values,  a  quantitative
test is required.

In  performing  a  quantitative  impairment  test,  we  compare  the  fair  value  of
each  reporting  unit  and  indefinite-lived  intangible  asset  with  their  respective
carrying  amounts.  If  the  carrying  amounts  of  the  reporting  unit  or  the
indefinite-lived  intangible  asset  exceed  their  respective  fair  values,  an
impairment charge is recognized in an amount equal to the difference, limited
to  the  total  amount  of  goodwill  allocated  to  that  reporting  unit  or  the  total
carrying value of the indefinite-lived intangible asset.

There was no impairment of goodwill or indefinite-lived intangible assets for
the years ended December 31, 2023, 2022 and 2021. Future disruptions to our
business  and  events,  such  as  prolonged  economic  weakness  or  unexpected
significant  declines  in  operating  results  of  any  of  our  reporting  units  or
businesses,  may  result  in  goodwill  or  indefinite-lived  intangible  asset
impairment charges in the future.

F-13

Other Long-Lived Assets

We  review  our  other  long-lived  assets,  such  as  finite-lived  intangible  assets
and property and equipment, for potential impairment when there is evidence
that events or changes in circumstances indicate that the carrying amount of an
asset  may  not  be  recoverable.  The  carrying  amount  of  an  asset  is  not
recoverable if it exceeds the sum of the undiscounted cash flows expected to
result from the use and eventual disposition of the asset. Fair value of finite-
lived  intangible  assets  and  property  and  equipment  is  based  on  various
valuation techniques. Any required impairment loss is measured as the amount
by  which  the  carrying  amount  of  the  asset  exceeds  its  fair  value  and  is
recorded  as  a  reduction  in  the  carrying  amount  of  the  related  asset  and  a
charge to operating results.

There were no material finite-lived impairment charges in 2023 and 2022. We
recorded pre-tax, non-cash finite-lived intangible assets impairment charges of
$14  million  in  2021  related  to  a  finite-lived  intangible  asset  for  customer
relationships  associated  with  the  wind  down  of  a  previous  acquisition.  In
addition,  we  also  recorded  pre-tax,  non-cash  property  and  equipment  asset
impairment charges of $12 million in 2023, $8 million in 2022, and $4 million
in 2021.

Revenue Recognition and Transaction-Based Expenses

Revenue From Contracts With Customers

Our  revenue  recognition  policies  under  “Revenue  from  Contracts  with
Customers (Topic 606),” are described in the following paragraphs.

Contract Balances

Substantially all of our revenues are considered to be revenues from contracts
with customers. The related accounts receivable balances are recorded in our
Consolidated Balance Sheets as receivables which are net of an allowance for
credit  losses  of  $18  million  as  of  December  31,  2023 and $15 million  as  of
December 31, 2022. The activity during the period relating to changes in the
allowance  for  credit  losses  was  immaterial.  We  do  not  have  obligations  for
warranties, returns or refunds to customers.

The majority of our contracts with customers do not have significant variable
consideration. We do not have a material amount of revenues recognized from
performance  obligations  that  were  satisfied  in  prior  periods.  We  do  not
provide  disclosures  about 
to  unsatisfied
performance obligations if contract durations are less than one year.

transaction  price  allocated 

For contract durations that are one-year or greater, the portion of transaction
price  allocated  to  unsatisfied  performance  obligations  is  included  in  Note 3,
“Revenue  From  Contracts  With  Customers.”  Our  deferred  revenue  primarily
arises from contract liabilities related to our fees for annual and initial listings,
workflow  &  insights,  regulatory  technology,  and  capital  markets  technology
contracts. Deferred revenue is the only significant contract asset or liability as
of December 31, 2023 and 2022. See Note 8, “Deferred Revenue,” for our

discussion  of  deferred  revenue  balances,  activity,  and  expected  timing  of
recognition. See “Revenue Recognition” below for further descriptions of our
revenue contracts.

Sales commissions earned by our sales force are considered incremental and
recoverable  costs  of  obtaining  a  contract  with  a  customer.  These  costs  are
deferred and amortized on a straight-line basis over the period of benefit that
we have determined to be the contract term or estimated service period. Sales
commissions  for  renewal  contracts  are  deferred  and  amortized  on  a  straight-
line basis over the related contractual renewal period. Amortization expense is
included in compensation and benefits expense in the Consolidated Statements
of Income. The balance of deferred costs and related amortization expense are
not  material  to  our  consolidated  financial  statements.  Sales  commissions  are
expensed when incurred if contract durations are one year or less. Sales taxes
are excluded from transaction prices.

Certain judgments and estimates were used in the identification and timing of
satisfaction  of  performance  obligations  and 
the  related  allocation  of
transaction  price  and  are  discussed  below.  We  believe  that  these  represent  a
faithful depiction of the transfer of services to our customers.

Revenue Recognition

Our  primary  revenue  contract  classifications  are  described  below.  Revenues
are  categorized  based  on  similar  economic  characteristics  of  the  nature,
amount, timing and uncertainty of our revenues and cash flows.

Capital Access Platforms

Data and Listings

Data revenues are earned from U.S. and European proprietary data products.
We  earn  revenues  primarily  based  on  the  number  of  data  subscribers  and
distributors  of  our  data.  Data  revenues  are  subscription-based  and  are
recognized on a monthly basis.

Listing  services  revenues  primarily  include  initial  listing  fees  and  annual
renewal  fees.  Under  Topic  606,  the  initial  listing  fee  is  allocated  to  multiple
performance  obligations  including  initial  and  subsequent  listing  services  and
corporate  solutions  products  (when  a  company  qualifies  to  receive  certain
complimentary  IPO  products  under  the  applicable  Nasdaq  rule),  as  well  as  a
customer’s  material  right  to  renew  the  option  to  list  on  our  exchanges.  In
performing  this  allocation,  the  standalone  selling  price  of  the  performance
obligations  is  based  on  the  initial  and  annual  listing  fees  and  the  standalone
selling price of the IPO complimentary services is based on its market value.
All  listing  fees  are  billed  upfront  and  the  identified  performance  obligations
are satisfied over time since the customer receives and consumes the benefit as
Nasdaq provides the listing service. The amount of revenue related to the IPO
complimentary  services  performance  obligation  is  recognized  ratably  over  a
three-year  period,  which  is  based  on  contract  terms,  with  the  remaining
revenue  recognized  ratably  over  six  years  which  is  based  on  our  historical
listing experience and projected future listing duration.

F-14

In the U.S., annual renewal fees are charged to listed companies based on their
number of outstanding shares at the end of the prior year and are recognized
ratably  over  the  following  twelve-month  period  since  the  customer  receives
and  consumes  the  benefit  as  Nasdaq  provides  the  service.  Annual  fees  are
charged  to  newly  listed  companies  on  a  pro-rata  basis,  based  on  outstanding
shares  at  the  time  of  listing  and  recognized  over  the  remainder  of  the  year.
European  annual  renewal  fees,  which  are  received  from  companies  listed  on
our Nasdaq Nordic and Nasdaq Baltic exchanges and Nasdaq First North, are
directly  related  to  the  listed  companies’  market  capitalization  on  a  trailing
twelve-month  basis  and  are  recognized  ratably  over  the  following  twelve-
month period since the customer receives and consumes the benefit as Nasdaq
provides the service.

Index

We  develop  and  license  Nasdaq-branded  indices  and  financial  products  and
provide index data products for third-party clients. Revenues primarily include
license fees from these branded indices and financial products in the U.S. and
abroad.  We  primarily  have  two  types  of  license  agreements:  asset-based
licenses  and  transaction-based  licenses.  Asset-based  licenses  are  generally
renewable agreements. Customers are charged based on a percentage of AUM
for  licensed  products,  per  the  agreement,  on  a  monthly  or  quarterly
basis. These  revenues  are  recognized  over  the  term  of  the  license  agreement
since the customer receives and consumes the benefit as Nasdaq provides the
service. Revenue from index data subscriptions are recognized on a monthly
basis.  Transaction-based 
renewable
agreements.  Customers  are  charged  based  on  transaction  volume  or  a
minimum  contract  amount,  or  both.  If  a  customer  is  charged  based  on
transaction  volume,  we  recognize  revenue  when  the  transaction  occurs.  If  a
customer  is  charged  based  on  a  minimum  contract  amount,  we  recognize
revenue on a pro-rata basis over the licensing term since the customer receives
and consumes the benefit as Nasdaq provides the service. 

generally 

licenses 

also 

are 

Workflow & Insights

Analytics revenues are earned from investment content and analytics products.
We  earn  revenues  primarily  based  on  the  number  of  content  and  analytics
subscribers and distributors.

Subscription agreements are generally one  to  three  years  in  term,  payable  in
advance, and provide for automatic renewal. Subscription-based revenues are
recognized over time on a ratable basis over the contract period beginning on
the date that our service is made available to the customer since the customer
receives and consumes the benefit as Nasdaq provides the service.

Our corporate solutions business includes our Investor Relations Intelligence,
ESG Services and Governance Solutions businesses, which serve both public
and private companies and organizations.

Corporate  solutions  revenues  primarily  include  subscription  and  transaction-
based  income  from  our  investor  relations  intelligence  and  governance
solutions  products  and  services.  Subscription-based  revenues  earned  are
recognized over time on a ratable basis over the contract period beginning on
the date that our service is made available to the customer since the customer
receives and consumes the benefit as Nasdaq provides the service. Generally,
fees are billed in advance and the contract provides for automatic renewal. As
part  of  subscription  agreements,  customers  can  also  be  charged  usage  fees
based upon actual usage of the services provided. Revenues from usage fees
are recognized at a point in time when the service is provided.

Financial Technology

Financial Crime Management Technology

Our  financial  crime  management  technology  solution  primarily  consists  of
SaaS revenues. We enter into subscription agreements which allow customers
access  to  our  cloud  platform.  Subscription  agreements  are  generally  three
years in  term,  payable  in  advance,  with  the  option  of  automatic  renewal  for
some  products.  Subscription-based  revenues  are  recognized  over  time  on  a
ratable basis over the contract period beginning on the date that our service is
made available to the customer since the customer receives and consumes the
benefit as Nasdaq provides the service.

Regulatory Technology

Our  surveillance  solutions  primarily  consist  of  SaaS  revenues  and  we  enter
into  subscription  agreements  which  allow  customers  access  to  our  cloud
platform or a connection to our servers to access the software.  We  recognize
revenue  from  these  agreements  similarly  to  our  revenue  recognition  for  the
Financial Crime Management Technology agreements discussed above.

AxiomSL  provides  financial  institutions  with  risk  &  financial  regulatory
reporting  and  risk  management  solutions.  The  products  can  be  offered  as  an
on-premise or as a cloud service agreement.

A license for on-premise software provides customers with the right to use the
software at its current state at the time made available to the customer. These
contracts generally consist of the following distinct performance obligations:
license, professional services and maintenance.

In  allocating  the  contractual  price  to  each  performance  obligation,  we  have
used  our  best  estimate  of  the  stand-alone  selling  price.  Consideration  is  first
allocated  to  performance  obligations  with  established  stand-alone  selling
prices  based  on  observable  evidence  such  as  professional  services  with  the
residual being split between license and maintenance.

F-15

License revenue is recognized upfront at the point in time when the software
is made available to the customer as this is the point the user of the software
can direct the use of and obtain substantially all of the remaining benefits from
the software license. Maintenance revenue is recognized over time on a ratable
basis over the contract period beginning on the date that our service is made
available  to  the  customer  since  the  customer  receives  and  consumes  the
benefit as Nasdaq provides the service.

Professional  services  are  typically  billed  on  a  time  and  expense  basis  and
revenue is recognized based on actual hours incurred. Nasdaq also offers fixed
price contract agreements and revenue is recognized using the input method to
measure  progress  towards  complete  satisfaction  of  the  services,  because  the
customer simultaneously receives and consumes the benefits provided by the
Company.

AxiomSL  can  also  be  offered  as  a  cloud  service  whereby  the  software  is
hosted  and  managed  for  customers.  These  hosted  agreements  generally
include  a  license,  hosting  services  and  maintenance  services.  We  have
determined  that  these  services  are  not  distinct  in  the  context  of  the  hosting
arrangement  as  the  customer  cannot  benefit  from  the  license  or  maintenance
without  the  hosting  services.  Cloud  revenues  are  recognized  over  time  on  a
ratable basis over the contract period beginning on the date that our service is
made available to the customer since the customer receives and consumes the
benefit as Nasdaq provides the service.

Capital Markets Technology

Calypso’s  capital  market  product  consists  of  the  provision  of  cloud-enabled,
cross-asset, front-to-back solutions for financial markets. Our Calypso product
offering includes on-premise and cloud service agreements and we recognize
revenue  from  these  agreements  similarly  to  our  revenue  recognition  for  the
AxiomSL agreements discussed above.

Through our trade management services, we provide market participants with
a wide variety of alternatives for connecting to and accessing our markets for
a  fee.  We  also  offer  market  participants  colocation  services,  whereby  we
charge firms for cabinet space and power to house their own equipment and
servers  within  our  data  centers.  These  participants  are  charged  monthly  fees
for cabinet space, connectivity and support in accordance with our published
fee  schedules.  These  fees  are  recognized  on  a  monthly  basis  when  the
performance  obligation  is  met.  We  also  earn  revenues  from  annual  and
monthly  exchange  membership  and  registration  fees.  Revenues  for  monthly
exchange membership and registration fees are recognized on a monthly basis
as  the  service  is  provided.  Revenues  from  annual  fees  for  exchange
membership  and  registration  fees  are  recognized  ratably  over  the  following
twelve-month period since the customer receives and consumes the benefit as
Nasdaq provides the service.

Market technology revenues primarily consist of software, license and support
revenues, SaaS revenues, and change request revenues.

We  enter  into  long-term  contracts  with  customers  to  develop  customized
technology  solutions,  license  the  right  to  use  software,  and  provide  support
and other services to our customers. We also enter into agreements to modify
the system solutions sold by Nasdaq after delivery has occurred. In addition,
we  enter  into  subscription  agreements  which  allow  customers  to  connect  to
our servers to access our software.

Our  long-term  contracts  with  customers  to  develop  customized  technology
solutions,  license  the  right  to  use  software  and  provide  support  and  other
services  to  our  customers  have  multiple  performance  obligations.  The
performance  obligations  are  generally:  (i)  software  license  and  installation
service  and  (ii)  software  support.  We  have  determined  that  the  software
license  and  installation  service  are  not  distinct  as  the  license  and  the
customized  installation  service  are  inputs  to  produce  the  combined  output,  a
functional and integrated software system.

For contracts with multiple performance obligations, we allocate the contract
transaction price to each performance obligation using our best estimate of the
standalone  selling  price  of  each  distinct  good  or  service  in  the  contract.  In
instances  where  standalone  selling  price  is  not  directly  observable,  such  as
when  we  do  not  sell  the  product  or  service  separately,  we  determine  the
standalone selling price predominantly through an expected cost plus a margin
approach.  For  the  years  ended  December  31,  2023,  2022  and  2021  we
recognized revenues of $75 million, $75 million and $77 million, respectively,
related to the market technology contracts described above.

Contract  modifications  are  routine  in  the  performance  of  our  contracts.
Contracts are often modified to account for changes in contract specifications
or  requirements.  In  most  instances,  contract  modifications  are  for  goods  and
services  that  are  not  distinct,  and,  therefore,  are  accounted  for  as  part  of  the
existing contract.

For  our  long-term  contracts,  payments  are  generally  made  throughout  the
contract  life  and  can  be  dependent  on  either  reaching  certain  milestones  or
paid  upfront  in  advance  of  the  service  period  depending  on  the  stage  of  the
contract.  For  subscription  agreements,  contract  payment  terms  can  be
quarterly,  annually  or  monthly,  in  advance.  For  all  other  contracts,  payment
terms vary.

We  generally  recognize  revenue  over  time  as  our  customers  simultaneously
receive  and  consume  the  benefits  provided  by  our  performance  because  our
customer controls the asset for which we are creating, our performance does
not  create  an  asset  with  alternative  use,  and  we  have  a  right  to  payment  for
performance completed to date. For these services, we recognize revenue over
time using costs incurred to date relative to total estimated costs at completion
to  measure  progress  toward  satisfying  our  performance  obligation.  Incurred
costs represent work performed, which corresponds with, and thereby depicts,
the transfer of control to the customer. Contract costs generally include labor
and direct overhead. For software support and update services, and for

F-16

subscription  agreements  which  allow  customers  to  connect  to  our  servers  to
access our software, we generally recognize revenue ratably over the service
period  beginning  on  the  date  our  service  is  made  available  to  the  customer
since  the  customer  receives  and  consumes  the  benefit  consistently  over  the
period as Nasdaq provides the services.

Accounting for our long-term contracts requires judgment relative to assessing
risks and their impact on the estimate of revenues and costs. Our estimates are
impacted  by  factors  such  as  the  potential  for  schedule  and  technical  issues,
productivity,  and  the  complexity  of  work  performed.  When  adjustments  in
estimated  total  contract  costs  are  required,  any  changes  in  the  estimated
revenues  from  prior  estimates  are  recognized  in  the  current  period  for  the
effect of such change. If estimates of total costs to be incurred on a contract
exceed estimates of total revenues, a provision for the entire estimated loss on
the contract is recorded in the period in which the loss is determined.

Market Technology SaaS revenues are recognized over time on a ratable basis
over  the  contract  period  beginning  on  the  date  that  our  service  is  made
available  to  the  customer  due  to  the  fact  that  the  customer  receives  and
consumes the benefit as Nasdaq provides the service.

Market Services

Transaction-Based Trading and Clearing

Transaction-based trading and clearing includes equity derivative trading and
clearing, cash equity trading and FICC revenues. Nasdaq charges transaction
fees for trades executed on our exchanges, as well as on orders that are routed
to  and  executed  on  other  market  venues.  Nasdaq  charges  clearing  fees  for
contracts cleared with Nasdaq Clearing.

In the U.S., transaction fees are based on trading volumes for trades executed
on  our  U.S.  exchanges  and  in  Europe,  transaction  fees  are  based  on  the
volume and value of traded and cleared contracts. In Canada, transaction fees
are based on trading volumes for trades executed on our Canadian exchange.

Nasdaq  satisfies  its  performance  obligation  for  trading  services  upon  the
execution of a customer trade and clearing services when a contract is cleared,
as trading and clearing transactions are substantially complete when they are
executed  and  we  have  no  further  obligation  to  the  customer  at  that  time.
Transaction-based trading and clearing fees can be variable and are based on
trade  volume  tiered  discounts.  Transaction  revenues,  as  well  as  any  tiered
volume  discounts,  are  calculated  and  billed  monthly  in  accordance  with  our
published  fee  schedules.  In  the  U.S.,  we  also  pay  liquidity  payments  to
customers  based  on  our  published  fee  schedules.  We  use  these  payments  to
improve the liquidity on our markets and therefore recognize those payments
as a cost of revenue.

For  U.S.  equity  derivative  trading,  we  credit  a  portion  of  the  per  share
execution charge to the market participant that provides the liquidity. For U.S.
and Canadian cash equity

trading,  including  for  The  Nasdaq  Stock  Market,  Nasdaq  PSX  and  Nasdaq
CXC,  we  credit  a  portion  of  the  per  share  execution  charge  to  the  market
participant  that  provides  the  liquidity,  and  for  Nasdaq  BX  and  Nasdaq  CX2,
we credit a portion of the per share execution charge to the market participant
that takes the liquidity. We record these credits as transaction rebates that are
included  in  transaction-based  expenses  in  the  Consolidated  Statements  of
Income.  These  transaction  rebates  are  paid  on  a  monthly  basis  and  the
amounts  due  are  included  in  accounts  payable  and  accrued  expenses  in  the
Consolidated Balance Sheets.

In the U.S., we pay Section 31 fees to the SEC for supervision and regulation
of securities markets. We pass these costs along to our customers through our
equity  derivative  trading  and  clearing  fees  and  our  cash  equity  trading  fees.
We  collect  the  fees  as  a  pass-through  charge  from  organizations  executing
eligible trades on our options exchanges and our cash equity platforms and we
recognize these amounts in transaction-based expenses when incurred. Section
31 fees received are included in cash and cash equivalents in the Consolidated
Balance Sheets at the time of receipt and, as required by law, the amount due
to the SEC is remitted semiannually and recorded as Section 31 fees payable
to  the  SEC  in  the  Consolidated  Balance  Sheets  until  paid.  Since  the  amount
recorded  as  revenues  is  equal  to  the  amount  recorded  as  transaction-based
expenses, there is no impact on our revenues less transaction-based expenses.
As  we  hold  the  cash  received  until  payment  to  the  SEC,  we  earn  interest
income on the related cash balances.

Under  our  Limitation  of  Liability  Rule  and  procedures,  we  may,  subject  to
certain  caps,  provide  compensation  for  losses  directly  resulting  from  our
systems’ actual failure to correctly process an order, quote, message or other
data  into  our  platform.  We  do  not  record  a  liability  for  any  potential  claims
that may be submitted under the Limitation of Liability Rule unless they meet
the provisions required in accordance with U.S. GAAP. As such, losses arising
as  a  result  of  the  rule  are  accrued  and  charged  to  expense  only  if  the  loss  is
probable and estimable.

U.S. Tape Plans

For  U.S.  Tape  plans,  revenues  are  collected  monthly  based  on  published  fee
schedules and distributed quarterly to the U.S. exchanges based on a formula
required by Regulation NMS that takes into account both trading and quoting
activity.  These  revenues  are  presented  on  a  net  basis  as  all  indicators  of
principal  versus  agent  reporting  under  U.S.  GAAP  have  been  considered  in
analyzing the appropriate presentation of the revenue sharing. The following
are primary indicators of net reporting:

• We are the administrator for the UTP plan, in addition to being a participant
in the plan. In our unique role as administrator, we facilitate the collection
and  dissemination  of  revenues  on  behalf  of  the  plan  participants.  As  a
participant,  we  share  in  the  net  distribution  of  revenues  according  to  the
plan on the same terms as all other plan participants.

F-17

• The operating committee of the plan, which comprises representatives from
each  of  the  participants,  including  us  solely  in  our  capacity  as  a  plan
participant,  is  responsible  for  setting  the  level  of  fees  to  be  paid  by
distributors  and  subscribers  and  taking  action  in  accordance  with  the
provisions of the plan, subject to SEC approval.

• Risk  of  loss  on  the  revenue  is  shared  equally  among  plan  participants

according to the plan.

Other Revenues

Other revenues related to our European power trading and clearing business,
following  our  announcement  in  June  2023  to  sell  this  business,  subject  to
regulatory  approval.  Prior  to  June  2023,  these  amounts  were  included  in  our
Market Services and Capital Access Platforms segments. Other revenues also
include revenues related to our Nordic broker services business for which we
completed  the  wind-down  in  June  2022,  as  well  as  revenues  associated  with
our  U.S.  Fixed  Income  business,  which  was  sold  in  June  2021.  Prior  to  the
closing  of  the  transaction,  these  revenues  were  included  in  our  Market
Services  and  Capital  Access  Platforms  segments.  Additionally,  for  the  year
ended  December  31,  2021,  other  revenues  include  revenues  associated  with
the  NPM  business  which  we  contributed  in  July  2021  to  a  standalone,
independent company, of which we own the largest minority interest, together
with a consortium of third-party financial institutions. Prior to July 2021, these
revenues  were  included  in  our  Capital  Access  Platforms  segment.  For  the
years ended December 31, 2023, 2022 and 2021, other revenues also include a
transitional services agreement associated with a divested business.

Earnings Per Share

We present both basic and diluted earnings per share. Basic earnings per share
is  computed  by  dividing  net  income  attributable  to  Nasdaq  by  the  weighted-
average  number  of  common  shares  outstanding  for  the  period.  Diluted
earnings per share is computed by dividing net income attributable to Nasdaq
by  the  weighted-average  number  of  common  shares  and  common  share
equivalents outstanding during the period and reflects the assumed conversion
of all dilutive securities, which primarily consist of restricted stock, PSUs, and
employee  stock  options.  Common  share  equivalents  are  excluded  from  the
computation  in  periods  for  which  they  have  an  anti-dilutive  effect.  Stock
options for which the exercise price exceeds the average market price over the
period  are  anti-dilutive  and,  accordingly,  are  excluded  from  the  calculation.
Shares  which  are  considered  contingently  issuable  are  included  in  the
computation of dilutive earnings per share on a weighted average basis when
management determines the applicable performance criteria would have been
met  if  the  performance  period  ended  as  of  the  date  of  the  relevant
computation. See Note 13, “Earnings Per Share,” for further discussion.

Pension and Post-Retirement Benefits

Pension  and  other  post-retirement  benefit  plan  information  for  financial
reporting  purposes  is  developed  using  actuarial  valuations.  We  assess  our
pension and other post-retirement benefit plan assumptions on a regular basis.
In  evaluating  these  assumptions,  we  consider  many  factors,  including
evaluation  of  the  discount  rate,  expected  rate  of  return  on  plan  assets,
mortality  rate,  healthcare  cost  trend  rate,  retirement  age  assumption,  our
historical  assumptions  compared  with  actual  results  and  analysis  of  current
market conditions and asset allocations. See Note 10, “Retirement Plans,” for
further discussion.

Discount  rates  used  for  pension  and  other  post-retirement  benefit  plan
calculations  are  evaluated  annually  and  modified  to  reflect  the  prevailing
market  rates  at  the  measurement  date  of  a  high-quality  fixed-income  debt
instrument  portfolio  that  would  provide  the  future  cash  flows  needed  to  pay
the  benefits  included  in  the  benefit  obligations  as  they  come  due.  Actuarial
assumptions are based upon management’s best estimates and judgment.

The  expected  rate  of  return  on  plan  assets  for  our  U.S.  pension  plans
represents our long-term assessment of return expectations which may change
based on significant shifts in economic and financial market conditions. The
long-term  rate  of  return  on  plan  assets  is  derived  from  return  assumptions
based on targeted allocations for various asset classes. While we consider the
pension  plans’  recent  performance  and  other  economic  growth  and  inflation
factors,  which  are  supported  by  long-term  historical  data,  the  return
expectations for the targeted asset categories represent a long-term prospective
return.

Share-Based Compensation

Nasdaq  uses  the  fair  value  method  of  accounting  for  share-based  awards.
Share-based  awards,  or  equity  awards,  include  restricted  stock,  PSUs,  and
stock options. The fair value of restricted stock awards and PSUs, other than
PSUs  granted  with  market  conditions,  is  determined  based  on  the  grant  date
closing stock price less the present value of future cash dividends. We estimate
the  fair  value  of  PSUs  granted  with  market  conditions  using  a  Monte  Carlo
simulation  model  at  the  date  of  grant.  The  fair  value  of  stock  options  are
estimated using the Black-Scholes option-pricing model.

We generally recognize compensation expense for equity awards on a straight-
line basis over the requisite service period of the award, taking into account an
estimated  forfeiture  rate.  Granted  but  unvested  shares  are  generally  forfeited
upon termination of employment.

Excess tax benefits or expense related to employee share-based payments, if
any,  are  recognized  as  income  tax  benefit  or  expense  in  the  Consolidated
Statements of Income when the awards vest or are settled.

F-18

Nasdaq also has an ESPP that allows eligible employees to purchase a limited
number of shares of our common stock at six-month intervals, called offering
periods, at 85.0% of the lower of the fair market value on the first or the last
day  of  each  offering  period.  The  15.0%  discount  given  to  our  employees  is
included in compensation and benefits expense in the Consolidated Statements
of Income.

See  Note  11,  “Share-Based  Compensation,”  for  further  discussion  of  our
share-based compensation plans.

Merger and Strategic Initiatives

We  incur  incremental  direct  merger  and  strategic  initiative  costs  relating  to
various completed and potential acquisitions, divestitures, and other strategic
opportunities. These costs generally include integration costs, as well as legal,
due diligence and other third-party transaction costs.

Fair Value Measurements

Fair value is defined as the price that would be received from selling an asset
or  paid  to  transfer  a  liability,  or  the  exit  price,  in  an  orderly  transaction
between market participants at the measurement date. When determining the
fair  value  measurements  for  assets  and  liabilities  required  or  permitted  to  be
either  recorded  or  disclosed  at  fair  value,  we  consider  the  principal  or  most
advantageous  market  in  which  we  would  transact,  and  we  also  consider
assumptions  that  market  participants  would  use  when  pricing  the  asset  or
liability.  Fair  value  measurement  establishes  a  hierarchy  of  valuation
techniques  based  on  whether  the  inputs  to  those  valuation  techniques  are
observable  or  unobservable.  Observable  inputs  reflect  market  data  obtained
from independent sources, while unobservable inputs reflect Nasdaq’s market
assumptions.  These  two  types  of  inputs  create  the  following  fair  value
hierarchy:

• Level 1 - Quoted prices for identical instruments in active markets.

• Level  2  -  Quoted  prices  for  similar  instruments  in  active  markets;  quoted
prices for identical or similar instruments in markets that are not active; and
model-derived valuations whose inputs are observable or whose significant
value drivers are observable.

• Level 3 - Instruments whose significant value drivers are unobservable.

This hierarchy requires the use of observable market data when available.

See Note 14, “Fair Value of Financial Instruments,” for further discussion.

Tax Matters

We  use  the  asset  and  liability  method  to  determine  income  taxes  on  all
transactions  recorded  in  the  consolidated  financial  statements.  Deferred  tax
assets  (net  of  valuation  allowances)  and  deferred  tax  liabilities  are  presented
net by jurisdiction as either a non-current asset or liability in our Consolidated
Balance  Sheets,  as  appropriate.  Deferred  tax  assets  and  liabilities  are
determined  based  on  differences  between  the  financial  statement  carrying
amounts  and  the  tax  basis  of  existing  assets  and  liabilities  (i.e.,  temporary
differences) and are measured at the enacted rates that will be in effect when
these  differences  are  realized.  If  necessary,  a  valuation  allowance  is
established to reduce deferred tax assets to the amount that is more likely than
not to be realized.

In order to recognize and measure our unrecognized tax benefits, management
determines whether a tax position is more likely than not to be sustained upon
examination,  including  resolution  of  any  related  appeals  or  litigation
processes, based on the technical merits of the position. Once it is determined
that  a  position  meets  the  recognition  thresholds,  the  position  is  measured  to
determine the amount of benefit to be recognized in the consolidated financial
statements.  Interest  and/or  penalties  related  to  income  tax  matters  are
recognized in income tax expense.

Subsequent Events

We have evaluated subsequent events through the issuance date of this Annual
Report on Form 10-K.

Recent Accounting Developments

In  November  2023,  the  FASB  issued  ASU  2023-07,  “Segment  Reporting
(Topic 280): Improvements to Reportable Segment Disclosures.” ASU 2023-
07  requires  disclosure  of  significant  segment  expenses  that  are  regularly
provided  to  the  chief  operating  decision  maker  ("CODM")  and  included
within the segment measure of profit or loss, an amount and description of its
composition for other segment items to reconcile to segment profit or loss, and
the  title  and  position  of  the  entity’s  CODM  and  an  explanation  of  how  the
CODM  uses  the  reported  measure  of  segment  profit  or  loss  in  assessing
segment  performance  and  deciding  how  to  allocate  resources.  ASU  2023-07
will be applied retrospectively and is effective for annual reporting periods in
fiscal years beginning after December 15, 2023, and interim reporting periods
in fiscal years beginning after December 31, 2024. We are currently reviewing
the impact that the adoption of ASU 2023-07 may have on our Consolidated
Financial Statements and disclosures.

F-19

3. REVENUE FROM CONTRACTS WITH CUSTOMERS

Disaggregation of Revenue

The  following  tables  summarize  the  disaggregation  of  revenue  by  major
product and service and by segment for the years ended December 31, 2023
and 2022:

Capital Access Platforms
Data & Listing Services
Index
Workflow & Insights
Financial Technology
Financial Crime Management
Technology
Regulatory Technology
Capital Markets Technology
Market Services, net
Other revenues
Revenues less transaction-based
expenses

Year Ended December 31,

2023

2022

(in millions)

2021

$

749  $
528 
493 

727  $
486 
469 

678 
459 
429 

223 
212 
664 
987 
39 

176 
130 
558 
988 
48 

104 
127 
541 
1,005 
77 

$

3,895  $

3,582  $

3,420 

Substantially  all  revenues  from  the  Capital  Access  Platforms  segment  are
recognized over time for the years ended December 31, 2023, 2022 and 2021.
For  2023,  6.7%  of  the  Financial  Technology  segment  revenues  were
recognized  at  a  point  in  time.  This  relates  to  AxiomSL  and  Calypso  license
revenues  for  the  two  months  since  acquisition.  The  remaining  Financial
Technology  revenues  were  recognized  over  time.  For  the  years  ended
December 31, 2023, 2022 and 2021 approximately 93.0%, 93.2%, and 93.6%
respectively, of Market Services revenues were recognized at a point in time
and 7.0%, 6.8% and 6.4%, respectively, were recognized over time.

Contract Balances

Substantially all of our revenues are considered to be revenues from contracts
with customers. The related accounts receivable balances are recorded in our
Consolidated  Balance  Sheets  as  receivables,  which  are  net  of  allowance  for
doubtful accounts of $18 million as of December 31, 2023 and $15 million as
of  December  31,  2022.  There  were  no  material  upward  or  downward
adjustments to the allowance during the year ended December  31,  2023.  We
do not have obligations for warranties, returns or refunds to customers.

For  the  majority  of  our  contracts  with  customers,  except  for  our  market
technology  and  listing  services  contracts,  our  performance  obligations  range
from  three  months  to  three  years  and  there  is  no  significant  variable
consideration.

Deferred  revenue  is  the  only  significant  contract  asset  or  liability  as  of
December  31,  2023. Deferred  revenue  represents  consideration  received  that
is  yet  to  be  recognized  as  revenue  for  unsatisfied  performance  obligations.
Deferred revenue primarily represents our contract liabilities related to

our fees for Annual and Initial Listings, Workflow & Insights, Financial Crime
Management  Technology,  Regulatory  Technology  and  Capital  Markets
Technology contracts. See Note 8, “Deferred Revenue,” for our discussion on
deferred revenue balances, activity, and expected timing of recognition.

We do not provide disclosures about transaction price allocated to unsatisfied
performance  obligations  if  contract  durations  are  less  than  one  year.  For  our
initial  listings,  the  transaction  price  allocated  to  remaining  performance
obligations  is  included  in  deferred  revenue.  For  our  Financial  Crime
Management  Technology,  Regulatory  Technology,  Capital  Markets
Technology  and  Workflow  &  Insights  contracts,  the  portion  of  transaction
price allocated to unsatisfied performance obligations is presented in the table
below. To the extent consideration has been received, unsatisfied performance
obligations would be included in the table below as well as deferred revenue.

The following table summarizes the amount of the transaction price allocated
to performance obligations that are unsatisfied, for contract durations greater
than one year, as of December 31, 2023:

Financial Crime
Management
Technology

Regulatory
Technology

Capital Markets
Technology

Workflow &
Insights

Total

2024
2025
2026
2027
2028
2029+

Total

$

$

224  $
206 
137 
53 
16 
2 
638  $

(in millions)

261  $
174 
78 
44 
26 
5 
588  $

311  $
243 
193 
131 
71 
129 
1,078  $

159  $
101 
47 
24 
14 
— 
345  $

955 
724 
455 
252 
127 
136 
2,649 

4. ACQUISITIONS

2023 Acquisition

In  June  2023,  we  entered  into  a  definitive  agreement  to  acquire  Adenza
Holdings, Inc., or Adenza, a provider of mission-critical risk management and
regulatory software to the financial services industry, for $5.75 billion in cash
(subject  to  customary  post-closing  adjustments)  and  a  fixed  amount  of
85.6 million shares of Nasdaq common stock, based on the volume-weighted
average  price  per  share  over  15  consecutive  trading  days  prior  to  signing.
Nasdaq issued $5.6 billion of debt and entered into a $600 million term loan
and used the proceeds for the cash portion of the consideration. See “Senior
Unsecured  Notes”  and  “2023  Term  Loan”  in  “Financing  of  the  Adenza
Acquisition” of Note 9, “Debt Obligations,” for further discussion.

On November 1, 2023, Nasdaq completed the acquisition of Adenza for a total
of purchase consideration of $9,984 million, which comprises the following:

F-20

(in millions, except
price per share)

Intangible Assets

Shares of Nasdaq common stock issued
Closing price per share of Nasdaq common stock on
November 1, 2023
Fair value of equity portion of the purchase consideration
Cash consideration

Total purchase consideration

$
$
$
$

85.6 

48.71 
4,170 
5,814 
9,984 

At the closing of the transaction, the 85.6 million shares of Nasdaq common
stock  were  issued  to  Thoma  Bravo,  the  sole  shareholder  of  Adenza,  and
represented  approximately  15%  of  the  outstanding  shares  of  Nasdaq.  For
further  discussion  on  the  rights  of  common  stockholders  refer  to  “Common
Stock”  of  Note  12,  “Nasdaq  Stockholders’  Equity.”  Adenza  is  part  of  our
Financial Technology segment.

The  amounts  in  the  table  below  represent  the  preliminary  allocation  of  the
purchase  price  to  the  acquired  intangible  assets,  the  deferred  tax  liability  on
the acquired intangible assets and other assets acquired and liabilities assumed
based  on  their  preliminary  respective  estimated  fair  values  on  the  date  of
acquisition.  The  excess  purchase  price  over  the  net  tangible  and  acquired
intangible  assets  has  been  recorded  as  goodwill.  The  goodwill  recognized  is
attributable  primarily  to  expected  synergies  and  is  assigned  to  our  Financial
Technology segment.

Goodwill
Acquired intangible assets
Receivables, net
Other net assets acquired
Cash and cash equivalents
Accrued personnel costs
Deferred revenue
Deferred tax liability on acquired intangible assets

Total purchase consideration

(in millions)

5,933 
5,050 
236 
153 
48 
(44)
(130)
(1,262)
9,984 

$

$

The primary areas of the preliminary purchase price allocation that are not yet
finalized relate to the valuation of the identifiable intangible assets and income
taxes. The allocation of the purchase price will be finalized within one year of
the date of acquisition.

The  following  table  presents  the  details  of  acquired  intangible  assets  at  the
date of acquisition. Acquired intangible assets with finite lives are amortized
using the straight-line method.

Intangible asset value
(in millions)
Discount rate used
Estimated average
useful life

Customer
Relationships

Technology

Trade
Names

Total Acquired
Intangible
Assets

$

3,740 

$

9.5 %

$

950 
8.5 %

$

360 
8.5 %

5,050 

22 years

6 years

20 years

Customer Relationships

Customer relationships represent the contractual relationships with customers.

Methodology

Customer  relationships  were  valued  using  the  income  approach,  specifically
an  excess  earnings  method.  The  excess  earnings  method  examines  the
economic  returns  contributed  by  the  identified  tangible  and  intangible  assets
of  a  company,  and  then  isolates  the  excess  return  that  is  attributable  to  the
intangible asset being valued.

Discount Rate

The  discount  rate  used  reflects  the  amount  of  risk  associated  with  the
hypothetical  cash  flows  for  the  customer  relationships  relative  to  the  overall
business.  In  developing  a  discount  rate  for  the  customer  relationships,  we
estimated  a  weighted-average  cost  of  capital  for  the  overall  business  and  we
utilized  this  rate  as  an  input  when  discounting  the  cash  flows.  The  resulting
discounted cash flows were then tax-effected at the applicable statutory rate.

A discounted tax amortization benefit was added to the fair value of the assets
under the assumption that the customer relationships would be amortized for
tax purposes over a period of 15 years.

Technology

As  part  of  our  acquisition  of  Adenza,  we  acquired  developed  technology
relating to AxiomSL and Calypso.

Methodology

The developed technology was valued using the income approach, specifically
the relief-from-royalty method, or RFRM. The RFRM is used to estimate the
cost  savings  that  accrue  to  the  owner  of  an  intangible  asset  who  would
otherwise have to pay royalties or license fees on revenues earned through the
use of the asset. The royalty rate is applied to the projected revenue over the
expected remaining life of the intangible asset to estimate royalty savings. The
net  after-tax  royalty  savings  are  calculated  for  each  year  in  the  remaining
economic life of the technology and discounted to present value.

F-21

The  unaudited  supplemental  pro  forma  financial  information  for  the  periods
presented is as follows:

Year Ended December 31,

2023

2022

(in millions)

Pro forma revenues less transaction-based
expenses
Pro forma operating income
Pro forma net income attributable to Nasdaq

$

4,329  $
1,485 
822 

4,096 
1,476 
812 

2022 Acquisition

In June 2022, we acquired Metrio, a provider of ESG data collection, analytics
and  reporting  services  based  in  Montreal,  Canada.  Metrio  is  part  of  our
Workflow & Insights business in our Capital Access Platforms segment.

The consolidated financial statements for the years ended December 31, 2023
and 2022 include the financial results of the Metrio acquisition from the date
of the acquisition. Pro forma financial results have not been presented as this
acquisition was not material to our financial results.

Acquisition-related  costs  were  expensed  as  incurred  and  are  included  in
merger  and  strategic  initiatives  expense  in  the  Consolidated  Statements  of
Income.

Discount Rate

The  discount  rate  used  reflects  the  amount  of  risk  associated  with  the
hypothetical  cash  flows  for  the  developed  technology  relative  to  the  overall
business as discussed above in “Customer Relationships.”

Trade Name

As part of our acquisition of Adenza, we acquired the AxiomSL and Calypso
trade  names.  The  trade  names  are  recognized  in  the  industry  and  carry  a
reputation  for  quality.  As  such,  the  reputation  and  positive  recognition
embodied in the trade names is a valuable asset to Nasdaq.

Methodology

The  AxiomSL  and  Calypso  trade  names  were  valued  using  the  income
approach, specifically the RFRM as discussed above in “Technology.”

Discount Rate

The  discount  rate  used  reflects  the  amount  of  risk  associated  with  the
hypothetical cash flows for the trade name relative to the overall business as
discussed above in “Customer Relationships.”

Pro Forma Results and Acquisition-Related Costs

From the date of acquisition through December 31, 2023, Adenza revenues of
$149  million  were  included  in  Financial  Technology  revenues  in  the
Consolidated  Statement  of  Income  and  Adenza  operating  income  of  $55
million  was  included  in  our  operating  income  in  the  Consolidated  Statement
of Income.

Acquisition-related  costs  were  expensed  as  incurred  and  are  included  in
merger  and  strategic  initiatives  expense  in  the  Consolidated  Statements  of
Income.

Supplemental Pro Forma Information (Unaudited)

The unaudited supplemental pro forma financial information presented below
is  for  illustrative  purposes  only  and  is  not  necessarily  indicative  of  the
financial position or results of operations that would have been realized if the
acquisition  had  been  completed  on  the  date  indicated,  does  not  reflect
synergies  that  might  have  been  achieved,  nor  is  it  indicative  of  future
operating results or financial position.

The  following  supplemental  pro  forma  financial  information  presents  the
combined results of operations as if Adenza had been acquired as of January
1,  2022.  The  pro  forma  adjustments  are  based  upon  currently  available
information  and  certain  assumptions  we  believe  are  reasonable  under  the
circumstances.  These  adjustments  primarily  include  a  net  increase  in
amortization  expense  that  would  have  been  recognized  due  to  acquired
identifiable  intangible  assets,  a  net  increase  to  interest  expense  to  reflect  the
additional  borrowings  for  the  financing  of  the  Adenza  acquisition  net  of  the
interest expense relating to the repayment of Adenza’s historical debt, and the
related income tax effects of the adjustments noted above.

F-22

5. GOODWILL AND ACQUIRED INTANGIBLE ASSETS

Acquired Intangible Assets

Goodwill

The  following  table  presents  the  changes  in  goodwill  by  business  segment
during the year ended December 31, 2023:

(in millions)

Capital Access Platforms
Balance at December 31, 2022
Foreign currency translation adjustments

Balance at December 31, 2023
Financial Technology
Balance at December 31, 2022
Goodwill acquired
Foreign currency translation adjustments
Balance at December 31, 2023
Market Services
Balance at December 31, 2022
Foreign currency translation adjustments

Balance at December 31, 2023

Total
Balance at December 31, 2022
Goodwill acquired
Foreign currency translation adjustments

Balance at December 31, 2023

$

$

$

$

$

$

$

$

4,178 
36 
4,214 

1,933 
5,933 
7 
7,873 

1,988 
37 
2,025 

8,099 
5,933 
80 
14,112 

Goodwill  represents  the  excess  of  purchase  price  over  the  value  assigned  to
the net assets, including identifiable intangible assets, of a business acquired.
Goodwill is allocated to our reporting units based on the assignment of the fair
values  of  each  reporting  unit  of  the  acquired  company.  We  test  goodwill  for
impairment at the reporting unit level annually, or in interim periods if certain
events  occur  indicating  that  the  carrying  amount  may  be  impaired,  such  as
changes in the business climate, poor indicators of operating performance or
the sale or disposition of a significant portion of a reporting unit. There was no
impairment  of  goodwill  for  the  years  ended  December  31,  2023,  2022  and
2021;  however,  events  such  as  prolonged  economic  weakness  or  unexpected
significant  declines  in  operating  results  of  any  of  our  reporting  units  or
businesses may result in goodwill impairment charges in the future.

The  following  table  presents  details  of  our  total  acquired  intangible  assets,
both finite- and indefinite-lived:

Finite-Lived Intangible Assets
Gross Amount
Technology
Customer relationships
Trade names and other
Foreign currency translation adjustment
Total gross amount
Accumulated Amortization
Technology
Customer relationships
Trade names and other
Foreign currency translation adjustment
Total accumulated amortization
Net Amount
Technology
Customer relationships
Trade names and other
Foreign currency translation adjustment
Total finite-lived intangible assets

Indefinite-Lived Intangible Assets
Exchange and clearing registrations
Trade names
Licenses
Foreign currency translation adjustment
Total indefinite-lived intangible assets

Total intangible assets, net

December 31, 2023

December 31, 2022

(in millions)

$

$

$

$

$

$

$

$
$

1,254  $
5,743 
417 
(194)
7,220  $

(169) $
(912)
(21)
120 
(982) $

1,085  $
4,831 
396 
(74)
6,238  $

1,257  $
121 
52 
(225)
1,205  $
7,443  $

304 
2,005 
60 
(209)
2,160 

(97)
(778)
(17)
120 
(772)

207 
1,227 
43 
(89)
1,388 

1,257 
121 
52 
(237)
1,193 
2,581 

There was no impairment of indefinite-lived intangible assets for 2023, 2022
and  2021.  There  were  no  material  finite-lived  impairment  charges  in  2023,
2022 and 2021.

F-23

The  following  table  presents  our  amortization  expense  for  acquired  finite-
lived intangible assets:

2023

Year Ended
December 31,

2022

(in millions)

2021

Amortization expense

$

206  $

153  $

170 

The table below presents the estimated future amortization expense (excluding
the  impact  of  foreign  currency  translation  adjustments  of  $74  million  as  of
December 31, 2023) of acquired finite-lived intangible assets as of December
31, 2023:

2024
2025
2026
2027
2028
2029+

Total

(in millions)

501 
497 
494 
494 
460 
3,866 
6,312 

$

$

6. INVESTMENTS

The following table presents the details of our investments:

December 31, 2023

December 31, 2022

Financial investments
Equity method investments
Equity securities

$

Financial Investments

(in millions)
188  $
380 
87 

181 
390 
86 

Financial  investments  are  comprised  of  trading  securities,  primarily  highly
rated  European  government  debt  securities,  of  which  $168  million  as  of
December  31,  2023  and  $161  million  as  of  December  31,  2022  are  assets
primarily  utilized  to  meet  regulatory  capital  requirements,  mainly  for  our
clearing operations at Nasdaq Clearing.

Equity Method Investments

We  record  our  estimated  pro-rata  share  of  earnings  or  losses  each  reporting
period and record any dividends as a reduction in the investment balance. As
of  December  31,  2023  and  2022,  our  equity  method  investments  primarily
included our 40.0% equity interest in OCC.

The carrying amounts of our equity method investments are included in other
non-current  assets 
the  Consolidated  Balance  Sheets.  No  material
impairments were recorded for the years ended December 31, 2023, 2022 and
2021.

in 

Net  income  (loss)  recognized  from  our  equity  interest  in  the  earnings  and
losses of these equity method investments, primarily OCC and NPM, was $(7)
million, $31 million, and $52 million for the years ended December 31, 2023,
2022  and  2021,  respectively.  For  the  year  ended  December  31,  2023,  equity
interest in the earnings of OCC was offset by our equity interest in the loss of
NPM  and  another  equity  method  investment.  For  the  year  ended  December
31, 2022, lower equity interest in the earnings of OCC, as compared to 2021,
was primarily driven by a reduction in the clearing fee rate that OCC charges
its customers, partially offset by elevated U.S. industry trading volumes.

Equity Securities 

in 

the  Consolidated  Balance  Sheets.  We  elected 

The  carrying  amounts  of  our  equity  securities  are  included  in  other  non-
the
current  assets 
measurement alternative for substantially all of our equity securities as they do
not have a readily determinable fair value. No material adjustments were made
to the carrying value of our equity securities for the years ended December 31,
2023, 2022 and 2021. As of December 31, 2023 and December 31, 2022, our
equity  securities  primarily  represent  various  strategic  investments  made
through our corporate venture program.

7. PROPERTY AND EQUIPMENT, NET

The following table presents our major categories of property and equipment,
net:

Data processing equipment and software
Furniture, equipment and leasehold
improvements
Total property and equipment
Less: accumulated depreciation and
amortization and impairment charges

Total property and equipment, net

Year Ended December 31,

2023

2022

(in millions)
913  $

325 
1,238 

(662)
576  $

786 

305 
1,091 

(559)
532 

$

$

Depreciation and amortization expense for property and equipment was $117
million  for  the  year  ended  December  31,  2023,  $105  million  for  the  year
ended December 31, 2022, and $108 million for the year ended December 31,
2021. These amounts are included in depreciation and amortization expense in
the Consolidated Statements of Income.

F-24

 
 
 
 
We  recorded  pre-tax,  non-cash  property  and  equipment  asset  impairment
charges on capitalized software that was retired and accelerated depreciation
expense  on  certain  assets  as  a  result  of  a  decrease  in  their  useful  life  of
$12 million in 2023, $8 million in 2022 and $4 million in 2021. These charges
are  included  in  restructuring  charges  in  the  Consolidated  Statements  of
Income. See Note 20, “Restructuring Charges,” for further discussion. There
were  no  other  material  impairments  of  property  and  equipment  recorded  in
2023, 2022 and 2021.

As of December 31, 2023 and 2022, we did not own any real estate properties.

8. DEFERRED REVENUE

Deferred revenue represents consideration received that is yet to be recognized
as  revenue.  The  changes  in  our  deferred  revenue  during  the  year  ended
December 31, 2023 are reflected in the following table: 

Balance at

December 31, 2022 Additions Revenue Recognized
(in millions)

Adjustments

Balance at
December 31, 2023

Capital Access Platforms:

Initial Listings

$

Annual Listings
Workflow &
Insights

Financial Technology:
Financial Crime
Management
Technology

Regulatory

Technology
Capital Markets
Technology

Other

Total

$

In the above table:

116  $
2 

19  $
2 

(39) $
(1)

172 

177 

(169)

103 

5 

29 
21 
448  $

122 

81 

211 
9 
621  $

(102)

(19)

(59)
(9)
(398) $

1  $

— 

— 

— 

1 

2 
— 

4  $

97 
3 

180 

123 

68 

183 
21 
675 

• Additions  reflect  deferred  revenue  billed  in  the  current  period,  net  of
recognition.  Regulatory  Technology  and  Capital  Markets  Technology
additions  include  deferred  revenue  acquired  as  part  of  the  acquisition  of
Adenza.

• Revenue recognized includes revenue recognized during the current period

that was included in the beginning balance.

• Adjustments reflect foreign currency translation adjustments.

• Other  primarily  includes  deferred  revenue  from  our  non-U.S.  listing  of
additional shares fees and our Index business. These fees are included in our
Capital Access Platforms segment.

As  of  December  31,  2023,  we  estimate  that  our  deferred  revenue  will  be
recognized in the following years:
Fiscal year
ended:

2029+

Total

2028

2025

2026

2024

2027
(in millions)

Capital Access Platforms:

Initial Listings

$

Annual Listings
Workflow &
Insights

Financial Technology:
Financial Crime
Management
Technology

Regulatory

Technology
Capital Markets
Technology

Other

Total

$

37  $
3 

26  $
— 

20  $
— 

178 

2 

— 

120 

68 

176 
12 
594  $

2 

— 

3 
5 
38  $

1 

— 

2 
3 
26  $

10  $
— 

— 

— 

— 

2 
1 
13  $

3  $

1  $

— 

— 

— 

— 

— 
— 

— 

— 

— 

— 

— 
— 

3  $

1  $

97 
3 

180 

123 

68 

183 
21 
675 

Deferred  revenue  that  will  be  recognized  in  2025  and  beyond  is  included  in
other non-current liabilities in the Consolidated Balance Sheets. The timing of
recognition of deferred revenue related to certain market technology contracts
represents  our  best  estimates  as  the  recognition  is  primarily  dependent  upon
the  completion  of  customization  and  any  significant  modifications  made
pursuant to existing market technology contracts.

F-25

 
9. DEBT OBLIGATIONS

Senior Unsecured Notes

Our  2040  Notes  were  issued  at  par.  All  of  our  other  outstanding  senior
unsecured  notes  were  issued  at  a  discount.  As  a  result  of  the  discount,  the
proceeds  received  from  each  issuance  were  less  than  the  aggregate  principal
amount. As of December 31, 2023, the amounts in the table above reflect the
aggregate  principal  amount,  less  the  unamortized  debt  issuance  costs,  which
are  being  accreted  through  interest  expense  over  the  life  of  the  applicable
notes.  The  accretion  of  these  costs  was  $10  million  for  the  year  ended
December 31, 2023. Our Euro denominated notes are adjusted for the impact
of  foreign  currency  translation.  Our  senior  unsecured  notes  are  general
unsecured  obligations  which  rank  equally  with  all  of  our  existing  and  future
unsubordinated obligations and are not guaranteed by any of our subsidiaries.
The  senior  unsecured  notes  were  issued  under  indentures  that,  among  other
things, limit our ability to consolidate, merge or sell all or substantially all of
our  assets,  create  liens,  and  enter  into  sale  and  leaseback  transactions.  The
senior unsecured notes may be redeemed by Nasdaq at any time, subject to a
make-whole amount.

Upon  a  change  of  control  triggering  event  (as  defined  in  the  various
supplemental indentures governing the applicable notes), the terms require us
to repurchase all or part of each holder’s notes for cash equal to 101% of the
aggregate principal amount purchased plus accrued and unpaid interest, if any.

The  2029  Notes,  2030  Notes,  2032  Notes  and  2033  Notes  pay  interest
annually. All other notes pay interest semi-annually. The U.S senior unsecured
notes coupon rates may vary with Nasdaq’s debt rating, to the extent Nasdaq is
downgraded below investment grade, up to an upward rate adjustment not to
exceed 2%.

Net Investment Hedge

Our  Euro  denominated  notes  have  been  designated  as  a  hedge  of  our  net
investment in certain foreign subsidiaries to mitigate the foreign exchange risk
associated  with  certain  investments  in  these  subsidiaries.  Accordingly,  the
remeasurement of these notes is recorded in accumulated other comprehensive
loss within Nasdaq’s stockholders’ equity in the Consolidated Balance Sheets.
For the year ended December 31, 2023, the impact of translation decreased the
U.S. dollar value of our Euro denominated notes by $70 million.

The following table presents the carrying amounts of our debt outstanding, net
of unamortized debt issuance costs:

Short-term debt:

Commercial paper

Long-term debt - senior unsecured notes:

2025 Notes, $500 million, 5.650% notes due

June 28, 2025

2026 Notes, $500 million, 3.850% notes due

June 30, 2026

2028 Notes, $1 billion, 5.350% notes
  due June 28, 2028
2029 Notes, €600 million, 1.75% notes due

March 28, 2029

2030 Notes, €600 million, 0.875% notes due

February 13, 2030

2031 Notes, $650 million, 1.650% notes due

January 15, 2031

2032 Notes, €750 million, 4.500% notes due

February 15, 2032

2033 Notes, €615 million, 0.900% notes due

July 30, 2033

2034 Notes $1.25 billion, 5.550% notes due

February 15, 2034

2040 Notes, $650 million, 2.500% notes due

December 21, 2040

2050 Notes, $500 million, 3.250% notes due

April 28, 2050

2052 Notes, $550 million, 3.950% notes due

March 7, 2052

2053 Notes, $750 million, 5.950% notes due

August 15, 2053

2063 Notes, $750 million, 6.100% notes due

June 28, 2063

2023 Term Loan
2022 Revolving Credit Facility
Total long-term debt

Total debt obligations

Commercial Paper Program

December 31, 2023

December 31, 2022

(in millions)

$

291  $

664 

497 

499 

991 

658 

658 

645 

819 

674 

1,239 

644 

487 

541 

738 

738 

— 

498 

— 

637 

637 

644 

— 

653 

— 

644 

486 

541 

— 

— 

339 
(4)
10,163  $
10,454  $

$
$

— 
(5)
4,735 
5,399 

Our  U.S.  dollar  commercial  paper  program  is  supported  by  our  2022
Revolving Credit Facility, which provides liquidity support for the repayment
of commercial paper issued through this program. See “2022 Revolving Credit
Facility”  below  for  further  discussion.  The  effective  interest  rate  of
commercial paper issuances fluctuates as short-term interest rates and demand
fluctuate. The fluctuation of these rates may impact our interest expense. As of
December  31,  2023,  we  had  $291  million  outstanding  under  the  commercial
paper program.

F-26

Financing of the Adenza Acquisition

Senior Unsecured Notes

In  June  2023,  Nasdaq  issued  six  series  of  notes  for  total  proceeds  of  $5,016
million, net of debt issuance costs of $38 million, with various maturity dates
ranging  from  2025  to  2063.  During  the  second  half  of  2023,  we  incurred  an
additional  $6  million  in  debt  issuance  costs,  for  total  net  proceeds  from  the
issuance of the six series of notes of $5,010 million as of December 31, 2023.
The  net  proceeds  from  these  notes  were  used  to  finance  the  majority  of  the
cash consideration due in connection with the Adenza acquisition. For further
discussion  of  the  Adenza  acquisition,  see  “2023  Acquisition,”  of  Note  4,
“Acquisitions.”

2023 Term Loan

In June 2023, in connection with the financing of the Adenza acquisition, we
entered into a term loan credit agreement, or the 2023 Term Loan. The 2023
Term  Loan  provided  us  with  the  ability  to  borrow  up  to  $600  million  to
finance  a  portion  of  the  cash  consideration  for  the  Adenza  acquisition,  for
repayment of certain debt of Adenza and its subsidiaries, and to pay fees, costs
and  expenses  related  to  the  transaction.  Under  the  2023  Term  Loan,
borrowings  bear  interest  on  the  principal  amount  outstanding  at  a  variable
interest  rate  based  on  the  SOFR  plus  an  applicable  margin  that  varies  with
Nasdaq’s credit rating. On November 1, 2023, we borrowed $599 million, net
of fees, under this term loan towards payment of the cash consideration due in
connection with the Adenza acquisition. We made a partial repayment during
the  fourth  quarter  of  $260  million.  As  of  December  31,  2023,  we  had  $339
million outstanding under this term loan.

Credit Facilities

2022 Revolving Credit Facility

In December 2022, Nasdaq amended and restated its previously issued $1.25
billion  five-year  revolving  credit  facility,  with  a  new  maturity  date  of
December  16,  2027.  Nasdaq  intends  to  use  funds  available  under  the  2022
Revolving  Credit  Facility  for  general  corporate  purposes  and  to  provide
liquidity  support  for  the  repayment  of  commercial  paper  issued  through  the
commercial  paper  program.  Nasdaq  is  permitted  to  repay  borrowings  under
our  2022  Revolving  Credit  Facility  at  any  time  in  whole  or  in  part,  without
penalty.

As  of  December  31,  2023,  no  amounts  were  outstanding  on  the  2022
Revolving  Credit  Facility.  The  $(4)  million  balance  represents  unamortized
debt issuance costs which are being accreted through interest expense over the
life of the credit facility.

Borrowings under the revolving credit facility and swingline borrowings bear
interest on the principal amount outstanding at a variable interest rate based on
either the SOFR (or a successor rate to SOFR), the base rate (as defined in the
2022  Revolving  Credit  Facility  agreement),  or  other  applicable  rate  with
respect  to  non-dollar  borrowings,  plus  an  applicable  margin  that  varies  with
Nasdaq’s debt rating. We are charged commitment fees of 0.100% to 0.250%,
depending on our credit rating, whether or not amounts have been borrowed.
These commitment fees are included in interest expense and were not material
for the years ended December 31, 2023 and 2022.

The  2022  Revolving  Credit  Facility  contains  financial  and  operating
covenants. Financial covenants include a maximum leverage ratio. Operating
covenants include, among other things, limitations on Nasdaq’s ability to incur
additional  indebtedness,  grant  liens  on  assets,  dispose  of  assets  and  make
certain  restricted  payments.  The  facility  also  contains  customary  affirmative
covenants,  including  access  to  financial  statements,  notice  of  defaults  and
certain  other  material  events,  maintenance  of  properties  and  insurance,  and
customary  events  of  default,  including  cross-defaults  to  our  material
indebtedness.

The 2022 Revolving Credit Facility includes an option for Nasdaq to increase
the available aggregate amount by up to $750 million, subject to the consent
of the lenders funding the increase and certain other conditions.

Other Credit Facilities

Certain of our European subsidiaries have several other credit facilities, which
are available in multiple currencies, primarily to support our Nasdaq Clearing
operations  in  Europe,  as  well  as  to  provide  a  cash  pool  credit  line  for  one
subsidiary.  These  credit  facilities,  in  aggregate,  totaled  $191  million  as  of
December  31,  2023  and  $184  million  as  of  December  31,  2022  in  available
liquidity,  none  of  which  was  utilized.  Generally,  these  facilities  each  have  a
one-year  term.  The  amounts  borrowed  under  these  various  credit  facilities
bear  interest  on  the  principal  amount  outstanding  at  a  variable  interest  rate
based  on  a  base  rate  (as  defined  in  the  applicable  credit  agreement),  plus  an
applicable  margin.  We  are  charged  commitment  fees  (as  defined  in  the
applicable  credit  agreement),  whether  or  not  amounts  have  been  borrowed.
These commitment fees are included in interest expense and were not material
for the years ended December 31, 2023 and 2022.

These  facilities  include  customary  affirmative  and  negative  operating
covenants and events of default.

Debt Covenants

As of December 31, 2023, we were in compliance with the covenants of all of
our debt obligations.

F-27

10. RETIREMENT PLANS

Defined Contribution Savings Plan

We  sponsor  a  401(k)  plan  which  is  a  voluntary  defined  contribution  savings
plan,  for  U.S.  employees.  Employees  are  immediately  eligible  to  make
contributions  to  the  plan  and  are  also  eligible  for  an  employer  contribution
match  at  an  amount  equal  to  100.0%  of  the  first  6.0%  of  eligible  employee
contributions. Savings plan expense is included in compensation and benefits
expense in the Consolidated Statements of Income:

Year Ended December 31,

2023

2022

(in millions)

2021

Savings Plan expense

$

19  $

17  $

14 

Pension and Supplemental Executive Retirement Plans

We  maintain  non-contributory,  a  defined-benefit  pension  plan,  non-qualified
SERPs for certain senior executives and other post-retirement benefit plans for
eligible employees in the U.S. Our pension plan and SERPs are frozen. Future
service  and  salary  for  all  participants  do  not  count  toward  an  accrual  of
benefits under the pension plan and SERPs. Most employees outside the U.S.
are  covered  by  local  retirement  plans  or  by  applicable  social  laws.  Benefits
under social laws are generally expensed in the periods in which the costs are
incurred.  In  June  2023,  we  terminated  our  U.S.  pension  plan  and  are  taking
steps to wind down the plan and transfer the resulting liability to an insurance
company  which  started  in  2023  and  will  be  completed  in  2024.  These  steps
include  settling  all  future  obligations  under  our  U.S.  pension  plan  through  a
combination  of  lump  sum  payments  to  eligible,  electing  participants
(completed in 2023) and the transfer of any remaining benefits to a third-party
insurance company through a group annuity contract. In connection with the
plan  termination  and  partial  settlement,  a  loss  of  $9  million  was  recorded  to
compensation and benefits expense in the Consolidated Statement of Income.
We  expect  to  incur  an  additional  settlement  loss  upon  the  finalization  of  the
group  annuity  purchase  during  the  first  half  of  2024.  The  total  expense  for
these  plans  is  included  in  compensation  and  benefits  expense  in  the
Consolidated Statements of Income:

Year Ended December 31,

2023

2022

(in millions)

2021

Retirement Plans expense

$

34  $

24  $

26 

Nasdaq recognizes the funded status of our U.S. defined-benefit pension plan,
measured  as  the  difference  between  the  fair  value  of  the  plan  assets  and  the
benefit obligation, in the Consolidated Balance Sheets.

As of December 31, 2023, the fair value of our U.S. defined-benefit pension
plan’s assets was $57 million and the benefit obligation was $57 million. As a
result,  the  U.S.  defined-benefit  pension  plan  is  fully  funded  as  of  December
31, 2023.

As of December 31, 2022, the fair value of our U.S. defined-benefit pension
plan’s assets was $79 million and the benefit obligation was $81 million. As a
result, the U.S. defined-benefit pension plan was underfunded by $2 million as
of December 31, 2022.

During  2023  and  2022,  we  did  not  make  any  contributions  to  our  U.S.
defined-benefit pension plan. For our SERP and other post-retirement benefit
plans, the net underfunded liability was $27 million as of December 31, 2023
and  $28  million  as  of  December  31,  2022.  The  underfunded  liability  for  the
above  plans  is  included  in  accrued  personnel  costs  and  other  non-current
liabilities in the Consolidated Balance Sheets. The U.S. pension plan’s assets
are  invested  per  target  allocations  adopted  by  Nasdaq’s  Pension  and  401(k)
Committee  and  are  primarily  invested  in  liability  driven  portfolios  that  have
underlying investments in fixed income securities. More specifically, the plan
has  investments  in  long  duration  cash  bonds,  as  well  co-mingled  investment
options referred to as a separate account under a life insurance company group
annuity  contract.  The  life  insurance  company  owns  the  underlying  financial
instruments held within the separate accounts and plan sponsors gain access to
them  through  the  purchase  of  a  group  annuity  contract.  These  group  annuity
contracts are valued on a daily basis and offer daily liquidity, and use a unit
value system of recordkeeping to track a plan sponsor’s interest in the separate
account investment.

Accumulated Other Comprehensive Loss

As of December 31, 2023, accumulated other comprehensive
loss for the U.S. pension plan was $15 million reflecting an unrecognized net
loss of $17 million, partially offset by an income tax benefit of $2 million.

Estimated Future Benefit Payments

We  expect  to  make  future  benefit  payments  to  participants  in  SERPs  of
approximately $20 million over the next ten years.

Nonqualified Deferred Compensation Plan

In  June  2022,  we  established  the  Nasdaq,  Inc.  Nonqualified  Deferred
Compensation  Plan.  This  plan  provides  certain  eligible  employees  with  the
opportunity  to  defer  a  portion  of  their  annual  salary  and  bonus  up  to  certain
approval  limits.  All  deferrals  and  associated  earnings  are  our  general
unsecured obligations and were immaterial for the year ended December 31,
2023 and 2022.

11. SHARE-BASED COMPENSATION

We  have  a  share-based  compensation  program  for  employees  and  non-
employee  directors.  Share-based  awards  granted  under  this  program  include
restricted stock (consisting of restricted stock units), PSUs and stock options.
For accounting purposes, we consider PSUs to be a form of restricted stock.
Generally, annual employee awards are granted on or about April 1st of each
year.

F-28

Summary of Share-Based Compensation Expense

Summary of Restricted Stock Activity

The  following  table  presents  the  total  share-based  compensation  expense
resulting  from  equity  awards  and  the  15.0%  discount  for  the  ESPP  for  the
years  ended  December  31,  2023,  2022  and  2021,  which  is  included  in
compensation and benefits expense in the Consolidated Statements of Income:

The  following  table  summarizes  our  restricted  stock  activity  for  the  year
ended December 31, 2023, 2022, and 2021:

Restricted Stock

Number of Awards

Weighted-Average Grant
Date Fair Value

Year Ended December 31,

2023

2022

2021

(in millions)

Share-based compensation
expense before income taxes

$

122  $

106  $

90 

Common Shares Available Under Our Equity Plan

As  of  December  31,  2023,  we  had  approximately  24.6  million  shares  of
common stock authorized for future issuance under our Equity Plan.

Restricted Stock

We  grant  restricted  stock  to  most  employees.  The  grant  date  fair  value  of
restricted stock awards is based on the closing stock price at the date of grant
less  the  present  value  of  future  cash  dividends.  Restricted  stock  awards
granted to employees below the manager level generally vest 33% on the first
anniversary of the grant date, 33% on the second anniversary of the grant date,
and the remainder on the third anniversary of the grant date. Restricted stock
awards  granted  to  employees  at  or  above  the  manager  level  generally  vest
33% on the second anniversary of the grant date, 33% on the third anniversary
of  the  grant  date,  and  the  remainder  on  the  fourth  anniversary  of  the  grant
date.

Unvested at December 31, 2020
Granted
Vested
Forfeited
Unvested at December 31, 2021
Granted
Vested
Forfeited
Unvested at December 31, 2022
Granted
Vested
Forfeited

Unvested at December 31, 2023

4,917,153  $
1,523,235 
(1,624,809)
(416,559)
4,399,020  $
1,785,138 
(1,525,442)
(278,203)
4,380,513  $
1,850,790 
(1,703,252)
(318,752)
4,209,299  $

28.07 
50.52 
27.78 
34.04 
35.39 
57.65 
31.22 
42.07 
45.48 
52.66 
38.21 
51.15 
51.15 

As  of  December  31,  2023,  $119  million  of  total  unrecognized  compensation
cost related to restricted stock is expected to be recognized over a weighted-
average period of 1.7 years.

PSUs

PSUs  are  based  on  performance  measures  that  impact  the  amount  of  shares
that  each  recipient  will  receive  upon  vesting.  Prior  to  April  1,  2020,  we  had
two  performance-based  PSU  programs  for  certain  officers,  a  one-year
performance-based  program  and  a  three-year  cumulative  performance-based
program  that  focuses  on  TSR.  Effective  April  1,  2020,  to  better  align  the
equity programs for eligible officers, the one-year performance-based program
was  eliminated  and  all  eligible  officers  now  participate  in  the  three-year
cumulative  performance-based  program.  The  performance  periods  are
complete  for  all  PSUs  granted  under  the  one-year  performance-based
program,  and  all  shares  underlying  these  PSUs  have  vested  as  of  December
31, 2022.

F-29

 
 
 
 
One-Year PSU Program

The  grant  date  fair  value  of  PSUs  under  the  one-year  performance-based
program  was  based  on  the  closing  stock  price  at  the  date  of  grant  less  the
present  value  of  future  cash  dividends.  Under  this  program,  an  eligible
employee received a target grant of PSUs, but could have received from 0.0%
to  150.0%  of  the  target  amount  granted,  depending  on  the  achievement  of
performance  measures.  These  awards  vest  ratably  on  an  annual  basis  over  a
three-year  period  commencing  with  the  end  of  the  one-year  performance
period.  Compensation  cost  was  recognized  over  the  performance  period  and
the  three-year  vesting  period  based  on  the  probability  that  such  performance
measures will be achieved, taking into account an estimated forfeiture rate.

Three-Year PSU Program

Under  the  three-year  performance-based  program,  each  eligible  individual
receives  PSUs,  subject  to  the  satisfaction  of  applicable  market  performance
conditions,  with  a  three-year  cumulative  performance  period  that  vest  at  the
end  of  the  performance  period  and  which  settle  in  shares  of  our  common
stock.  Compensation  cost  is  recognized  over  the  three-year  performance
period, taking into account an estimated forfeiture rate, regardless of whether
the market condition is satisfied, provided that the requisite service period has
been completed. Performance will be determined by comparing Nasdaq’s TSR
to  two  peer  groups,  each  weighted  50.0%.  The  first  peer  group  consists  of
exchange companies, and the second peer group consists of all companies in
the S&P 500. For the PSU awards that will be granted in 2024, we will replace
the exchange company peer group with the S&P 500 GICS 4020 Index, which
is  a  blend  of  exchanges,  as  well  as  data,  financial  technology  and  banking
companies  to  align  more  closely  with  Nasdaq’s  diverse  business  and
competitors.  The  PSU  award  granted  to  our  Chief  Financial  Officer  in
December  2023,  in  connection  with  the  commencement  of  her  employment,
also  included  this  new  peer  group.  Nasdaq’s  relative  performance  ranking
against  each  of  these  groups  will  determine  the  final  number  of  shares
delivered to each individual under the program. The award issuance under this
program  will  be  between  0.0%  and  200.0%  of  the  number  of  PSUs  granted
and  will  be  determined  by  Nasdaq’s  overall  performance  against  both  peer
groups. However, if Nasdaq’s TSR is negative for the three-year performance
period, regardless of TSR ranking, the award issuance will not exceed 100.0%
of  the  number  of  PSUs  granted.  We  estimate  the  fair  value  of  PSUs  granted
under the three-year PSU program using the Monte Carlo simulation model, as
these awards contain a market condition.

Grants of PSUs that were issued in 2021 with a three-year performance period
exceeded  the  applicable  performance  parameters.  As  a  result,  an  additional
387,011  units  above  the  original  target  were  granted  in  the  first  quarter  of
2024 and were fully vested upon issuance.

The  following  weighted-average  assumptions  were  used  to  determine  the
weighted-average fair values of the outstanding PSU awards granted under the
three-year PSU program during the years ended December 31, 2023 and 2022:

Weighted-average risk-free
interest rate
Expected volatility
Weighted-average grant date
share price
Weighted-average fair value at
grant date

$

$

Year Ended December 31,

2023

2022

3.87 %
23.94 %

54.68 

55.36 

$

$

2.61 %
30.04 %

60.55 

63.68 

In  the  table  above,  the  risk-free  interest  rate  for  periods  within  the  expected
life of the award is based on the U.S. Treasury yield curve in effect at the time
of grant; and we use historic volatility for PSU awards issued under the three-
year PSU program, as implied volatility data could not be obtained for all the
companies  in  the  peer  groups  used  for  relative  performance  measurement
within the program.

In  addition,  the  annual  dividend  assumption  utilized  in  the  Monte  Carlo
simulation model is based on Nasdaq’s dividend yield at the date of grant.

Summary of PSU Activity

The  following  table  summarizes  our  PSU  activity  for  the  years  ended
December 31, 2023, 2022, and 2021:

PSUs

One-Year Program

Three-Year Program

Number of Awards  

Weighted-
Average Grant
Date Fair
Value

Number of Awards

Weighted-
Average Grant
Date Fair Value

Unvested at
December 31,
2020
Granted
Vested
Forfeited
Unvested at
December 31,
2021
Granted
Vested
Forfeited
Unvested at
December 31,
2022
Granted
Vested
Forfeited
Unvested at
December 31,
2023

F-30

508,644  $
— 
(299,292)
(60,150)

149,202  $
— 
(142,459)
(6,743)

—  $
— 
— 
— 

—  $

27.78 
— 
27.66 
27.76 

28.01 
— 
28.02 
27.85 

— 
— 
— 
— 

— 

2,429,967    $
1,081,707 
(1,178,181)
(41,121)

2,292,372    $
1,495,092 
(1,735,842)
(85,080)

1,966,542  $
1,693,065 
(1,552,311)
(98,974)

36.04 
58.66 
38.95 
47.43 

45.01 
45.66 
32.57 
52.27 

56.44 
47.14 
37.59 
57.51 

2,008,322  $

62.86 

 
In the table above, the granted amount also includes additional awards granted
based on overachievement of performance parameters.

As of December 31, 2023, the total unrecognized compensation cost related to
the  PSU  program  is  $52  million  and  is  expected  to  be  recognized  over  a
weighted-average period of 1.5 years.

Stock Options

In January 2022, in connection with a new five year employment agreement,
our  Chief  Executive  Officer  received  an  aggregate  of  613,872  performance-
based non-qualified stock options, which will vest as follows:

• 50%  will  vest  contingent  upon  the  achievement  of  certain  performance

conditions; and

• 50%  will  vest  five  years  after  the  grant  date,  subject  to  continued

employment through such date.

The fair value of stock options are estimated using the Black-Scholes option-
pricing  model.  These  options  expire  10  years  after  the  date  of  grant.  There
were no stock option awards granted for the years ended December 31, 2023
and 2021.

A summary of our outstanding and exercisable stock options at December 31,
2023, 2022 and 2021 is as follows:

Number of Stock
Options

Weighted-
Average
Exercise Price

Weighted-
Average
Remaining
Contractual
Term (in
years)

Aggregate
Intrinsic
Value (in
millions)

Outstanding at December

31, 2020

Exercised
Forfeited
Outstanding at December

31, 2021

Granted
Outstanding at December

31, 2022

Outstanding at December

31, 2023

Exercisable at December 31,

2023

880,059  $
(73,227)
(381)

806,451  $
613,872 

21.07 
8.43 
8.43 

22.23 
67.49 

1,420,323  $

41.79 

1,420,323  $

41.79 

806,451  $

22.23 

5.0 $

6.2 $

5.2 $

3.0 $

39 

32 

29 

29 

There  were  no  stock  options  exercised  in  2023  and  2022.  The  net  cash
proceeds  from  the  exercise  of  73,227  stock  options  for  the  year  ended
December 31, 2021 was $1 million. The total pre-tax intrinsic value of stock
options exercised was $3 million for the year ended December 31, 2021.

As  of  December  31,  2023,  the  aggregate  pre-tax  intrinsic  value  of  the
outstanding and exercisable stock options in the above table was $29 million
and represents the difference between our closing stock price on December 31,
2023 of $58.14 and the exercise price, times the number of shares that would
have  been  received  by  the  option  holder  had  the  option  holder  exercised  the
stock options on that date. This amount can change based on the fair market
value of our common stock. As of December 31, 2023 and 2022, 0.8 million
outstanding stock options were exercisable and the weighted-average exercise
price was $22.23. 

ESPP

We  have  an  ESPP  under  which  approximately  11.4  million  shares  of  our
common  stock  were  available  for  future  issuance  as  of  December  31,  2023.
Under  our  ESPP,  employees  may  purchase  shares  having  a  value  not
exceeding  10.0%  of  their  annual  compensation,  subject  to  applicable  annual
Internal Revenue Service limitations. We record compensation expense related
to the 15.0% discount that is given to our employees.

Year Ended December 31,

2023

2022

2021

Number of shares purchased by
employees
Weighted-average price of

shares purchased

Compensation expense (in

millions)

$

$

687,688 

591,820 

605,274 

42.33  $

43.54  $

41.41 

7  $

8  $

7 

12. NASDAQ STOCKHOLDERS’ EQUITY

Common Stock

As  of  December  31,  2023,  900,000,000  shares  of  our  common  stock  were
authorized,  598,014,520  shares  were  issued  and  575,159,336  shares  were
outstanding.  As  of  December  31,  2022,  900,000,000  shares  of  our  common
stock  were  authorized,  513,157,630  shares  were  issued  and  491,592,491
shares were outstanding. The holders of common stock are entitled to one vote
per share, except that our certificate of incorporation limits the ability of any
shareholder  to  vote  in  excess  of  5.0%  of  the  then-outstanding  shares  of
Nasdaq common stock.

F-31

 
Common Stock in Treasury, at Cost

Cash Dividends on Common Stock

During  2023,  our  board  of  directors  declared  and  paid  the  following  cash
dividends:

Declaration Date

Dividend Per
Common
Share

Record Date

Total Amount
Paid

(in millions)

January 24, 2023
April 18, 2023

$

July 18, 2023

October 17, 2023

March 17,
2023
June 16, 2023
September 15,
2023
December 8,
2023

0.20 
0.22 

0.22 

0.22 

$

$

97 
109 

108 

127 
441 

Payment Date

March 31,
2023
June 30, 2023
September 29,
2023
December 22,
2023

The  total  amount  paid  of  $441  million  was  recorded  in  retained  earnings
within  Nasdaq’s  stockholders’  equity  in  the  Consolidated  Balance  Sheets  at
December 31, 2023.

In  January  2024,  the  board  of  directors  approved  a  regular  quarterly  cash
dividend of $0.22 per share on our outstanding common stock. The dividend is
payable on March 28, 2024 to shareholders of record at the close of business
on March 14, 2024. The estimated aggregate payment of this dividend is $127
million.  Future  declarations  of  quarterly  dividends  and  the  establishment  of
future  record  and  payment  dates  are  subject  to  approval  by  the  board  of
directors.

The  board  of  directors  maintains  a  dividend  policy  with  the  intention  to
provide  shareholders  with  regular  and  increasing  dividends  as  earnings  and
cash flows increase.

We account for the purchase of treasury stock under the cost method with the
shares  of  stock  repurchased  reflected  as  a  reduction  to  Nasdaq  stockholders’
equity and included in common stock in treasury, at cost in the Consolidated
Balance  Sheets.  Shares  repurchased  under  our  share  repurchase  program  are
currently  retired  and  canceled  and  are  therefore  not  included  in  the  common
stock in treasury balance. If treasury shares are reissued, they are recorded at
the average cost of the treasury shares acquired. We held 22,855,184 shares of
common stock in treasury as of December 31, 2023 and 21,565,139 shares as
of  December  31,  2022,  most  of  which  are  related  to  shares  of  our  common
stock  withheld  for  the  settlement  of  employee  tax  withholding  obligations
arising from the vesting of restricted stock and PSUs.

Share Repurchase Program

In September 2023, our board of directors authorized an increase to our share
repurchase program, bringing the aggregate authorized amount to $2.0 billion.
As of December 31, 2023, the remaining aggregate authorized amount under
the existing share repurchase program was $1.9 billion.

These repurchases may be made from time to time at prevailing market prices
in  open  market  purchases,  privately-negotiated  transactions,  block  purchase
techniques,  an  accelerated  share  repurchase  program  or  otherwise,  as
determined  by  our  management.  The  repurchases  are  primarily  funded  from
existing  cash  balances.  The  share  repurchase  program  may  be  suspended,
modified or discontinued at any time, and has no defined expiration date.

The  following  is  a  summary  of  our  share  repurchase  activity,  reported  based
on settlement date, for the year ended December 31, 2023:

Year Ended December 31,
2023

Number of shares of common stock repurchased
Average price paid per share
Total purchase price (in millions)

$
$

4,694,774 
57.36 
269 

In  the  table  above,  the  number  of  shares  of  common  stock  repurchased
excludes an aggregate of 1,290,045 shares withheld to satisfy tax obligations
of the grantee upon the vesting of restricted stock and PSUs for the year ended
December 31, 2023.

As  discussed  above  in  “Common  Stock  in  Treasury,  at  Cost,”  shares
repurchased  under  our  share  repurchase  program  are  currently  retired  and
cancelled.

Preferred Stock

Our  certificate  of  incorporation  authorizes  the  issuance  of  30,000,000  shares
of preferred stock, par value $0.01 per share, issuable from time to time in one
or more series. As of December 31, 2023 and December 31, 2022, no shares
of preferred stock were issued or outstanding.

F-32

 
 
 
 
Numerator:
Net income

attributable to
common shareholders $

Denominator:
Weighted-average
common shares
outstanding for basic
earnings per share

Weighted-average
effect of dilutive
securities - Employee
equity awards
Weighted-average
common shares
outstanding for
diluted earnings per
share

13. EARNINGS PER SHARE

14. FAIR VALUE OF FINANCIAL INSTRUMENTS

The  following  table  sets  forth  the  computation  of  basic  and  diluted  earnings
per share:

The  following  tables  present  our  financial  assets  and  financial  liabilities  that
were measured at fair value on a recurring basis as of December 31, 2023 and
December 31, 2022.

Year Ended December 31,

2023

2022

2021

(in millions, except share and per share amounts)

1,059  $

1,125  $

1,187 

Total

Level 1

Level 2

Level 3

December 31, 2023

504,909,392 

492,420,787 

497,698,377 

3,483,590 

5,436,778 

7,389,189 

European government
debt securities

State-owned enterprises
and municipal
securities

508,392,982 

497,857,565 

505,087,566 

Basic and diluted earnings per share:
Basic earnings per

share

Diluted earnings per

share

$

2.10  $

$

2.08  $

2.28  $

2.26  $

2.38 

2.35 

Swedish mortgage
bonds

Total assets at fair value $

In the table above, employee equity awards from our PSU program, which are
considered contingently issuable, are included in the computation of dilutive
earnings per share on a weighted average basis when management determines
that  the  applicable  performance  criteria  would  have  been  met  if  the
performance period ended as of the date of the relevant computation.

Securities  that  were  not  included  in  the  computation  of  diluted  earnings  per
share because their effect was antidilutive were immaterial for the years ended
December 31, 2023, 2022 and 2021.

European government
debt securities

State-owned enterprises
and municipal
securities

Swedish mortgage
bonds

Corporate debt
securities

(in millions)

$

170  $

170  $

—  $

— 

11 

— 

11 

6 
187  $

— 
170  $

6 
17  $

December 31, 2022

— 

— 
— 

Total

Level 1

Level 2

Level 3

(in millions)

$

147  $

147  $

—  $

— 

7 

20 

— 

— 

7 

20 

7 
181  $

— 
147  $

7 
34  $

— 

— 

— 
— 

Total assets at fair value $

Financial Instruments Not Measured at Fair Value on a Recurring Basis

Some  of  our  financial  instruments  are  not  measured  at  fair  value  on  a
recurring basis but are recorded at amounts that approximate fair value due to
their liquid or short-term nature. Such financial assets and financial liabilities
include:  cash  and  cash  equivalents,  restricted  cash  and  cash  equivalents,
receivables,  net,  certain  other  current  assets,  accounts  payable  and  accrued
expenses,  Section  31  fees  payable  to  SEC,  accrued  personnel  costs,
commercial paper and certain other current liabilities.

We  have  certain  investments,  primarily  our  investment  in  OCC,  which  are
accounted  for  under  the  equity  method  of  accounting.  We  have  elected  the
measurement  alternative  for  the  majority  of  our  equity  securities,  which
primarily represent various strategic investments made through our corporate
venture program. See “Equity Method Investments,” and “Equity Securities,”
of Note 6, “Investments,” for further discussion.

F-33

 
 
We  also  consider  our  debt  obligations  to  be  financial  instruments.  As  of
December  31,  2023,  the  majority  of  our  debt  obligations  were  fixed-rate
obligations.  We  are  exposed  to  changes  in  interest  rates  as  a  result  of
borrowings under our 2022 Revolving Credit Facility, as the interest rates on
this facility have a variable rate depending on the maturity of the borrowing
and the implied underlying reference rate. We are also exposed to changes in
interest rates on amounts outstanding from the sale of commercial paper under
our  commercial  paper  program  and  under  the  2023  Term  Loan  where  the
interest rates are based on either the SOFR or the base rate (or other applicable
rate  with  respect  to  non-dollar  borrowings),  plus  an  applicable  margin  that
varies  with  Nasdaq’s  credit  rating.  The  fair  value  of  our  remaining  debt
obligations utilizing discounted cash flow analyses for our floating rate debt,
and  prevailing  market  rates  for  our  fixed  rate  debt  was  $10.0  billion  as  of
December 31, 2023 and $4.4 billion as of December 31, 2022. The discounted
cash flow analyses are based on borrowing rates currently available to us for
debt  with  similar  terms  and  maturities.  Our  commercial  paper  and  our  fixed
rate  and  floating  rate  debt  are  categorized  as  Level  2  in  the  fair  value
hierarchy.

For further discussion of our debt obligations, see Note 9, “Debt Obligations.”

Non-Financial Assets Measured at Fair Value on a Non-Recurring Basis

Our non-financial assets, which include goodwill, intangible assets, and other
long-lived  assets,  are  not  required  to  be  carried  at  fair  value  on  a  recurring
basis.  Fair  value  measures  of  non-financial  assets  are  primarily  used  in  the
impairment  analysis  of  these  assets.  Any  resulting  asset  impairment  would
require that the non-financial asset be recorded at its fair value. Nasdaq uses
Level 3 inputs to measure the fair value of the above assets on a non-recurring
basis. As of December 31, 2023 and December 31, 2022, there were no non-
financial assets measured at fair value on a non-recurring basis.

15. CLEARING OPERATIONS

Nasdaq Clearing

Nasdaq  Clearing  is  authorized  and  supervised  under  EMIR  as  a  multi-asset
clearinghouse  by  the  SFSA.  Such  authorization  is  effective  for  all  member
states of the European Union and certain other non-member states that are part
of the European Economic Area, including Norway. The clearinghouse acts as
the  CCP  for  exchange  and  OTC  trades  in  equity  derivatives,  fixed  income
derivatives,  resale  and  repurchase  contracts,  power  derivatives,  emission
allowance derivatives, and seafood derivatives. In June 2023, we entered into
an  agreement  to  sell  our  European  energy  trading  and  clearing  business,
subject to regulatory approval.

Through  our  clearing  operations  in  the  financial  markets,  which  include  the
resale  and  repurchase  market,  the  commodities  markets,  and  the  seafood
market,  Nasdaq  Clearing  is  the  legal  counterparty  for,  and  guarantees  the
fulfillment of, each contract cleared. These contracts are not used by Nasdaq
Clearing  for  the  purpose  of  trading  on  its  own  behalf.  As  the  legal
counterparty of each transaction, Nasdaq Clearing bears the counterparty risk
between the purchaser and seller in the contract. In its guarantor role, Nasdaq
Clearing  has  precisely  equal  and  offsetting  claims  to  and  from  clearing
members  on  opposite  sides  of  each  contract,  standing  as  the  CCP  on  every
contract  cleared.  In  accordance  with  the  rules  and  regulations  of  Nasdaq
Clearing,  default  fund  and  margin  collateral  requirements  are  calculated  for
each  clearing  member’s  positions  in  accounts  with  the  CCP.  See  “Default
Fund  Contributions  and  Margin  Deposits”  below  for  further  discussion  of
Nasdaq Clearing’s default fund and margin requirements.

Nasdaq Clearing maintains three member sponsored default funds: one related
to  financial  markets,  one  related  to  commodities  markets  and  one  related  to
the  seafood  market.  Under  this  structure,  Nasdaq  Clearing  and  its  clearing
members must contribute to the total regulatory capital related to the clearing
operations of Nasdaq Clearing. This structure applies an initial separation of
default fund contributions for the financial, commodities and seafood markets
in order to create a buffer for each market’s counterparty risks. See “Default
Fund Contributions” below for further discussion of Nasdaq Clearing’s default
fund.  A  power  of  assessment  and  a  liability  waterfall  have  also  been
implemented  to  further  align  risk  between  Nasdaq  Clearing  and  its  clearing
members.  See  “Power  of  Assessment”  and  “Liability  Waterfall”  below  for
further discussion.

Default Fund Contributions and Margin Deposits

As  of  December  31,  2023,  clearing  member  default  fund  contributions  and
margin deposits were as follows:

Cash Contributions

December 31, 2023

Non-Cash
Contributions

(in millions)

Total Contributions

$

$

900 
6,375 
7,275 

$

$

222 
5,750 
5,972 

$

$

1,122 
12,125 
13,247 

Default fund
contributions
Margin deposits

Total

Of the total default fund contributions of $1,122 million, Nasdaq Clearing can
utilize $858 million as capital resources in the event of a counterparty default.
The  remaining  balance  of  $264  million  pertains  to  member  posted  surplus
balances.

Our  clearinghouse  holds  material  amounts  of  clearing  member  cash  deposits
which  are  held  or  invested  primarily  to  provide  security  of  capital  while
minimizing  credit,  market  and  liquidity  risks.  While  we  seek  to  achieve  a
reasonable  rate  of  return,  we  are  primarily  concerned  with  preservation  of
capital and managing the risks associated with these deposits.

F-34

 
 
 
Clearing member cash contributions are maintained in demand deposits held
at  central  banks  and  large,  highly  rated  financial  institutions  or  secured
through direct investments, primarily central bank certificates and highly rated
European  government  debt  securities  with  original  maturities  primarily  one
year or less, reverse repurchase agreements and multilateral development bank
debt  securities.  Investments  in  reverse  repurchase  agreements  range  in
maturity  from  3  to  5  days  and  are  secured  with  highly  rated  government
securities  and  multilateral  development  banks.  The  carrying  value  of  these
securities  approximates  their  fair  value  due  to  the  short-term  nature  of  the
instruments and reverse repurchase agreements.

Nasdaq Clearing has invested the total cash contributions of $7,275 million as
of  December  31,  2023  and  $7,021  million  as  of  December  31,  2022,  in
accordance with its investment policy as follows:

December 31, 2023

December 31, 2022

$

Demand deposits
Central bank certificates
Restricted cash and cash equivalents $
European government debt securities
Reverse repurchase agreements
Multilateral development bank debt

securities
Investments

Total

$
$

(in millions)

5,344  $
1,301 
6,645  $
306 
209 

115 
630  $
7,275  $

4,775 
1,695 
6,470 
222 
192 

137 
551 
7,021 

In the table above, the change from December 31, 2022 to December 31, 2023
includes  currency  translation  adjustments  of  $229  million  for  restricted  cash
and cash equivalents and $5 million for investments.

For the years ended December 31, 2023, 2022 and 2021 investments related to
default  funds  and  margin  deposits,  net  includes  purchases  of  investment
securities  of  $53,657  million  and  $47,525  million,  and  $41,098  million
respectively, and proceeds from sales and redemptions of investment securities
of $53,583 million, $47,736 million and $40,966 million respectively.

In the investment activity related to default fund and margin contributions, we
are  exposed  to  counterparty  risk  related  to  reverse  repurchase  agreement
transactions,  which  reflect  the  risk  that  the  counterparty  might  become
insolvent  and,  thus,  fail  to  meet  its  obligations  to  Nasdaq  Clearing.  We
mitigate  this  risk  by  only  engaging  in  transactions  with  high  credit  quality
reverse  repurchase  agreement  counterparties  and  by  limiting  the  acceptable
collateral  under  the  reverse  repurchase  agreement  to  high  quality  issuers,
primarily government securities and other securities explicitly guaranteed by a
government.  The  value  of  the  underlying  security  is  monitored  during  the
lifetime  of  the  contract,  and  in  the  event  the  market  value  of  the  underlying
security  falls  below  the  reverse  repurchase  amount,  our  clearinghouse  may
require additional collateral or a reset of the contract.

Default Fund Contributions

Required contributions to the default funds are proportional to the exposures
of each clearing member. When a clearing member is active in more than one
market, contributions must be made to all markets’ default funds in which the
member is active. Clearing members’ eligible contributions may include cash
and  non-cash  contributions.  Cash  contributions  received  are  maintained  in
demand  deposits  held  at  central  banks  and  large,  highly  rated  financial
institutions or invested by Nasdaq Clearing, in accordance with its investment
policy,  either  in  central  bank  certificates,  highly  rated  government  debt
securities,  reverse  repurchase  agreements  with  highly  rated  government  debt
securities  as  collateral,  or  multilateral  development  bank  debt  securities.
Nasdaq  Clearing  maintains  and  manages  all  cash  deposits  related  to  margin
collateral.  All  risks  and  rewards  of  collateral  ownership,  including  interest,
belong  to  Nasdaq  Clearing.  Clearing  members’  cash  contributions  are
included  in  default  funds  and  margin  deposits  in  the  Consolidated  Balance
Sheets  as  both  a  current  asset  and  a  current  liability.  Non-cash  contributions
include  highly  rated  government  debt  securities  that  must  meet  specific
criteria  approved  by  Nasdaq  Clearing.  Non-cash  contributions  are  pledged
assets  that  are  not  recorded  in  the  Consolidated  Balance  Sheets  as  Nasdaq
Clearing  does  not  take  legal  ownership  of  these  assets  and  the  risks  and
rewards remain with the clearing members. These balances may fluctuate over
time due to changes in the amount of deposits required and whether members
choose to provide cash or non-cash contributions. Assets pledged are held at a
nominee  account  in  Nasdaq  Clearing’s  name  for  the  benefit  of  the  clearing
members and are immediately accessible by Nasdaq Clearing in the event of a
default.

F-35

 
 
In  addition  to  clearing  members’  required  contributions  to  the  liability
waterfall, Nasdaq Clearing is also required to contribute capital to the liability
waterfall  and  overall  regulatory  capital  as  specified  under  its  clearinghouse
rules. As of December 31, 2023, Nasdaq Clearing committed capital totaling
$123  million  to  the  liability  waterfall  and  overall  regulatory  capital,  in  the
form  of  government  debt  securities,  which  are  recorded  as  financial
investments  in  the  Consolidated  Balance  Sheets.  The  combined  regulatory
capital of the clearing members and Nasdaq Clearing is intended to secure the
obligations of a clearing member exceeding such member’s own margin and
default fund deposits and may be used to cover losses sustained by a clearing
member in the event of a default.

Margin Deposits

Nasdaq  Clearing  requires  all  clearing  members  to  provide  collateral,  which
may consist of cash and non-cash contributions, to guarantee performance on
the clearing members’ open positions, or initial margin. In addition, clearing
members must also provide collateral to cover the daily margin call if needed.
See  “Default  Fund  Contributions”  above  for  further  discussion  of  cash  and
non-cash contributions.

Similar to default fund contributions, Nasdaq Clearing maintains and manages
all  cash  deposits  related  to  margin  collateral.  All  risks  and  rewards  of
collateral  ownership,  including  interest,  belong  to  Nasdaq  Clearing  and  are
recorded  in  revenues.  These  cash  deposits  are  recorded  in  default  funds  and
margin deposits in the Consolidated Balance Sheets as both a current asset and
a  current  liability.  Pledged  margin  collateral  is  not  recorded  in  our
Consolidated Balance Sheets as all risks and rewards of collateral ownership,
including  interest,  belong  to  the  counterparty.  Assets  pledged  are  held  at  a
nominee  account  in  Nasdaq  Clearing’s  name  for  the  benefit  of  the  clearing
members and are immediately accessible by Nasdaq Clearing in the event of a
default.

Nasdaq  Clearing  marks  to  market  all  outstanding  contracts  and  requires
payment from clearing members whose positions have lost value. The mark-
to-market process helps identify any clearing members that may not be able to
satisfy  their  financial  obligations  in  a  timely  manner  allowing  Nasdaq
Clearing the ability to mitigate the risk of a clearing member defaulting due to
exceptionally  large  losses.  In  the  event  of  a  default,  Nasdaq  Clearing  can
access the defaulting member’s margin and default fund deposits to cover the
defaulting member’s losses.

Regulatory Capital and Risk Management Calculations

Nasdaq  Clearing  manages  risk  through  a  comprehensive  counterparty  risk
management framework, which comprises policies, procedures, standards and
financial  resources.  The  level  of  regulatory  capital  is  determined  in
accordance with Nasdaq Clearing’s regulatory capital and default fund policy,
as  approved  by  the  SFSA.  Regulatory  capital  calculations  are  continuously
updated through a proprietary capital-at-risk calculation model that establishes
the appropriate level of capital.

As  mentioned  above,  Nasdaq  Clearing  is  the  legal  counterparty  for  each
contract  cleared  and  thereby  guarantees  the  fulfillment  of  each  contract.
Nasdaq Clearing accounts for this guarantee as a performance guarantee. We
determine  the  fair  value  of  the  performance  guarantee  by  considering  daily
settlement of contracts and other margining and default fund requirements, the
risk  management  program,  historical  evidence  of  default  payments,  and  the
estimated  probability  of  potential  default  payouts.  The  calculation  is
determined  using  proprietary  risk  management  software  that  simulates  gains
and  losses  based  on  historical  market  prices,  extreme  but  plausible  market
scenarios,  volatility  and  other  factors  present  at  that  point  in  time  for  those
particular  unsettled  contracts.  Based  on  this  analysis,  excluding  any  liability
related to the Nasdaq commodities clearing default (see discussion above), the
estimated liability was nominal and no liability was recorded as of December
31, 2023.

Power of Assessment 

To further strengthen the contingent financial resources of the clearinghouse,
Nasdaq Clearing has power of assessment that provides the ability to collect
additional  funds  from  its  clearing  members  to  cover  a  defaulting  member’s
remaining  obligations  up  to  the  limits  established  under  the  terms  of  the
clearinghouse  rules.  The  power  of  assessment  corresponds  to  230%  of  the
clearing  member’s  aggregate  contribution  to  the  financial,  commodities  and
seafood markets’ default funds.

Liability Waterfall

The  liability  waterfall  is  the  priority  order  in  which  the  capital  resources
would  be  utilized  in  the  event  of  a  default  where  the  defaulting  clearing
member’s  collateral  and  default  fund  contribution  would  not  be  sufficient  to
cover  the  cost  to  settle  its  portfolio.  If  a  default  occurs  and  the  defaulting
clearing  member’s  collateral,  including  cash  deposits  and  pledged  assets,  is
depleted, then capital is utilized in the following amount and order:

• junior capital contributed by Nasdaq Clearing, which totaled $41 million as

of December 31, 2023;

• a loss-sharing pool related only to the financial market that is contributed to
by clearing members and only applies if the defaulting member’s portfolio
includes interest rate swap products;

F-36

• specific  market  default  fund  where  the  loss  occurred  (i.e.,  the  financial,
commodities,  or  seafood  market),  which  includes  capital  contributions  of
the clearing members on a pro-rata basis; and

• fully  segregated  senior  capital  for  each  specific  market  contributed  by
Nasdaq Clearing, calculated in accordance with clearinghouse rules, which
totaled $17 million as of December 31, 2023.

If  additional  funds  are  needed  after  utilization  of  the  liability  waterfall,  or  if
part  of  the  waterfall  has  been  utilized  and  needs  to  be  replenished,  then
Nasdaq  Clearing  will  utilize  its  power  of  assessment  and  additional  capital
contributions  will  be  required  by  non-defaulting  members  up  to  the  limits
established under the terms of the clearinghouse rules.

During  2022,  Nasdaq  Clearing  updated  its  recovery  plan  and  rule  book  by
introducing  additional  recovery  tools,  in  line  with  the  new  European  Union
regulations  for  the  recovery  and  resolution  of  central  counterparties,  which
became effective during 2022.

In  addition  to  the  capital  held  to  withstand  counterparty  defaults  described
above,  Nasdaq  Clearing  also  has  committed  capital  of  $65  million  to  ensure
that  it  can  handle  an  orderly  wind-down  of  its  operation,  and  that  it  is
adequately protected against investment, operational, legal, and business risks.

Market Value of Derivative Contracts Outstanding

The  following  table  presents  the  market  value  of  derivative  contracts
outstanding prior to netting:

Commodity and seafood options, futures and
forwards
Fixed-income options and futures
Stock options and futures
Index options and futures

Total

In the table above:

December 31, 2023

(in millions)

$

$

139 
1,027 
140 
32 
1,338 

• We  determined  the  fair  value  of  our  option  contracts  using  standard
valuation  models  that  were  based  on  market-based  observable  inputs
including  implied  volatility,  interest  rates  and  the  spot  price  of  the
underlying instrument.

• We  determined  the  fair  value  of  our  futures  contracts  based  upon  quoted

market prices and average quoted market yields.

• We  determined  the  fair  value  of  our  forward  contracts  using  standard
valuation  models  that  were  based  on  market-based  observable  inputs
including benchmark rates and the spot price of the underlying instrument.

Derivative Contracts Cleared

The following table presents the total number of derivative contracts cleared
through Nasdaq Clearing for the years ended December 31, 2023 and 2022:

Commodity and seafood options, futures
and forwards
Fixed-income options and futures
Stock options and futures
Index options and futures

Total

Year Ended December 31,

2023

2022

233,194 
19,175,402 
20,728,290 
40,009,367 
80,146,253 

288,142 
21,992,124 
18,619,950 
45,616,647 
86,516,863 

In  the  table  above,  the  total  volume  in  cleared  power  related  to  commodity
contracts  was  422  Terawatt  hours  (TWh)  and  413  TWh  for  the  years  ended
December 31, 2023 and 2022, respectively.

Resale and Repurchase Agreements Contracts Outstanding and Cleared

The outstanding contract value of resale and repurchase agreements was $580
million and $120 million as of December 31, 2023 and 2022, respectively. The
total  number  of  resale  and  repurchase  agreements  contracts  cleared  was
4,669,740  and  6,287,717  for  the  years  ended  December  31,  2023  and  2022,
respectively.

16. LEASES

We have operating leases which are primarily real estate leases predominantly
for  our  U.S.  and  European  headquarters,  data  centers  and  for  general  office
space.  The  following  table  provides  supplemental  balance  sheet  information
related to Nasdaq’s operating leases:

Leases

Assets:
Operating lease
assets

Liabilities:
Current lease
liabilities
Non-current lease
liabilities
Total lease
liabilities

Balance Sheet
Classification

Operating lease
assets

Other current
liabilities
Operating lease
liabilities

$

$

$

December 31, 2023

December 31, 2022

(in millions)

402  $

444 

62  $

417 

479  $

54 

452 

506 

F-37

 
 
 
The following table summarizes Nasdaq’s lease cost: 

Operating lease cost
Variable lease cost
Sublease income

Total lease cost

Year Ended December 31,

2023

2022

2021

(in millions)

$

$

88  $
44 
(3)
129  $

75  $
32 
(3)
104  $

85 
28 
(4)
109 

In the table above, operating lease costs include short-term lease cost, which
was immaterial.

In the first quarter of 2023, we initiated a review of our real estate and facility
capacity requirements due to our new and evolving work models. As a result
of  this  ongoing  review,  for  the  year  ended  December  31,  2023,  we  recorded
impairment charges of $23 million, of which $13 million related to operating
lease  asset  impairment  and  is  included  in  operating  lease  cost  in  the  table
above, $5 million related to exit costs and is included in variable lease cost in
the  table  above  and  $5  million  related  to  impairment  of  leasehold
improvements,  which  are  recorded  in  depreciation  and  amortization  expense
in the Consolidated Statements of Income. We fully impaired our lease assets
for locations that we vacated with no intention to sublease. Substantially all of
the  property,  equipment  and  leasehold  improvements  associated  with  the
vacated leased office space were fully impaired as there are no expected future
cash flows for these items.

The  following  table  reconciles  the  undiscounted  cash  flows  for  each  of  the
first five years and total of the remaining years to the operating lease liabilities
recorded in our Consolidated Balance Sheets.

December 31, 2023

(in millions)

2024
2025
2026
2027
2028
2029+
Total lease payments

Less: interest

Present value of lease liabilities

$

$

80 
68 
55 
52 
50 
270 
575 
(96)
479 

In the table above, interest is calculated using the interest rate for each lease.
Present value of lease liabilities includes the current portion of $62 million.

Total lease payments in the table above exclude $41 million of legally binding
minimum lease payments for leases signed but not yet commenced.

The  following  table  provides  information  related  to  Nasdaq’s  lease  term  and
discount rate:

Weighted-average remaining lease term (in years)

Weighted-average discount rate

December 31, 2023

9.6

3.8 %

The  following  table  provides  supplemental  cash  flow  information  related  to
Nasdaq’s operating leases:

Year Ended December 31,

2023

2022

(in millions)

2021

78  $

66  $

26  $

137  $

77 

45 

Cash paid for amounts included in
the measurement of operating lease
liabilities

Lease assets obtained in exchange
for operating lease liabilities

$

$

17. INCOME TAXES

Income Before Income Tax Provision

The following table presents the domestic and foreign components of income
provision:
before 

income 

tax 

Domestic
Foreign
Income before income tax
provision

$

$

Year Ended December 31,

2023

2022

(in millions)

2021

1,073  $
328 

1,216  $
259 

1,299 
235 

1,401  $

1,475  $

1,534 

Income Tax Provision

The 

income 

tax  provision 

consists  of 

following 

the 
Year Ended December 31,

amounts:

Current income taxes provision:
Federal
State
Foreign
Total current income taxes provision
Deferred income taxes provision
(benefit):
Federal
State
Foreign
Total deferred income taxes provision

Total income tax provision

$

$

2023

2022

2021

(in millions)

145  $
52 
79 
276 

51 
8 
9 
68 
344  $

170  $
67 
77 
314 

36 
6 
(4)
38 
352  $

144 
45 
64 
253 

82 
22 
(10)
94 
347 

F-38

 
 
 
 
 
We  have  determined 
that  undistributed  earnings  of  certain  non-U.S.
subsidiaries are not considered indefinitely reinvested and would not give rise
to  a  material  tax  liability  when  remitted.  Nasdaq  continues  to  indefinitely
reinvest all other outside basis differences to the extent reversal would incur a
significant  tax  liability.  A  determination  of  an  unrecognized  deferred  tax
liability related to such outside basis differences is not practicable.

A  reconciliation  of  the  income  tax  provision,  based  on  the  U.S.  federal
statutory  rate,  to  our  actual  income  tax  provision  for  the  years  ended
follows:
December 

2023, 

2022 

and 

31, 

as 
2021 
Year Ended December 31,

is 

Federal income tax provision at the
statutory rate
State income tax provision, net of
federal effect
Deduction for foreign derived
intangible income
Excess tax benefits related to
employee share-based
compensation
Non-U.S. subsidiary earnings
Tax credits and deductions
Change in unrecognized tax benefits
Other, net

Actual income tax provision

2023

2022

2021

21.0 %

21.0 %

21.0 %

3.2 %

3.8 %

3.9 %

(1.6)%

(1.0)%

(1.2)%

(0.7)%
2.5 %
(0.2)%
1.0 %
(0.6)%
24.6 %

(0.9)%
1.2 %
(0.3)%
1.1 %
(1.0)%
23.9 %

(1.4)%
1.2 %
(0.3)%
0.6 %
(1.2)%
22.6 %

The increase in our effective tax rate in 2023 compared to 2022 was primarily
due to increased US tax on overseas earnings. The increase in our effective tax
rate  in  2022  compared  to  2021  was  primarily  due  to  an  increase  in  state
unrecognized tax benefits.

The  effective  tax  rate  may  vary  from  period  to  period  depending  on,  among
other factors, the geographic and business mix of earnings and losses. These
same  and  other  factors,  including  history  of  pre-tax  earnings  and  losses,  are
taken into account in assessing the ability to realize deferred tax assets.

Deferred Income Taxes

The  temporary  differences,  which  give  rise  to  our  deferred  tax  assets  and
following:
(liabilities), 

consisted 

the 

of 

$

Deferred tax assets:
Deferred revenues
U.S. federal net operating loss
Foreign net operating loss
State net operating loss
Compensation and benefits
Deferred interest expense
Tax credits
Federal benefit of uncertain tax positions
Operating lease liabilities
Other
Gross deferred tax assets
Less: valuation allowance
Total deferred tax assets, net of valuation allowance $

December 31,

2023

2022

(in millions)

19  $
— 
12 
3 
45 
55 
26 
12 
118 
29 
319 
(4)
315  $

18 
5 
12 
3 
42 
— 
3 
9 
118 
33 
243 
(4)
239 

Deferred tax liabilities:
Amortization of software development costs and
depreciation
Amortization of acquired intangible assets and
goodwill
Investments
Unrealized gains
Operating lease assets
Other
Gross deferred tax liabilities

Net deferred tax liabilities
Reported as:
Non-current deferred tax assets
Deferred tax liabilities, net

Net deferred tax liabilities

$

(21) $

(65)

(1,736)
(74)
(11)
(99)
(9)
(1,950) $
(1,635) $

7  $

(1,642)
(1,635) $

(375)
(105)
(29)
(103)
(15)
(692)
(453)

3 
(456)
(453)

$
$

$

$

In the table above, non-current deferred tax assets are included in other non-
current assets in the Consolidated Balance Sheets.

We recognized a valuation allowance of $4 million as of December 31, 2023
and 2022 due to recurring operating losses in a foreign jurisdiction. Based on
all available positive and negative evidence, we believe the sources of future
taxable income are sufficient to realize the remainder of Nasdaq’s deferred tax
asset inventory.

F-39

 
 
 
 
 
 
 
 
Nasdaq has deferred tax assets associated with net operating losses, or NOLs,
in U.S. state and local and non-U.S. jurisdictions with the following expiration
dates:

Jurisdiction

December 31, 2023

Expiration Date

Foreign NOL
U.S. state and local NOL

Unrecognized Tax Benefits

(in millions)

$

12 
3 

2039-2043
2025-2042

A  reconciliation  of  the  beginning  and  ending  amount  of  unrecognized  tax
benefits is as follows:

Beginning balance
Additions as a result of tax positions taken in
prior periods
Additions as a result of tax positions taken in
the current period
Reductions related to settlements with taxing
authorities
Reductions as a result of lapses of the
applicable statute of limitations

Ending balance

Year Ended December 31,

2023

2022

2021

(in millions)

$

70  $

57  $

2 

25 

(14)

13 

9 

(7)

(3)
80  $

(2)
70  $

$

42 

16 

11 

(6)

(6)
57 

We  had  $80  million  of  unrecognized  tax  benefits  as  of  December  31,  2023,
$70  million  as  of  December  31,  2022,  and  $57  million  as  of  December  31,
2021  which,  if  recognized  in  the  future,  would  affect  our  effective  tax  rate.
Nasdaq  does  not  believe  that  our  unrecognized  tax  benefits  will  materially
change over the next 12 months.

We  recognize  interest  and/or  penalties  related  to  income  tax  matters  in  the
provision for income taxes in our Consolidated Statements of Income, which
was  $3  million  tax  expense  for  the  year  ended  December  31,  2023  and  less
than  $1  million  for  the  year  ended  December  31,  2022  and  $2  million  tax
benefit  for  the  year  ended  for  December  31,  2021.  Accrued  interest  and
penalties,  net  of  tax  effect  were  $6  million  as  of  December  31,  2023  and  $5
million as of December 31, 2022.

Tax Audits

Nasdaq and its eligible subsidiaries file a consolidated U.S. federal income tax
return and applicable state and local income tax returns and non-U.S. income
tax  returns.  We  are  subject  to  examination  by  federal,  state  and  local,  and
foreign  tax  authorities.  Our  Federal  income  tax  return  is  under  audit  for  tax
year 2018 and is subject to examination by the Internal Revenue Service for
the  years  2020  through  2022.  Several  state  tax  returns  are  currently  under
examination by the respective tax authorities for the years 2014 through 2022.
Non-U.S.  tax  returns  are  subject  to  examination  by  the  respective  tax
authorities for the years 2018 through 2023. We regularly assess the likelihood
of  additional  assessments  by  each  jurisdiction  and  have  established  tax
reserves that we believe are adequate in relation to the potential for additional
assessments. Examination outcomes and the timing of

examination  settlements  are  subject  to  uncertainty.  Although  the  results  of
such examinations may have an impact on our unrecognized tax benefits, we
do  not  anticipate  that  such  impact  will  be  material  to  our  consolidated
financial  position  or  results  of  operations.  We  do  not  expect  to  settle  any
material tax audits in the next twelve months.

18. COMMITMENTS, CONTINGENCIES AND GUARANTEES

Guarantees Issued and Credit Facilities Available

In addition to the default fund contributions and margin collateral pledged by
clearing  members  discussed  in  Note  15,  “Clearing  Operations,”  we  have
obtained financial guarantees and credit facilities, which are guaranteed by us
through counter indemnities, to provide further liquidity related to our clearing
businesses.  Financial  guarantees  issued  to  us  totaled  $4  million  as  of
December  31,  2023  and  2022.  As  discussed  in  “Other  Credit  Facilities,”  of
Note 9, “Debt Obligations,” we also have credit facilities primarily related to
our  Nasdaq  Clearing  operations,  which  are  available  in  multiple  currencies,
and  totaled  $191  million  as  of  December  31,  2023  and  $184  million  as  of
December 31, 2022 in available liquidity, none of which was utilized.

Other Guarantees

Through our clearing operations in the financial markets, Nasdaq Clearing is
the  legal  counterparty  for,  and  guarantees  the  performance  of,  its  clearing
members.  See  Note  15,  “Clearing  Operations,”  for  further  discussion  of
Nasdaq Clearing performance guarantees.

We  have  provided  a  guarantee  related  to  lease  obligations  for  The  Nasdaq
Entrepreneurial Center, Inc., which is a not-for-profit organization designed to
convene, connect and engage aspiring and current entrepreneurs. This entity is
not included in the consolidated financial statements of Nasdaq.

We  believe  that  the  potential  for  us  to  be  required  to  make  payments  under
these arrangements is unlikely. Accordingly, no contingent liability is recorded
in the Consolidated Balance Sheets for the above guarantees.

Routing Brokerage Activities

to  guarantee 

require  members 

One of our broker-dealer subsidiaries, Nasdaq Execution Services, provides a
guarantee  to  securities  clearinghouses  and  exchanges  under  its  standard
the
membership  agreements,  which 
performance  of  other  members.  If  a  member  becomes  unable  to  satisfy  its
obligations to a clearinghouse or exchange, other members would be required
to meet its shortfalls. To mitigate these performance risks, the exchanges and
clearinghouses  often  require  members  to  post  collateral,  as  well  as  meet
certain  minimum  financial  standards.  Nasdaq  Execution  Services’  maximum
potential liability under these arrangements cannot be quantified. However, we
believe  that  the  potential  for  Nasdaq  Execution  Services  to  be  required  to
make  payments  under  these  arrangements  is  unlikely.  Accordingly,  no
contingent  liability  is  recorded  in  the  Consolidated  Balance  Sheets  for  these
arrangements.

F-40

Legal and Regulatory Matters 

Armenian Stock Exchange Investigation

As disclosed in our prior filings with the SEC, a former non-U.S. subsidiary of
Nasdaq,  NASDAQ  OMX  Armenia  OJSC,  operated  the  Armenian  Stock
Exchange and the Central Depository of Armenia, which are regulated by the
Central  Bank  of  Armenia  under  Armenian  law.  In  accordance  with  the
requirements  of  Armenian  law,  Mellat  Bank  SB  CJSC,  an  Armenian  entity
that is designated under Executive Order 13382, was a market participant on
the  Armenian  Stock  Exchange  and,  as  a  result,  paid  participation  and
transaction  fees  to  the  Armenian  Stock  Exchange  during  the  period  from
2012-2014.  In  2014,  we  voluntarily  self-disclosed  this  matter  to  the  U.S.
Department  of  Treasury’s  Office  of  Foreign  Assets  Control,  or  OFAC,  and
received authorization from OFAC to continue, if necessary, certain activities
pertaining to Mellat Bank SB CJSC in Armenia in a limited manner. In 2015,
Nasdaq sold a majority of its ownership of Nasdaq OMX Armenia OJSC, with
the remaining minority interest sold in 2018.

As previously disclosed, OFAC conducted an inquiry into the Armenian Stock
Exchange matter described above and in our prior filings since 2016. During
the first quarter of 2021, we were advised that OFAC was considering a civil
monetary  penalty  in  connection  with  that  matter.  In  November  2023,  we
reached  a  settlement  with,  and  made  a  payment  to,  OFAC,  which  was
materially  in  line  with  the  immaterial  loss  contingency  we  had  accrued  in
2022.

CFTC Matter

In  June  2022,  NASDAQ  Futures,  Inc.  (“NFX”),  a  non-operational,  wholly-
owned  subsidiary  of  Nasdaq,  received  a  telephonic  “Wells  Notice”  from  the
staff  of  the  CFTC  relating  to  certain  alleged  potential  violations  by  NFX  of
provisions  of  the  Commodity  Exchange  Act  and  CFTC  rules  thereunder
during  the  period  beginning  July  2015  through  October  2018.  The  alleged
potential  violations  concern  the  accuracy  of  NFX’s  description  of  one  of  its
market  maker  incentive  programs.  The  Wells  Notice  informed  NFX  that  the
CFTC  staff  has  made,  subject  to  consideration  of  NFX’s  response,  a
preliminary  determination  to  recommend  that  the  CFTC  authorize  an
enforcement  action  against  NFX  in  connection  with  its  former  futures
exchange business. Nasdaq sold NFX’s futures exchange business to a third-
party  in  November  2019,  including  the  portfolio  of  open  interest  in  NFX
contracts.  During  2020,  all  remaining  open  interest  in  NFX  contracts  was
migrated  to  other  exchanges  and  NFX  ceased  operation.  A  Wells  Notice  is
neither  a  formal  charge  of  wrongdoing  nor  a  final  determination  that  the
recipient  has  violated  any  law.  NFX  has  submitted  a  response  to  the  Wells
Notice that contests all aspects of the CFTC staff’s position. The CFTC staff
subsequently informed us that it plans to formally recommend that the CFTC
authorize  a  civil  enforcement  action.  We  cannot  predict  if  or  when  such  an
action will be brought, including the scope of the claims or the remedy sought,
but such action could commence at any time, and the scope of claims or

remedies sought could be material. We believe that NFX would have defenses
to any claims if they are the same as those alleged by the CFTC staff during
the  Wells  Notice  process.  We  are  unable  to  predict  the  ultimate  outcome  of
this  matter  or  the  amount  or  type  of  remedies  that  the  CFTC  may  seek  or
obtain,  but  any  such  remedies  could  have  a  material  negative  effect  on  our
operating results and reputation.

SFSA Inquiry

In  September  2023,  Nasdaq  Stockholm  AB,  a  wholly-owned  subsidiary  of
Nasdaq  and  the  operator  of  the  Nasdaq  Stockholm  exchange,  received  a
written notification from the SFSA regarding a review initiated with regard to
the obligation of Nasdaq Stockholm AB to report suspected market abuse. The
review  was  initiated  in  connection  with  an  investigation  of  alleged  insider
trading  in  the  shares  of  four  companies  listed  on  the  Nasdaq  Stockholm
exchange. The SFSA’s preliminary assessment is that Nasdaq Stockholm AB,
by  not  reporting  certain  suspicious  transactions  in  the  four  listed  companies,
breached  its  obligation  under  certain  provisions  of  the  Market  Abuse
Regulation and the Swedish Securities Market Act. In January 2024, the SFSA
notified Nasdaq Stockholm AB that the review will continue, and in February
the  SFSA  sent  a  request  for  submission  to  Nasdaq  for  our  review  and
response.  Nasdaq  Stockholm  AB  is  cooperating  fully  and  is  engaged  in
ongoing communications with the SFSA.

Other Matters

Except  as  disclosed  above  and  in  our  prior  reports  filed  under  the  Exchange
Act,  we  are  not  currently  a  party  to  any  litigation  or  proceeding  that  we
believe  could  have  a  material  adverse  effect  on  our  business,  consolidated
financial condition, or operating results. However, from time to time, we have
been  threatened  with,  or  named  as  a  defendant  in,  lawsuits  or  involved  in
regulatory proceedings.

In the normal course of business, Nasdaq discusses matters with its regulators
raised during regulatory examinations or otherwise subject to their inquiries.
Management  believes  that  censures,  fines,  penalties  or  other  sanctions  that
could  result  from  any  ongoing  examinations  or  inquiries  will  not  have  a
material impact on its consolidated financial position or results of operations.
However, we are unable to predict the outcome or the timing of the ultimate
resolution  of  these  matters,  or  the  potential  fines,  penalties  or  injunctive  or
other equitable relief, if any, that may result from these matters.

Related to the legal and regulatory matters described above we have recorded
immaterial legal accruals during the year ended 2023.

F-41

Tax Audits

We are engaged in ongoing discussions and audits with taxing authorities on
various tax matters, the resolutions of which are uncertain. Currently, there are
matters that may lead to assessments, some of which may not be resolved for
several  years.  Based  on  currently  available  information,  we  believe  we  have
adequately  provided  for  any  assessments  that  could  result  from  those
proceedings  where  it  is  more  likely  than  not  that  we  will  be  assessed.  We
review our positions on these matters as they progress. See “Tax Audits,” of
Note 17, “Income Taxes,” for further discussion.

19. BUSINESS SEGMENTS

Prior to November 1, 2023, we managed, operated and provided our products
and  services  in  three  business  segments:  Market  Platforms,  Capital  Access
Platforms  and  Anti-Financial  Crime.  After  the  closing  of  the  Adenza
acquisition, we realigned our reportable segments to Capital Access Platforms,
Financial  Technology  and  Market  Services.  See  Note  1,  “Organization  and
Nature of Operations,” for further discussion of our reportable segments.

This Annual Report on Form 10-K presents our results in alignment with the
new corporate structure. All periods presented are restated to reflect the new
structure.

Our management allocates resources, assesses performance and manages these
businesses  as  three  separate  segments.  We  evaluate  the  performance  of  our
segments based on several factors, of which the primary financial measure is
operating income. Results of individual businesses are presented based on our
management accounting practices and structure. Our chief operating decision
maker  does  not  review  total  assets  or  statements  of  income  below  operating
income by segments as key performance metrics; therefore, such information
is not presented below.

The  following  table  presents  certain  information  regarding  our  business
segments for the years ended December 31, 2023, 2022 and 2021:

Year Ended December 31,

2023

2022

(in millions)

2021

Capital Access Platforms
Total revenues
Depreciation and amortization*
Operating income
Purchase of property and equipment
Financial Technology
Total revenues
Depreciation and amortization*
Operating income
Purchase of property and equipment
Market Services
Total revenues
Transaction-based expenses
Revenues less transaction-based
expenses
Depreciation and amortization*
Operating income
Purchase of property and equipment
Corporate Items
Total revenues
Depreciation and amortization
Operating loss

$

Consolidated
Total revenues
Transaction-based expenses
Revenues less transaction-based
expenses
$
Depreciation and amortization
Operating income
$
Purchase of property and equipment $

$

$

1,770  $
39 
971 
53 

1,682  $
36 
914 
50 

1,099 
36 
494 
50 

3,156 
(2,169)

987 

34 
582 
55 

39 
214 
(469)

864 
35 
299 
49 

3,632 
(2,644)

988 

32 
627 
53 

48 
155 
(276)

6,064  $
(2,169)

6,226  $
(2,644)

3,895  $

3,582  $

323  $
1,578  $
158  $

258  $
1,564  $
152  $

1,566 
34 
842 
50 

772 
36 
259 
55 

3,471 
(2,466)

1,005 

34 
664 
58 

77 
174 
(324)

5,886 
(2,466)

3,420 

278 
1,441 
163 

* excludes amortization of acquired intangible assets

F-42

Below amounts are allocated to Corporate Items in our management reports as
we  believe  they  do  not  contribute  to  a  meaningful  evaluation  of  a  particular
segment’s  ongoing  operating  performance.  Management  does  not  consider
these items for the purpose of evaluating the performance of our segments or
their managers or when making decisions to allocate resources. Therefore, we
believe  performance  measures  excluding 
items  provide
management with a useful representation of our segments’ ongoing activity in
each period. These items, which are presented in the table below, include the
following:

the  below 

• Amortization expense of acquired intangible assets: We amortize intangible
assets  acquired  in  connection  with  various  acquisitions.  Intangible  asset
amortization  expense  can  vary  from  period  to  period  due  to  episodic
acquisitions  completed,  rather  than  from  our  ongoing  business  operations.
As  such,  if  intangible  asset  amortization  is  included  in  performance
measures, it is more difficult to assess the day-to-day operating performance
of  the  segments,  and  the  relative  operating  performance  of  the  segments
between periods.

• Merger and strategic initiatives expense: We have pursued various strategic
initiatives  and  completed  acquisitions  and  divestitures  in  recent  years  that
have  resulted  in  expenses  which  would  not  have  otherwise  been  incurred.
These  expenses  generally  include  integration  costs,  as  well  as  legal,  due
diligence  and  other  third-party  transaction  costs.  The  frequency  and  the
amount  of  such  expenses  vary  significantly  based  on  the  size,  timing  and
complexity of the transaction. For the year ended December 31, 2023, these
costs primarily relate to the Adenza acquisition.

• Restructuring charges: In the fourth quarter of 2023, following the closing
of  the  Adenza  acquisition,  our  management  approved,  committed  to  and
initiated  a  restructuring  program,  “Adenza  Restructuring”  to  optimize  our
efficiencies  as  a  combined  organization.  In  October  2022,  following  our
September 2022 announcement to realign our segments and leadership, we
initiated  a  divisional  alignment  program  with  a  focus  on  realizing  the  full
potential  of  this  structure.  In  2019,  we  initiated  the  transition  of  certain
technology platforms to advance our strategic opportunities as a technology
and  analytics  provider  and  continue  the  realignment  of  certain  business
areas.  See  Note  20,  “Restructuring  Charges,”  for  further  discussion  of  this
plan.

• Revenues  and  expenses  -  divested  businesses:  For  the  years  ended
December  31,  2023,  2022  and  2021,  these  amounts  include  revenues  and
expenses  related  to  our  European  power  trading  and  clearing  business,
following  our  announcement  in  June  2023  to  sell  this  business,  subject  to
regulatory  approval.  Historically,  these  amounts  were  included  in  our
Market Services and Capital Access Platforms results. For 2022 and 2021,
we have included in corporate items the revenues and expenses of our U.S.
Fixed  Income  business,  which  was  previously  included  in  our  Market
Services and Capital Access Platforms results.

Also included are the revenues and expenses of our Nordic broker services
business  for  which  we  completed  the  wind-down  in  June  2022.  For  2021,
we  included  in  corporate  items  the  revenues  and  expenses  associated  with
the  NPM  business  which  we  contributed  to  a  standalone,  independent
company,  of  which  we  own  the  largest  minority  interest,  together  with  a
consortium  of  third-party  financial  institutions  in  July  2021.  Prior  to  July,
these  revenues  were  previously  included  in  our  Capital  Access  Platforms
results.  For  the  years  ended  December  31,  2023,  2022  and  2021,  other
revenues  also  include  a  transitional  services  agreement  associated  with  a
divested business.

• Other items: We  have  included  certain  other  charges  or  gains  in  corporate
items, to the extent we believe they should be excluded when evaluating the
ongoing  operating  performance  of  each  individual  segment.  Other  items
primarily include:

◦ Lease  asset  impairments:  For  2023,  this  includes  impairment  charges
related  to  our  operating  lease  assets  and  leasehold  improvements
associated with vacating certain leased office space, which are recorded in
occupancy  and  depreciation  and  amortization  expense 
in  our
Consolidated Statements of Income.

◦ Extinguishment  of  debt:  For  2022  and  2021  this  includes  a  loss  on
extinguishment  of  debt,  which  is  recorded  under  general,  administrative
and other expense in our Consolidated Statements of Income.

◦ Legal and regulatory matters: For 2023 and 2022, this includes accruals
related  to  certain  legal  matters.  For  2023,  these  charges  were  partially
offset by insurance recoveries related to certain legal matters. The charges
and related insurance recoveries are recorded in professional and contract
services  and  general,  administrative  and  other  expense 
the
Consolidated Statements of Income. For 2022 and 2021, this also includes
a charge related to an administrative fine imposed by the SFSA related to
the  clearing  default  that  occurred  in  2018.  This  charge  was  included  in
regulatory expense in the Consolidated Statements of Income.

in 

◦ Pension  settlement  charge:  For  2023,  we  terminated  our  U.S.  pension
plan  and  recorded  a  partial  settlement  charge  under  compensation  and
benefits  in  the  Consolidated  Statements  of  Income.  See  Note  10,
“Retirement  Plans,”  to  the  consolidated  financial  statements  for  further
discussion.

F-43

 
 
Revenues - divested businesses
Expenses:
Amortization expense of acquired
intangible assets
Merger and strategic initiatives
expense
Restructuring charges
Lease asset impairments
Legal and regulatory matters
Extinguishment of debt
Pension Settlement
Expenses - divested businesses
Other
Total expenses

Operating loss

$

Year Ended December 31,

2023

2022

(in millions)

2021

$

39  $

48  $

77 

206 

153 

148 
80 
25 
12 
— 
9 
21 
7 
508 
(469) $

82 
15 
— 
26 
16 
— 
27 
5 
324 
(276) $

170 

87 
31 
— 
44 
33 
— 
38 
(2)
401 
(324)

For  further  discussion  of  our  segments’  results,  see  “Segment  Operating
Results,”  of  “Part  II,  Item  7.  Management’s  Discussion  and  Analysis  of
Financial Condition and Results of Operations.”

Geographic Data

The  following  table  presents  total  revenues  and  property  and  equipment,  net
by  geographic  area  for  2023,  2022  and  2021.  Revenues  are  classified  based
upon  the  location  of  the  customer.  Property  and  equipment  information  is
based on the physical location of the assets.

Total
Revenues

Property and
Equipment, Net

2023:
United States
All other countries

Total

2022:
United States
All other countries

Total

2021:
United States
All other countries

Total

$

$

$

$

$

$

 (in millions)

4,870  $
1,194 
6,064  $

5,100  $
1,126 
6,226  $

4,822  $
1,064 
5,886  $

367 
209 
576 

344 
188 
532 

325 
184 
509 

Property  and  equipment,  net  for  all  other  countries  primarily  includes  assets
held  in  Sweden.  No  single  customer  accounted  for  10.0%  or  more  of  our
revenues in 2023, 2022 and 2021.

20. RESTRUCTURING CHARGES

In the fourth quarter of 2023, following the closing of the Adenza acquisition,
our  management  approved,  committed  to  and  initiated  a  restructuring
program, “Adenza Restructuring” to optimize our efficiencies as a combined
organization.  In  connection  with 
incur
approximately $80 million in pre-tax charges principally related to employee-
related costs, contract terminations, real estate impairments and other related
costs.  We  expect  to  achieve  benefits  primarily  in  the  form  of  expense  and
revenue  synergies.  Costs  related  to  the  2023  Adenza  Restructuring  program
will  be  recorded  as  restructuring  charges  in  the  Consolidated  Statements  of
Income.

this  program,  we  expect 

to 

In October 2022, following our September 2022 announcement to realign our
segments  and  leadership,  we  initiated  a  divisional  alignment  program  with  a
focus  on  realizing  the  full  potential  of  this  structure.  In  connection  with  the
program, we expect to incur $115 million to $145 million in pre-tax charges
principally  related  to  employee-related  costs,  consulting,  asset  impairments
and  contract  terminations  over  a  two-year  period.  Costs  related  to  the
divisional alignment program will be recorded as restructuring charges in the
Consolidated Statements of Income.

In September 2019, we initiated the transition of certain technology platforms
to  advance  the  Company’s  strategic  opportunities  as  a  technology  and
analytics  provider  and  continue  the  realignment  of  certain  business  areas.  In
connection with these restructuring efforts, we retired certain elements of our
market  infrastructure  and  technology  product  offerings  as  we  implemented
Nasdaq Financial Framework and other technologies internally and externally.
This represented a fundamental shift in our strategy and technology as well as
executive  realignment.  In  June  2021,  we  completed  our  2019  restructuring
plan  and  recognized  total  pre-tax  charges  of  $118  million  over  a  two-year
period. Total pre-tax charges related primarily to non-cash items such as asset
impairments  and  accelerated  depreciation,  and  third-party  consulting  costs.
Severance and employee-related charges were also incurred.

F-44

 
 
 
 
 
 
 
The  following  table  presents  a  summary  of  the  2023  Adenza  restructuring
program,  our  2022  divisional  alignment  program  and  our  2019  restructuring
plan charges for the years ended December 31, 2023, 2022 and 2021 as well
as total program costs incurred since the inception date of each program.

Year Ended December 31,

2023

2022

2021

(in millions)

Asset impairment charges
Divisional realignment
2019 program
Consulting services

Adenza restructuring
Divisional realignment
2019 program
Employee-related costs

Adenza restructuring
Divisional realignment
2019 program

Other

Adenza restructuring
Divisional realignment
2019 program

Total restructuring charges

Total Program Costs Incurred
Adenza restructuring
Divisional realignment
2019 program

8  $

— 

— 
3 
— 

— 
3 
— 
— 
— 
1 
— 
15  $

— 
4 

— 
— 
19 
— 
— 
— 
1 
— 
— 
— 
7 
31 

$

12  $
— 

3 
34 
— 

6 
13 
— 
— 
1 
11 
— 
80  $

10 
85 
118 

$

$
$
$

F-45

DESCRIPTION OF THE REGISTRANT’S SECURITIES
REGISTERED PURSUANT TO SECTION 12 OF THE
SECURITIES EXCHANGE ACT OF 1934

Exhibit 4.21

Nasdaq, Inc. (the “Company”) has five classes of securities registered under Section 12 of the Securities Exchange Act of 1934,

as amended (the “Exchange Act”):

(1) Common Stock, par value $0.01 per share (“Common Stock”);

(2) 4.500% Senior Notes due 2032;

(3) 0.900% Senior Notes due 2033;

(4) 0.875% Senior Notes due 2030; and

(5) 1.75% Senior Notes due 2029.

As used in this summary, the terms “Nasdaq,” “the Company,” “we,” “our,” and “us” refer solely to Nasdaq, Inc. and not its

subsidiaries, unless otherwise specified.

Description of Common Stock

The following is a description of the material terms and provisions relating to our common stock. Because it is a summary, the
following  description  is  not  complete  and  is  subject  to  and  qualified  in  its  entirety  by  reference  to  our  Amended  and  Restated
Certificate of Incorporation, as amended, or Certificate, our By-Laws, each of which is incorporated by reference as an exhibit to the
Annual Report on Form 10-K, and provisions of Delaware law, which define the rights of our stockholders.

As of December 31, 2023, 900,000,000 shares of our common stock were authorized.

The holders of our common stock are entitled to one vote per share on all matters to be voted upon by the stockholders except
that no person may exercise voting rights in respect of any shares in excess of 5% of the then outstanding shares of our Common Stock.
Subject  to  certain  additional  conditions,  this  limitation  does  not  apply  to  persons  exempted  from  this  limitation  by  our  Board  of
Directors prior to the time such person owns more than 5.0% of the then-outstanding shares of our common stock.

At any meeting of our stockholders, a majority of the votes entitled to be cast will constitute a quorum for such meeting.

Holders of common stock are entitled to receive ratably such dividends, if any, as may be declared from time to time by our
board of directors out of funds legally available for them. In the event of our liquidation, dissolution, or winding-up, the holders of our
common  stock  are  entitled  to  share  ratably  in  all  assets  remaining  after  payment  of  liabilities,  subject  to  prior  distribution  rights  of
preferred stock, if any, then outstanding. Our common stock has no preemptive or conversion rights or other subscription rights. There
are no redemption or sinking fund provisions applicable to our common stock. All outstanding shares of common stock are fully paid
and non-assessable. Future dividends, if any, will be determined by our board of directors.

Certain Provisions of our Certificate and By-Laws

Some  provisions  of  our  Certificate  and  By-Laws,  which  provisions  are  summarized  below,  may  be  deemed  to  have  an  anti-
takeover effect and may delay, defer, or prevent a tender offer or takeover attempt that a stockholder might consider in its best interest,
including those attempts that might result in a premium over the market price for the shares held by stockholders.

Advance Notice Requirements for Stockholder Proposals and Directors Nominations

Our  by-laws  provide  that  stockholders  seeking  to  bring  business  before  an  annual  meeting  of  stockholders,  or  to  nominate
candidates  for  election  as  directors  at  an  annual  meeting  of  stockholders,  must  provide  timely  notice  in  writing.  To  be  timely,  a
stockholder’s notice must be delivered to or mailed and received at our principal executive offices not less than 90 nor more than 120
days  prior  to  the  anniversary  date  of  the  immediately  preceding  annual  meeting  of  stockholders;  provided,  that  in  the  event  that  the
annual meeting is called for a date that is not within 30 days before or 70 days after such anniversary date, notice by the stockholder in
order to be timely must be received not earlier than 120 days prior to the meeting and not later than the later of 90 days prior to the
meeting  and  the  close  of  business  on  the  10th  day  following  the  date  on  which  notice  of  the  date  of  the  annual  meeting  was  first
publicly announced by Nasdaq. In the case of a special meeting of stockholders called for the purpose of electing directors, notice by
the stockholder in order to be timely must be received not earlier than 120 days prior to the meeting and not later than the later of 90
days prior to the meeting or the close of business on the 10th day following the day on which public disclosure of the date of the special
meeting  and  our  nominees  was  first  made.  In  addition,  our  by-laws  specify  certain  requirements  as  to  the  form  and  content  of  a
stockholder’s notice. These provisions may preclude stockholders from bringing

matters  before  an  annual  meeting  of  stockholders  or  from  making  nominations  for  directors  at  an  annual  or  special  meeting  of
stockholders.

Proxy Access

Our  by-laws  include  a  proxy  access  provision  that  permits  a  stockholder,  or  a  group  of  stockholders,  owning  at  least  three
percent of our outstanding shares of common stock continuously for at least three years to nominate and include in the proxy materials
for an annual meeting of stockholders director nominees constituting up to the greater of two individuals and 25% of the total number
of directors then in office, provided that the stockholder(s) and nominee(s) satisfy the requirements specified in the by-laws.
Stockholder Action

Our Certificate provides that stockholders are not entitled to act by written consent in lieu of a meeting.

Right to Call Special Meeting

Our by-laws provide that stockholders representing 15% or more of our outstanding shares can convene a special meeting of

stockholders.

Amendments; Vote Requirements

The General Corporation Law of the State of Delaware provides generally that the affirmative vote of a majority of the shares
entitled  to  vote  on  any  matter  is  required  to  amend  a  corporation’s  certificate  of  incorporation,  unless  a  corporation’s  certificate  of
incorporation  requires  a  greater  percentage.  Our  Certificate  imposes  majority  voting  requirements  in  connection  with  stockholder
amendments to the by-laws and in connection with the amendment of certain provisions of the Certificate, including those provisions of
the Certificate relating to the limitations on voting rights of certain persons, removal of directors and prohibitions on stockholder action
by written consent.

Authorized But Unissued Shares

The authorized but unissued shares of our common stock will be available for future issuance without stockholder approval in
most cases. These additional shares may be utilized for a variety of corporate purposes, including future public or private offerings to
raise  additional  capital,  corporate  acquisitions  and  employee  benefit  plans.  The  existence  of  authorized  but  unissued  shares  of  our
common stock could render more difficult, or discourage, an attempt to obtain control of us by means of a proxy contest, tender offer,
merger or otherwise.

 
Delaware Business Combination Statute

We  are  organized  under  Delaware  law.  Delaware  law  generally  prohibits  a  publicly-held  or  widely-held  corporation  from
engaging  in  a  “business  combination”  with  an  “interested  stockholder”  for  three  years  after  the  stockholder  becomes  an  interested
stockholder. An “interested stockholder” is a person who, together with affiliates and associates, owns (or, in some cases, within three
years, did own) directly or indirectly 15% or more of the corporation’s outstanding voting stock. A “business combination” includes a
merger, asset sale or other transaction that results in a financial benefit to the interested stockholder. However, Delaware law does not
prohibit these business combinations if:

1. before the stockholder becomes an interested stockholder, the corporation’s board approved either the business combination or

the transaction that resulted in the stockholder becoming an interested stockholder;

2. after the transaction that results in the stockholder becoming an interested stockholder, the interested stockholder owns at least

85% of the corporation’s outstanding voting stock (excluding certain shares); or

3.

the corporation’s board approves the business combination and the holders of at least two-thirds of the corporation’s outstanding
voting stock that the interested stockholder does not own authorize the business combination at a meeting of stockholders.

Stockholders’ Agreements

Investor AB

On  December  14,  2022,  we  entered  into  an  amendment  to  our  stockholders’  agreement  with  Investor  AB  (the  “Amended
Stockholders’ Agreement”), amending the original stockholders’ agreement that was entered into between Nasdaq and Investor AB on
December 16, 2010.

The  Amended  Stockholders’  Agreement  reinstated  Investor  AB’s  right  to  propose  for  nomination  one  person,  reasonably
acceptable  to  our  Nominating  &  ESG  Committee,  for  election  to  our  Board  of  Directors  so  long  as  Investor  AB  continues  to
beneficially  own  at  least  10%  of  the  outstanding  common  stock  of  Nasdaq.  We  are  obligated  by  the  terms  of  the  Amended
Stockholders’ Agreement to (i) include the Investor AB designee as a nominee to the Board of Directors on each slate of nominees for
election to the Board of Directors proposed by management of Nasdaq, (ii) recommend the election of the Investor AB designee to our

stockholders and (iii) otherwise use our reasonable best efforts (which shall include the solicitation of proxies) to cause the Investor AB
designee to be elected to the Board of Directors.

The  foregoing  summary  of  the  Amended  Stockholders’  Agreement  does  not  purport  to  be  complete  and  is  subject  to,  and
qualified in its entirety by, the full text of the Amended Stockholders’ Agreement, which was filed as Exhibit 4.1 to Nasdaq’s Current
Report on Form 8-K filed on December 16, 2022.

Thoma Bravo

In connection with our acquisition of Adenza Holdings, Inc. (“Adenza”) on November 1, 2023, we entered into a Stockholders’
Agreement with Adenza Parent, LP (“Seller”), and Thoma Bravo, LP (“Thoma Bravo” and together with Seller, the “Seller Parties”),
dated as of November 1, 2023 (the “Stockholders’ Agreement”), pursuant to which the Seller Parties agreed to be subject to a lock-
up with respect to the transfer of the shares of our common stock issued to the Seller on the closing of the acquisition, with 50% of such
shares released from the lock-up on the six-month anniversary of the closing of the acquisition and the remaining 50% of such shares
released from the lock-up on the 18-month anniversary of the closing of the acquisition (subject to certain exceptions).

The Stockholders’ Agreement further provides that the Seller Parties will be entitled to propose for nomination one director for
election to our Board of Directors (with the initial nominee to be Mr. Holden Spaht), and such right will exist for so long as the Seller
Parties and their controlled affiliates continue to beneficially own at least 10% of the shares of Nasdaq common stock outstanding as of
November 1, 2023.

In addition, the Seller Parties have agreed to be subject to a standstill obligation, including a restriction on acquiring shares in
excess of 19.99% of the outstanding Nasdaq common stock on a fully diluted basis, subject to certain exceptions, for at least two years
following the closing date.

The foregoing description of the Stockholders’ Agreement does not purport to be complete and is qualified in its entirety by the
full text of the Stockholders’ Agreement, which was filed as Exhibit 4.1 to Nasdaq’s Current Report on Form 8-K filed on November 3,
2023.

Transfer Agent and Registrar

The transfer agent and registrar for our common stock is Computershare. Its address is 480 Washington Boulevard, Jersey City,

New Jersey 07310 and its telephone number is (800) 736-3001.

Listing

Our common stock is listed on The Nasdaq Stock Market under the trading symbol “NDAQ.”

Description of the 4.500% Senior Notes due 2032

The 4.500% Senior Notes due 2032 (the “2032 Notes”)  were  issued  under  an  indenture,  dated  as  of  June  7,  2013  (the  “base
indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National Association, as trustee (the “Trustee”) and a nineteenth supplemental
indenture dated as of June 28, 2023 (the “supplemental indenture” and, together with the base indenture, the “indenture”) by and among
Nasdaq,  Computershare  Trust  Company,  N.A.,  as  trustee,  as  successor  to  Wells  Fargo  Bank,  (the  “Trustee”)  and  HSBC  Bank  USA,
National Association, as paying agent, registrar and transfer agent. The indenture is publicly available at www.sec.gov.

We issued €750 million aggregate principal amount of the 2032 Notes on June 28, 2023.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of the 2032 Notes and the indenture,

including definitions of certain terms used therein.

General

The 2032 Notes:

•

•

•

•

are senior unsecured obligations of ours;

rank  equally  in  right  of  payment  with  all  of  our  other  senior  unsecured  indebtedness  from  time  to  time  outstanding,
commercial paper issuances and indebtedness under our credit facility;

are  structurally  subordinated  in  right  of  payment  to  all  existing  and  future  obligations  of  our  subsidiaries,  including
claims with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured indebtedness and other secured
obligations to the extent of the value of the collateral securing any such indebtedness and other obligations.

The 2032 Notes were issued in minimum denominations of €100,000 and integral multiples of €1,000 in excess thereof.

Principal, Maturity and Interest

The 2032 Notes will bear interest at a rate of 4.500% per year. Interest on the Notes is payable annually in arrears on February

15 of each year, beginning on February 15, 2024, and

 
will be computed on the basis of the actual number of days in the period for which interest is being calculated and the actual number of
days from and including the last date on which interest was paid on the 2032 Notes (or the settlement date if no interest has been paid or
duly  provided  for  on  the  2032  Notes),  to  but  excluding  the  next  date  on  which  interest  is  paid  or  duly  provided  for.  This  payment
convention is referred to as ACTUAL/ACTUAL (ICMA) as defined in the rulebook of the International Capital Market Association.
Interest  on  the  2032  Notes  will  accrue  from  and  including  the  settlement  date  and  will  be  paid  to  holders  of  record  on  the  day
immediately prior to the applicable interest payment date.

The  2032  Notes  will  mature  on  February  15,  2032.  On  the  maturity  date  of  the  2032  Notes,  the  holders  will  be  entitled  to

receive 100% of the principal amount of such 2032 Notes. The 2032 Notes will not have the benefit of any sinking fund.

If any interest payment date, redemption date or maturity date falls on a day that is not a business day, then the relevant payment
may be made on the next succeeding business day and no interest will accrue because of such delayed payment. With respect to the
2032 Notes, when we use the term “business day” we mean any day except a Saturday, a Sunday or a day on which banking institutions
in the applicable place of payment are authorized or required by law, regulation or executive order to close.

Claims against the Company for payment of principal, interest and additional amounts, if any, on the 2032 Notes will become
void unless presentment for payment is made (where so required under the indenture) within, in the case of principal and additional
amounts, if any, a period of ten years or, in the case of interest, a period of five years, in each case from the applicable original date of
payment therefor.

Euro Notes—Issuance in Euros

Initial holders of the 2032 Notes paid for the 2032 Notes in euros, and principal, premium, if any, and interest payments and
additional amounts, if any, in respect of the 2032 Notes will be payable in euros. If, on or after the date of this prospectus supplement,
the euro is unavailable to us due to the imposition of exchange controls or other circumstances beyond our control or the euro is no
longer  used  by  the  then  member  states  of  the  European  Monetary  Union  that  have  adopted  the  euro  as  their  currency  or  for  the
settlement of transactions by public institutions within the international banking community, then all payments in respect of the 2032
Notes will be made in U.S. dollars until the euro is again available to us or so used.

The amount payable on any date in euros will be converted to U.S. dollars on the basis of the most recently available market
exchange rate for euros as determined by us in our sole discretion. Any payment in respect of the 2032 Notes so made in U.S. dollars
will not constitute

an event of default under the indenture or the 2032 Notes. Neither the trustee nor the paying agent will be responsible for obtaining
exchange rates, effecting conversions or otherwise handling redenominations.

Ranking

The  2032  Notes  are  general  unsecured  obligations  of  ours  and  will  rank  equally  with  all  of  our  existing  and  future

unsubordinated obligations.

Holders  of  any  secured  indebtedness  and  other  secured  obligations  of  the  Company  will  have  claims  that  are  prior  to  your
claims as holders of the 2032 Notes, to the extent of the value of the assets securing such indebtedness and other obligations, in the
event of any bankruptcy, liquidation or similar proceeding.

Further Issues

The 2032 Notes constituted a separate series of debt securities under the indenture, limited to €750 million. Under the indenture,
we may, without the consent of the holders of the 2032 Notes, issue additional 2032 Notes of the same or a different series from time to
time in the future in an unlimited aggregate principal amount; provided that if any such additional 2032 Notes are not fungible with the
2032 Notes offered hereby (or any other tranche of additional 2032 Notes) for U.S. federal income tax purposes, then such additional
2032  Notes  will  have  different  ISIN  and/or  Common  Code  numbers  than  the  Notes  offered  hereby  (and  any  such  other  tranche  of
additional 2032 Notes). The 2032 Notes and any additional 2032 Notes of the same series would rank equally and ratably and would be
treated as a single class for all purposes under the indenture. This means that, in circumstances where the indenture provides for the
holders of debt securities of any series to vote or take any action, any of the outstanding 2032 Notes, as well as any additional 2032
Notes that we may issue by reopening such series, will vote or take action as a single class.

Redemption

Optional Redemption

The  2032  Notes  will  be  redeemable,  in  whole  at  any  time  or  in  part  from  time  to  time,  at  our  option,  prior  to  December  15,
2031, at a redemption price (the “make-whole redemption price”) equal to the greater of (i) 100% of the principal amount of the 2032
Notes  and  (ii)  as  determined  by  the  Quotation  Agent  (as  defined  below),  the  sum  of  the  present  values  of  the  remaining  scheduled
payments of principal and interest on the 2032 Notes (exclusive of interest accrued and unpaid as of the date of redemption), discounted
to the date of redemption on an

annual basis (ACTUAL/ACTUAL (ICMA)) at the Bund Rate (as defined below), plus 35 basis points, plus accrued and unpaid interest
thereon to the date of redemption. However, if the redemption date is after a record date and on or prior to a corresponding interest
payment date, the interest will be paid on the redemption date to the holder of record on the record date.

Notwithstanding the foregoing, at any time on or after December 15, 2031 (three months before their maturity date), the 2032
Notes will be redeemable, in whole or in part, at our option and at any time or from time to time, at a redemption price equal to 100%
of  the  principal  amount  of  the  2032  Notes  to  be  redeemed  plus  accrued  and  unpaid  interest  thereon  to,  but  excluding,  the  date  of
redemption.

Notice  of  any  redemption  will  be  mailed  at  least  10  days,  but  not  more  than  60  days,  before  the  redemption  date  to  each
registered  holder  of  2032  Notes  to  be  redeemed.  Once  notice  of  redemption  is  mailed,  the  2032  Notes  called  for  redemption  will
become due and payable on the redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not
including, the redemption date. Unless we default in payment of the redemption price, on and after the redemption date, interest will
cease to accrue on the 2032 Notes (or portion thereof) to be redeemed on such redemption date.

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the annual equivalent yield to maturity of
the  Comparable  German  Bund  Issue,  assuming  a  price  for  the  Comparable  German  Bund  Issue  (expressed  as  a  percentage  of  its
principal amount) equal to the Comparable German Bund Price for such redemption date.

“Comparable  German  Bund  Issue”  means  that  German  Bundesanleihe  security  selected  by  the  Quotation  Agent  as  having  a
maturity comparable to the remaining term of the 2032 Notes to be redeemed that would be utilized, at the time of selection and in
accordance with customary
financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of the Notes.

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average of four Reference German Bund
Dealer Quotations for such redemption date, after excluding the highest and lowest such Reference German Bund Dealer Quotations or
(ii) if the Quotation Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such quotations.

“Quotation Agent” means a Reference German Bund Dealer appointed by us.

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities selected by us in good faith.

 
“Reference German Bund Dealer Quotations” means, with respect to each Reference German Bund Dealer and any redemption
date, the average, as determined by us, of the bid and asked prices for the Comparable German Bund Issue (expressed in each case as a
percentage  of  its  principal  amount)  quoted  in  writing  to  the  Quotation  Agent  by  such  Reference  German  Bund  Dealer  at  3:30  p.m.,
Frankfurt, Germany time, on the third business day preceding such redemption date.

If we elect to redeem less than all of the 2032 Notes, and such 2032 Notes are at the time represented by a global note, then the
depositary will select by lot the particular interests to be redeemed. If we elect to redeem less than all of the 2032 Notes, and any of
such 2032 Notes are not represented by a global note, then the trustee will select the particular 2032 Notes to be redeemed in a manner
it deems appropriate and fair (and the depositary will select by lot the particular interests in any global note to be redeemed).

We may at any time, and from time to time, purchase the 2032 Notes at any price or prices in the open market or otherwise.

Repurchase upon Change of Control Triggering Event

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2032 Notes, unless we have exercised our
right  to  redeem  the  2032  Notes,  we  will  be  required  to  make  an  offer  to  repurchase  all  or,  at  the  holder’s  option,  any  part  (equal  to
€100,000 or any integral multiple of €1,000 in excess thereof) of each holder’s 2032 Notes pursuant to the offer described below (the
“Change of Control Offer”).

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% of the aggregate principal amount of
2032  Notes  repurchased  plus  accrued  and  unpaid  interest,  if  any,  on  the  2032  Notes  repurchased  to,  but  not  including,  the  date  of
purchase (the “Change of Control Payment”).

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect sale, transfer, conveyance or other
disposition (other than by way of merger or consolidation), in one or a series of related transactions, of all or substantially all of the
assets  of  us  and  our  Subsidiaries  taken  as  a  whole  to  any  Person  or  group  of  related  Persons  for  purposes  of  Section  13(d)  of  the
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders of our common stock of any plan or
proposal for our liquidation or dissolution; (3) the consummation of any transaction (including, without limitation, any merger

or consolidation) the result of which is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50%
of the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority of the members of our board of
directors are not Continuing Directors.

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of Control if (1) we become a direct or
indirect wholly owned subsidiary of a holding company and (2)(A) the direct or indirect holders of the Voting Stock of such holding
company immediately following that transaction are substantially the same as the holders of our Voting Stock immediately prior to that
transaction  or  (B)  immediately  following  that  transaction  no  Person  or  Group  (other  than  a  holding  company  satisfying  the
requirements  of  this  sentence)  is  the  beneficial  owner,  directly  or  indirectly  of  more  than  50%  of  the  Voting  Stock  of  such  holding
company.

“Change of Control Triggering Event” means the occurrence of both a Change of Control and a Below Investment Grade Rating

Event (as such term is defined in the indenture) occurring in respect of that Change of Control.

“Continuing Directors” means, as of any date of determination, any member of our board of directors who (1) was a member of
our board of directors on the date of the issuance of the 2032 Notes; or (2) was nominated or approved for election, elected or appointed
to our board of directors with the approval of a majority of the Continuing Directors who were members of our board of directors at the
time of such nomination, approval, election or appointment (either by a specific vote or by approval of the proxy statement issued by us
in which such member was named as a nominee for election as a director).

“Person”  means  any  individual,  firm,  limited  liability  company,  corporation,  partnership,  association,  joint  venture,  tribunal,
trust,  government  or  political  subdivision  or  agency  or  instrumentality  thereof,  or  any  other  entity  or  organization  and  includes  a
“person” as used in Section 13(d)(3) of the Exchange Act.

      “Voting Stock” of any specified Person as of any date means the capital stock of such Person that is at the time entitled to vote
generally in the election of the board of directors of such Person.

The definition of “Change of Control” includes a phrase relating to the sale, transfer, conveyance or other disposition of “all or
substantially all” of our consolidated assets. There is no precise, established definition of the phrase “substantially all” under applicable
law. Accordingly, your ability to require us to purchase your 2032 Notes as a result of the sale, transfer, conveyance or other disposition
of less than all of our assets may be uncertain.

Certain Covenants

The indenture contains, among others, restrictive covenants regarding (i) our ability to consolidate or merge with another entity
or  to  sell,  transfer  or  otherwise  convey  all  or  substantially  all  of  our  assets  to  another  entity,  (ii)  create  or  permit  certain  significant
subsidiaries to create or permit to exist certain liens and (iii) certain sale and lease-back transactions involving certain subsidiaries.

Events of Default

Holders  of  the  2032  Notes  will  have  specified  rights  if  an  Event  of  Default  (as  defined  below)  occurs.  The  term  “Event  of

Default” in respect of the 2032 Notes means any of the following:

(1)

(2)

(3)

(4)

we do not pay interest on any of the 2032 Notes within 30 days of its due date;

we fail to pay the principal (or premium, if any) of any 2033 Note, when such principal becomes due and payable, at

maturity, upon acceleration, upon redemption or otherwise;

we fail to comply with certain covenants under the indenture;

we  remain  in  breach  of  a  covenant  or  warranty  in  respect  of  the  indenture  or  2032  Notes  (other  than  a  covenant
included in the indenture solely for the benefit of debt securities of another series) for 90 days after we receive a written

notice of default, which notice must be sent by either the trustee or holders of at least 25% in principal amount of the
outstanding 2032 Notes;

(5)

we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization specified in the indenture;

(6)

(7)

we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an  aggregate  amount  of  at  least
$200,000,000,  constituting  a  default  either  of  payment  of  principal  when  due  and  payable  or  which  results  in

acceleration  of  the  indebtedness  unless  the  default  has  been  cured  or  waived  or  the  indebtedness  discharged  in  full
within 60 days after we have been notified of the default by the trustee or holders of at least 25% of the outstanding
2032 Notes; or

one  or  more  final  judgments  for  the  payment  of  money  in  an  aggregate  amount  in  excess  of  $200,000,000  above
available insurance or indemnity coverage shall be rendered against us or any significant subsidiary and the same shall
remain undischarged for a period of 60 consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect to the 2032 Notes has occurred, the
trustee or the holders of at least 25% in principal amount of the 2032 Notes may declare the entire unpaid principal amount of (and
premium,  if  any),  and  all  the  accrued  interest  on,  the  Notes  to  be  due  and  immediately  payable.  This  is  called  a  declaration  of
acceleration of maturity. There is no action on the part of the trustee or any holder of the 2032 Notes required for such declaration if the
Event  of  Default  is  the  Company’s  bankruptcy,  insolvency  or  reorganization.  Holders  of  a  majority  in  principal  amount  of  the  2032
Notes may also waive certain past defaults under the indenture with respect to the 2032 Notes on behalf of all of the holders of the 2032
Notes. A declaration of acceleration of maturity may be canceled, under specified circumstances, by the holders of at least a majority in
principal amount of the 2032 Notes and the trustee.

Except in cases of default, where the trustee has special duties, the trustee is not required to take any action under the indenture at the
request of holders unless the holders offer the trustee protection from expenses and liability satisfactory to the trustee. If an indemnity
satisfactory to the trustee is provided, the holders of a majority in principal amount of 2032 Notes may direct the time, method and
place  of  conducting  any  lawsuit  or  other  formal  legal  action  seeking  any  remedy  available  to  the  trustee.  The  trustee  may  refuse  to
follow those directions in certain circumstances specified in the indenture. No delay or omission in exercising any right or remedy will
be treated as a waiver of the right, remedy or Event of Default.

Modification of the Indenture and Waiver of Rights of Holders

    
Under certain circumstances, we can make changes to the indenture and the 2032 Notes. Some types of changes require the approval of
each holder of 2032 Notes, some require approval by a vote of a majority of the holders of the 2032 Notes, and some changes do not
require any approval at all.
Description of the 0.900% Senior Notes Due 2033

The 0.900% Senior Notes due 2033 (the “2033 Notes”)  were  issued  under  an  indenture,  dated  as  of  June  7,  2013  (the  “base
indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National Association, as trustee (the “Trustee”) and a twelfth supplemental
indenture dated as of July 30, 2021 (the “supplemental indenture” and, together with the base indenture, the “indenture”) by and among
Nasdaq, the Trustee and HSBC Bank USA, National Association, as registrar and transfer agent. The indenture is publicly available at
www.sec.gov.

We issued €615 million aggregate principal amount of the 2033 Notes on July 30, 2021.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of the 2033 Notes and the indenture,

including definitions of certain terms used therein.

General

The 2033 Notes:

•

•

•

•

are senior unsecured obligations of ours;

rank  equally  in  right  of  payment  with  all  of  our  other  senior  unsecured  indebtedness  from  time  to  time  outstanding,
commercial paper issuances and indebtedness under our credit facility;

are  structurally  subordinated  in  right  of  payment  to  all  existing  and  future  obligations  of  our  subsidiaries,  including
claims with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured indebtedness and other secured
obligations to the extent of the value of the collateral securing any such indebtedness and other obligations.

The 2033 Notes were issued in minimum denominations of €100,000 and integral multiples of €1,000 in excess thereof.

 
Principal, Maturity and Interest

The 2033 Notes will bear interest at a rate of 0.900% per year. Interest on the Notes is payable annually in arrears on July 30 of
each year, beginning on July 30, 2022, and will be computed on the basis of the actual number of days in the period for which interest is
being calculated and the actual number of days from and including the last date on which interest was paid on the 2033 Notes (or the
settlement date if no interest has been paid or duly provided for on the 2033 Notes), to but excluding the next date on which interest is
paid or duly provided  for.  This  payment  convention  is  referred  to  as  ACTUAL/ACTUAL (ICMA) as defined in the rulebook of the
International Capital Market Association. Interest on the 2033 Notes will accrue from and including the settlement date and will be paid
to holders of record on the day immediately prior to the applicable interest payment date.

The 2033 Notes will mature on July 30, 2033. On the maturity date of the 2033 Notes, the holders will be entitled to receive

100% of the principal amount of such 2033 Notes. The 2033 Notes will not have the benefit of any sinking fund.

If any interest payment date, redemption date or maturity date falls on a day that is not a business day, then the relevant payment
may be made on the next succeeding business day and no interest will accrue because of such delayed payment. With respect to the
2033 Notes, when we use the term “business day” we mean any day except a Saturday, a Sunday or a day on which banking institutions
in the applicable place of payment are authorized or required by law, regulation or executive order to close.

Claims against the Company for payment of principal, interest and additional amounts, if any, on the 2033 Notes will become
void unless presentment for payment is made (where so required under the indenture) within, in the case of principal and additional
amounts, if any, a period of ten years or, in the case of interest, a period of five years, in each case from the applicable original date of
payment therefor.

Euro Notes—Issuance in Euros

Initial holders of the 2033 Notes paid for the 2033 Notes in euros, and principal, premium, if any, and interest payments and
additional amounts, if any, in respect of the 2033 Notes will be payable in euros. If, on or after the date of this prospectus supplement,
the euro is unavailable to us due to the imposition of exchange controls or other circumstances beyond our control or the euro is no
longer  used  by  the  then  member  states  of  the  European  Monetary  Union  that  have  adopted  the  euro  as  their  currency  or  for  the
settlement of transactions by public institutions within the international banking community, then all payments in respect of the 2033
Notes will be made in U.S. dollars until the euro is again available to us or so used.

The amount payable on any date in euros will be converted to U.S. dollars on the basis of the most recently available market
exchange rate for euros as determined by us in our sole discretion. Any payment in respect of the 2033 Notes so made in U.S. dollars
will not constitute an event of default under the indenture or the 2033 Notes. Neither the trustee nor the paying agent will be responsible
for obtaining exchange rates, effecting conversions or otherwise handling redenominations.

Ranking

The  2033  Notes  are  general  unsecured  obligations  of  ours  and  will  rank  equally  with  all  of  our  existing  and  future

unsubordinated obligations.

Holders  of  any  secured  indebtedness  and  other  secured  obligations  of  the  Company  will  have  claims  that  are  prior  to  your
claims as holders of the 2033 Notes, to the extent of the value of the assets securing such indebtedness and other obligations, in the
event of any bankruptcy, liquidation or similar proceeding.

Further Issues

The 2033 Notes constituted a separate series of debt securities under the indenture, limited to €615 million. Under the indenture,
we may, without the consent of the holders of the 2033 Notes, issue additional 2033 Notes of the same or a different series from time to
time in the future in an unlimited aggregate principal amount; provided that if any such additional 2033 Notes are not fungible with the
2033 Notes offered hereby (or any other tranche of additional 2033 Notes) for U.S. federal income tax purposes, then such additional
2033  Notes  will  have  different  ISIN  and/or  Common  Code  numbers  than  the  Notes  offered  hereby  (and  any  such  other  tranche  of
additional 2033 Notes). The 2033 Notes and any additional 2033 Notes of the same series would rank equally and ratably and would be
treated as a single class for all purposes under the indenture. This means that, in circumstances where the indenture provides for the
holders of debt securities of any series to vote or take any action, any of the outstanding 2033 Notes, as well as any additional 2033
Notes that we may issue by reopening such series, will vote or take action as a single class.

Redemption

Optional Redemption

The 2033 Notes will be redeemable, in whole at any time or in part from time to time, at our option, prior to April 30, 2033, at a

redemption price (the “make-whole redemption price”)

equal to the greater of (i) 100% of the principal amount of the 2033 Notes and (ii) as determined by the Quotation Agent (as defined
below), the sum of the present values of the remaining scheduled payments of principal and interest on the 2033 Notes (exclusive of
interest accrued and unpaid as of the date of redemption), discounted to the date of redemption on an annual basis (ACTUAL/ACTUAL
(ICMA)) at the Bund Rate (as defined below), plus 20 basis points, plus accrued and unpaid interest thereon to the date of redemption.
However, if the redemption date is after a record date and on or prior to a corresponding interest payment date, the interest will be paid
on the redemption date to the holder of record on the record date.

Notwithstanding the foregoing, at any time on or after April 30, 2033 (three months before their maturity date), the 2033 Notes
will be redeemable, in whole or in part, at our option and at any time or from time to time, at a redemption price equal to 100% of the
principal amount of the 2033 Notes to be redeemed plus accrued and unpaid interest thereon to, but excluding, the date of redemption.

Notice  of  any  redemption  will  be  mailed  at  least  10  days,  but  not  more  than  60  days,  before  the  redemption  date  to  each
registered  holder  of  2033  Notes  to  be  redeemed.  Once  notice  of  redemption  is  mailed,  the  2033  Notes  called  for  redemption  will
become due and payable on the redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not
including, the redemption date. Unless we default in payment of the redemption price, on and after the redemption date, interest will
cease to accrue on the 2033 Notes (or portion thereof) to be redeemed on such redemption date.

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the annual equivalent yield to maturity of
the  Comparable  German  Bund  Issue,  assuming  a  price  for  the  Comparable  German  Bund  Issue  (expressed  as  a  percentage  of  its
principal amount) equal to the Comparable German Bund Price for such redemption date.

“Comparable  German  Bund  Issue”  means  that  German  Bundesanleihe  security  selected  by  the  Quotation  Agent  as  having  a
maturity comparable to the remaining term of the 2033 Notes to be redeemed that would be utilized, at the time of selection and in
accordance with customary
financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of the Notes.

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average of four Reference German Bund
Dealer Quotations for such redemption date, after excluding the highest and lowest such Reference German Bund Dealer Quotations or
(ii) if the Quotation Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such quotations.

 
“Quotation Agent” means a Reference German Bund Dealer appointed by us.

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities selected by us in good faith.

“Reference German Bund Dealer Quotations” means, with respect to each Reference German Bund Dealer and any redemption
date, the average, as determined by us, of the bid and asked prices for the Comparable German Bund Issue (expressed in each case as a
percentage  of  its  principal  amount)  quoted  in  writing  to  the  Quotation  Agent  by  such  Reference  German  Bund  Dealer  at  3:30  p.m.,
Frankfurt, Germany time, on the third business day preceding such redemption date.

If we elect to redeem less than all of the 2033 Notes, and such 2033 Notes are at the time represented by a global note, then the
depositary will select by lot the particular interests to be redeemed. If we elect to redeem less than all of the 2033 Notes, and any of
such 2033 Notes are not represented by a global note, then the trustee will select the particular 2033 Notes to be redeemed in a manner
it deems appropriate and fair (and the depositary will select by lot the particular interests in any global note to be redeemed).

We may at any time, and from time to time, purchase the 2033 Notes at any price or prices in the open market or otherwise.

Repurchase upon Change of Control Triggering Event

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2033 Notes, unless we have exercised our
right  to  redeem  the  2033  Notes,  we  will  be  required  to  make  an  offer  to  repurchase  all  or,  at  the  holder’s  option,  any  part  (equal  to
€100,000 or any integral multiple of €1,000 in excess thereof) of each holder’s 2033 Notes pursuant to the offer described below (the
“Change of Control Offer”).

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% of the aggregate principal amount of
2033  Notes  repurchased  plus  accrued  and  unpaid  interest,  if  any,  on  the  2033  Notes  repurchased  to,  but  not  including,  the  date  of
purchase (the “Change of Control Payment”).

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect sale, transfer, conveyance or other
disposition (other than by way of merger or consolidation), in one or a series of related transactions, of all or substantially all of the
assets  of  us  and  our  Subsidiaries  taken  as  a  whole  to  any  Person  or  group  of  related  Persons  for  purposes  of  Section  13(d)  of  the
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders of our common stock of any plan or
proposal  for  our  liquidation  or  dissolution;  (3)  the  consummation  of  any  transaction  (including,  without  limitation,  any  merger  or
consolidation) the result of which is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50% of
the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority of the members of our board of
directors are not Continuing Directors.

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of Control if (1) we become a direct or
indirect wholly owned subsidiary of a holding company and (2)(A) the direct or indirect holders of the Voting Stock of such holding
company immediately following that transaction are substantially the same as the holders of our Voting Stock immediately prior to that
transaction  or  (B)  immediately  following  that  transaction  no  Person  or  Group  (other  than  a  holding  company  satisfying  the
requirements  of  this  sentence)  is  the  beneficial  owner,  directly  or  indirectly  of  more  than  50%  of  the  Voting  Stock  of  such  holding
company.

“Change of Control Triggering Event” means the occurrence of both a Change of Control and a Below Investment Grade Rating

Event (as such term is defined in the indenture) occurring in respect of that Change of Control.

“Continuing Directors” means, as of any date of determination, any member of our board of directors who (1) was a member of
our board of directors on the date of the issuance of the 2033 Notes; or (2) was nominated or approved for election, elected or appointed
to our board of directors with the approval of a majority of the Continuing Directors who were members of our board of directors at the
time of such nomination, approval, election or appointment (either by a specific vote or by approval of the proxy statement issued by us
in which such member was named as a nominee for election as a director).

“Person”  means  any  individual,  firm,  limited  liability  company,  corporation,  partnership,  association,  joint  venture,  tribunal,
trust,  government  or  political  subdivision  or  agency  or  instrumentality  thereof,  or  any  other  entity  or  organization  and  includes  a
“person” as used in Section 13(d)(3) of the Exchange Act.

      “Voting Stock” of any specified Person as of any date means the capital stock of such Person that is at the time entitled to vote
generally in the election of the board of directors of such Person.

The definition of “Change of Control” includes a phrase relating to the sale, transfer, conveyance or other disposition of “all or
substantially all” of our consolidated assets. There is no precise, established definition of the phrase “substantially all” under applicable
law. Accordingly, your ability to require us to purchase your 2033 Notes as a result of the sale, transfer, conveyance or other disposition
of less than all of our assets may be uncertain.

Certain Covenants

The indenture contains, among others, restrictive covenants regarding (i) our ability to consolidate or merge with another entity
or  to  sell,  transfer  or  otherwise  convey  all  or  substantially  all  of  our  assets  to  another  entity,  (ii)  create  or  permit  certain  significant
subsidiaries to create or permit to exist certain liens and (iii) certain sale and lease-back transactions involving certain subsidiaries.

Events of Default

Holders  of  the  2033  Notes  will  have  specified  rights  if  an  Event  of  Default  (as  defined  below)  occurs.  The  term  “Event  of

Default” in respect of the 2033 Notes means any of the following:

(1)

(2)

we do not pay interest on any of the 2033 Notes within 30 days of its due date;

we fail to pay the principal (or premium, if any) of any 2033 Note, when such principal becomes due and payable, at

maturity, upon acceleration, upon redemption or otherwise;

(3)

we fail to comply with certain covenants under the indenture;

(4)

(5)

(6)

(7)

we  remain  in  breach  of  a  covenant  or  warranty  in  respect  of  the  indenture  or  2033  Notes  (other  than  a  covenant
included in the indenture solely for the benefit of debt securities of another series) for 90 days after we receive a written
notice of default, which notice must be sent by either the trustee or holders of at least 25% in principal amount of the
outstanding 2033 Notes;

we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization specified in the indenture;

we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an  aggregate  amount  of  at  least
$200,000,000,  constituting  a  default  either  of  payment  of  principal  when  due  and  payable  or  which  results  in

acceleration  of  the  indebtedness  unless  the  default  has  been  cured  or  waived  or  the  indebtedness  discharged  in  full
within 60 days after we have been notified of the default by the trustee or holders of at least 25% of the outstanding
2033 Notes; or

one  or  more  final  judgments  for  the  payment  of  money  in  an  aggregate  amount  in  excess  of  $200,000,000  above
available insurance or indemnity coverage shall be rendered against us or any significant subsidiary and the same shall
remain undischarged for a period of 60 consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect to the 2033 Notes has occurred, the
trustee or the holders of at least 25% in principal amount of the 2033 Notes may declare the entire unpaid principal amount of (and
premium,  if  any),  and  all  the  accrued  interest  on,  the  Notes  to  be  due  and  immediately  payable.  This  is  called  a  declaration  of
acceleration of maturity. There is no action on the part of the trustee or any holder of the 2033 Notes required for such declaration if the
Event  of  Default  is  the  Company’s  bankruptcy,  insolvency  or  reorganization.  Holders  of  a  majority  in  principal  amount  of  the  2033
Notes may also waive certain past defaults under the indenture with respect to the 2033 Notes on behalf of all of the holders of the 2033
Notes. A declaration of acceleration of maturity may be canceled,

    
under specified circumstances, by the holders of at least a majority in principal amount of the 2033 Notes and the trustee.

Except in cases of default, where the trustee has special duties, the trustee is not required to take any action under the indenture at the
request of holders unless the holders offer the trustee protection from expenses and liability satisfactory to the trustee. If an indemnity
satisfactory to the trustee is provided, the holders of a majority in principal amount of 2033 Notes may direct the time, method and
place  of  conducting  any  lawsuit  or  other  formal  legal  action  seeking  any  remedy  available  to  the  trustee.  The  trustee  may  refuse  to
follow those directions in certain circumstances specified in the indenture. No delay or omission in exercising any right or remedy will
be treated as a waiver of the right, remedy or Event of Default.

Modification of the Indenture and Waiver of Rights of Holders

Under certain circumstances, we can make changes to the indenture and the 2033 Notes. Some types of changes require the approval of
each holder of 2033 Notes, some require approval by a vote of a majority of the holders of the 2033 Notes, and some changes do not
require any approval at all.
Description of the 0.875% Senior Notes Due 2030

The 0.875% Senior Notes due 2030 (the “2030 Notes”)  were  issued  under  an  indenture,  dated  as  of  June  7,  2013  (the  “base
indenture”) between Nasdaq, Inc. and Wells Fargo Bank, National Association, as trustee (the “Trustee”) and a seventh supplemental
indenture  dated  as  of  February  13,  2020  (the  “supplemental indenture”  and,  together  with  the  base  indenture,  the  “indenture”).  The
indenture is publicly available at www.sec.gov.

We issued €600 million aggregate principal amount of the 2030 Notes on February 13, 2020.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of the 2030 Notes and the indenture,

including definitions of certain terms used therein.

General

The 2030 Notes:

•

are senior unsecured obligations of ours;

•

•

•

rank  equally  in  right  of  payment  with  all  of  our  other  senior  unsecured  indebtedness  from  time  to  time  outstanding,
commercial paper issuances and indebtedness under our credit facility;

are  structurally  subordinated  in  right  of  payment  to  all  existing  and  future  obligations  of  our  subsidiaries,  including
claims with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured indebtedness and other secured
obligations to the extent of the value of the collateral securing any such indebtedness and other obligations.

The 2030 Notes were issued in minimum denominations of €100,000 and integral multiples of €1,000 in excess thereof.

Principal, Maturity and Interest

The 2030 Notes will bear interest at a rate of 0.875% per year. Interest on the Notes is payable annually in arrears on February
13  of each year, beginning  on  February  13,  2021,  and  will  be  computed  on  the basis of the actual number of days in the period for
which interest is being calculated and the actual number of days from and including the last date on which interest was paid on the 2030
Notes (or the settlement date if no interest has been paid or duly provided for on the 2030 Notes), to but excluding the next date on
which interest is paid or duly provided for. This payment convention is referred to as ACTUAL/ACTUAL (ICMA) as defined in the
rulebook of the International Capital Market Association. Interest on the 2030 Notes will accrue from and including the settlement date
and will be paid to holders of record on the day immediately prior to the applicable interest payment date.

The  2030  Notes  will  mature  on  February  13,  2030.  On  the  maturity  date  of  the  2030  Notes,  the  holders  will  be  entitled  to

receive 100% of the principal amount of such 2030 Notes. The 2030 2030 Notes will not have the benefit of any sinking fund.

If any interest payment date, redemption date or maturity date falls on a day that is not a business day, then the relevant payment
may be made on the next succeeding business day and no interest will accrue because of such delayed payment. With respect to the
2030 Notes, when we use the term “business day” we mean any day except a Saturday, a Sunday or a day on which banking institutions
in the applicable place of payment are authorized or required by law, regulation or executive order to close.

 
Claims against the Company for payment of principal, interest and additional amounts, if any, on the 2030 Notes will become
void unless presentment for payment is made (where so required under the indenture) within, in the case of principal and additional
amounts, if any, a period of ten years or, in the case of interest, a period of five years, in each case from the applicable original date of
payment therefor.

Euro Notes—Issuance in Euros

Initial holders of the 2030 Notes paid for the 2030 Notes in euros, and principal, premium, if any, and interest payments and
additional amounts, if any, in respect of the 2030 Notes will be payable in euros. If, on or after the date of this prospectus supplement,
the euro is unavailable to us due to the imposition of exchange controls or other circumstances beyond our control or the euro is no
longer  used  by  the  then  member  states  of  the  European  Monetary  Union  that  have  adopted  the  euro  as  their  currency  or  for  the
settlement of transactions by public institutions within the international banking community, then all payments in respect of the 2030
Notes will be made in U.S. dollars until the euro is again available to us or so used.

The amount payable on any date in euros will be converted to U.S. dollars on the basis of the most recently available market
exchange rate for euros as determined by us in our sole discretion. Any payment in respect of the 2030 Notes so made in U.S. dollars
will not constitute an event of default under the indenture or the 2030 Notes. Neither the trustee nor the paying agent will be responsible
for obtaining exchange rates, effecting conversions or otherwise handling redenominations.

Ranking

The  2030  Notes  are  general  unsecured  obligations  of  ours  and  will  rank  equally  with  all  of  our  existing  and  future

unsubordinated obligations.

Holders  of  any  secured  indebtedness  and  other  secured  obligations  of  the  Company  will  have  claims  that  are  prior  to  your
claims as holders of the 2030 Notes, to the extent of the value of the assets securing such indebtedness and other obligations, in the
event of any bankruptcy, liquidation or similar proceeding.

Further Issues

The 2030 Notes constituted a separate series of debt securities under the indenture, limited to €600 million. Under the indenture,
we may, without the consent of the holders of the 2030 Notes, issue additional 2030 Notes of the same or a different series from time to
time in the future in an unlimited aggregate principal amount; provided that if any such additional 2030

Notes are not fungible with the 2030 Notes offered hereby (or any other tranche of additional 2030 Notes) for U.S. federal income tax
purposes, then such additional 2030 Notes will have different ISIN and/or Common Code numbers than the Notes offered hereby (and
any such other tranche of additional 2030 Notes). The 2030 Notes and any additional 2030 Notes of the same series would rank equally
and ratably and would be treated as a single class for all purposes under the indenture. This means that, in circumstances where the
indenture provides for the holders of debt securities of any series to vote or take any action, any of the outstanding 2030 Notes, as well
as any additional 2030 Notes that we may issue by reopening such series, will vote or take action as a single class.

Redemption

Optional Redemption

The 2030 Notes will be redeemable, in whole at any time or in part from time to time, at our option, at a redemption price (the
“make-whole redemption price”) equal to the greater of (i) 100% of the principal amount of the 2030 Notes and (ii) as determined by
the Quotation Agent (as defined below), the sum of the present values of the remaining scheduled payments of principal and interest on
the  2030  Notes  (exclusive  of  interest  accrued  and  unpaid  as  of  the  date  of  redemption),  discounted  to  the  date  of  redemption  on  an
annual basis (ACTUAL/ACTUAL (ICMA)) at the Bund Rate (as defined below), plus 20 basis points, plus accrued and unpaid interest
thereon to the date of redemption. However, if the redemption date is after a record date and on or prior to a corresponding interest
payment date, the interest will be paid on the redemption date to the holder of record on the record date.

Notwithstanding the foregoing, at any time on or after November 13, 2029 (three months before their maturity date), the 2030
Notes will be redeemable, in whole or in part, at our option and at any time or from time to time, at a redemption price equal to 100%
of  the  principal  amount  of  the  2030  Notes  to  be  redeemed  plus  accrued  and  unpaid  interest  thereon  to,  but  excluding,  the  date  of
redemption.

Notice  of  any  redemption  will  be  mailed  at  least  30  days,  but  not  more  than  60  days,  before  the  redemption  date  to  each
registered  holder  of  2030  Notes  to  be  redeemed.  Once  notice  of  redemption  is  mailed,  the  2030  Notes  called  for  redemption  will
become due and payable on the redemption date and at the applicable redemption price, plus accrued and unpaid interest to, but not
including, the redemption date. Unless we default in payment of the redemption price, on and after the redemption date, interest will
cease to accrue on the 2030 Notes (or portion thereof) to be redeemed on such redemption date.

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the annual equivalent yield to maturity of
the  Comparable  German  Bund  Issue,  assuming  a  price  for  the  Comparable  German  Bund  Issue  (expressed  as  a  percentage  of  its
principal amount) equal to the Comparable German Bund Price for such redemption date.

“Comparable  German  Bund  Issue”  means  that  German  Bundesanleihe  security  selected  by  the  Quotation  Agent  as  having  a
maturity comparable to the remaining term of the 2030 Notes to be redeemed that would be utilized, at the time of selection and in
accordance with customary
financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of the Notes.

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average of four Reference German Bund
Dealer Quotations for such redemption date, after excluding the highest and lowest such Reference German Bund Dealer Quotations or
(ii) if the Quotation Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such quotations.

“Quotation Agent” means a Reference German Bund Dealer appointed by us.

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities selected by us in good faith.

“Reference German Bund Dealer Quotations” means, with respect to each Reference German Bund Dealer and any redemption
date, the average, as determined by us, of the bid and asked prices for the Comparable German Bund Issue (expressed in each case as a
percentage  of  its  principal  amount)  quoted  in  writing  to  the  Quotation  Agent  by  such  Reference  German  Bund  Dealer  at  3:30  p.m.,
Frankfurt, Germany time, on the third business day preceding such redemption date.

If we elect to redeem less than all of the 2030 Notes, and such 2030 Notes are at the time represented by a global note, then the
depositary will select by lot the particular interests to be redeemed. If we elect to redeem less than all of the 2030 Notes, and any of
such 2030 Notes are not represented by a global note, then the trustee will select the particular 2030 Notes to be redeemed in a manner
it deems appropriate and fair (and the depositary will select by lot the particular interests in any global note to be redeemed).

We may at any time, and from time to time, purchase the 2030 Notes at any price or prices in the open market or otherwise.

 
Repurchase upon Change of Control Triggering Event

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2030 Notes, unless we have exercised our
right  to  redeem  the  2030  Notes,  we  will  be  required  to  make  an  offer  to  repurchase  all  or,  at  the  holder’s  option,  any  part  (equal  to
€100,000 or any integral multiple of €1,000 in excess thereof) of each holder’s 2030 Notes pursuant to the offer described below (the
“Change of Control Offer”).

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% of the aggregate principal amount of
2030  Notes  repurchased  plus  accrued  and  unpaid  interest,  if  any,  on  the  2030  Notes  repurchased  to,  but  not  including,  the  date  of
purchase (the “Change of Control Payment”).

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect sale, transfer, conveyance or other
disposition (other than by way of merger or consolidation), in one or a series of related transactions, of all or substantially all of the
assets  of  us  and  our  Subsidiaries  taken  as  a  whole  to  any  Person  or  group  of  related  Persons  for  purposes  of  Section  13(d)  of  the
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders of our common stock of any plan or
proposal  for  our  liquidation  or  dissolution;  (3)  the  consummation  of  any  transaction  (including,  without  limitation,  any  merger  or
consolidation) the result of which is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50% of
the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority of the members of our board of
directors are not Continuing Directors.

Notwithstanding the foregoing, a transaction will not be deemed to involve a Change of Control if (1) we become a direct or
indirect wholly owned subsidiary of a holding company and (2)(A) the direct or indirect holders of the Voting Stock of such holding
company immediately following that transaction are substantially the same as the holders of our Voting Stock immediately prior to that
transaction  or  (B)  immediately  following  that  transaction  no  Person  or  Group  (other  than  a  holding  company  satisfying  the
requirements  of  this  sentence)  is  the  beneficial  owner,  directly  or  indirectly  of  more  than  50%  of  the  Voting  Stock  of  such  holding
company.

“Change of Control Triggering Event” means the occurrence of both a Change of Control and a Below Investment Grade Rating

Event (as such term is defined in the indenture) occurring in respect of that Change of Control.

“Continuing Directors” means, as of any date of determination, any member of our board of directors who (1) was a member of
our board of directors on the date of the issuance of the 2030 Notes; or (2) was nominated or approved for election, elected or appointed
to our board of directors with the approval of a majority of the Continuing Directors who were members of our board of directors at the
time of such nomination, approval, election or appointment (either by a specific vote or by approval of the proxy statement issued by us
in which such member was named as a nominee for election as a director).

“Person”  means  any  individual,  firm,  limited  liability  company,  corporation,  partnership,  association,  joint  venture,  tribunal,
trust,  government  or  political  subdivision  or  agency  or  instrumentality  thereof,  or  any  other  entity  or  organization  and  includes  a
“person” as used in Section 13(d)(3) of the Exchange Act.

      “Voting Stock” of any specified Person as of any date means the capital stock of such Person that is at the time entitled to vote
generally in the election of the board of directors of such Person.

The definition of “Change of Control” includes a phrase relating to the sale, transfer, conveyance or other disposition of “all or
substantially all” of our consolidated assets. There is no precise, established definition of the phrase “substantially all” under applicable
law. Accordingly, your ability to require us to purchase your 2030 Notes as a result of the sale, transfer, conveyance or other disposition
of less than all of our assets may be uncertain.

Certain Covenants

The indenture contains, among others, restrictive covenants regarding (i) our ability to consolidate or merge with another entity
or  to  sell,  transfer  or  otherwise  convey  all  or  substantially  all  of  our  assets  to  another  entity,  (ii)  create  or  permit  certain  significant
subsidiaries to create or permit to exist certain liens and (iii) certain sale and lease-back transactions involving certain subsidiaries.

Events of Default

Holders  of  the  2030  Notes  will  have  specified  rights  if  an  Event  of  Default  (as  defined  below)  occurs.  The  term  “Event  of

Default” in respect of the 2030 Notes means any of the following:

(1)

we do not pay interest on any of the 2030 Notes within 30 days of its due date;

(2)

(3)

(4)

(5)

(6)

(7)

we fail to pay the principal (or premium, if any) of any 2030 Note, when such principal becomes due and payable, at
maturity, upon acceleration, upon redemption or otherwise;

we fail to comply with certain covenants under the indenture;

we  remain  in  breach  of  a  covenant  or  warranty  in  respect  of  the  indenture  or  2030  Notes  (other  than  a  covenant
included in the indenture solely for the benefit of debt securities of another series) for 90 days after we receive a written
notice of default, which notice must be sent by either the trustee or holders of at least 25% in principal amount of the
outstanding 2030 Notes;

we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization specified in the indenture;

we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an  aggregate  amount  of  at  least
$150,000,000,  constituting  a  default  either  of  payment  of  principal  when  due  and  payable  or  which  results  in
acceleration  of  the  indebtedness  unless  the  default  has  been  cured  or  waived  or  the  indebtedness  discharged  in  full
within 60 days after we have been notified of the default by the trustee or holders of at least 25% of the outstanding
2030 Notes; or

one  or  more  final  judgments  for  the  payment  of  money  in  an  aggregate  amount  in  excess  of  $150,000,000  above
available insurance or indemnity coverage shall be rendered against us or any significant subsidiary and the same shall
remain undischarged for a period of 60 consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect to the 2030 Notes has occurred, the
trustee or the holders of at least 25% in principal amount of

    
the 2030 Notes may declare the entire unpaid principal amount of (and premium, if any), and all the accrued interest on, the Notes to be
due and immediately payable. This is called a declaration of acceleration of maturity. There is no action on the part of the trustee or any
holder  of  the  2030  Notes  required  for  such  declaration  if  the  Event  of  Default  is  the  Company’s  bankruptcy,  insolvency  or
reorganization. Holders of a majority in principal amount of the 2030 Notes may also waive certain past defaults under the indenture
with  respect  to  the  2030  Notes  on  behalf  of  all  of  the  holders  of  the  2030  Notes.  A  declaration  of  acceleration  of  maturity  may  be
canceled, under specified circumstances, by the holders of at least a majority in principal amount of the 2030 Notes and the trustee.

Except in cases of default, where the trustee has special duties, the trustee is not required to take any action under the indenture at the
request of holders unless the holders offer the trustee protection from expenses and liability satisfactory to the trustee. If an indemnity
satisfactory to the trustee is provided, the holders of a majority in principal amount of 2030 Notes may direct the time, method and
place  of  conducting  any  lawsuit  or  other  formal  legal  action  seeking  any  remedy  available  to  the  trustee.  The  trustee  may  refuse  to
follow those directions in certain circumstances specified in the indenture. No delay or omission in exercising any right or remedy will
be treated as a waiver of the right, remedy or Event of Default.

Modification of the Indenture and Waiver of Rights of Holders

Under certain circumstances, we can make changes to the indenture and the 2030 Notes. Some types of changes require the approval of
each holder of 2030 Notes, some require approval by a vote of a majority of the holders of the 2030 Notes, and some changes do not
require any approval at all.
Description of the 1.75% Senior Notes Due 2029

The  1.75%  Senior  Notes  due  2029  (the  “2029  Notes”)  were  issued  under  an  indenture,  dated  as  of  June  7,  2013  (the  “base
indenture”)  between  Nasdaq,  Inc.  and  Wells  Fargo  Bank,  National  Association,  as  trustee  (the  “Trustee”)  and  a  sixth  supplemental
indenture dated as of April 1, 2019 (the “supplemental indenture” and, together with the base indenture, the “indenture”). The indenture
is publicly available at www.sec.gov.

We issued €600 million aggregate principal amount of the 2029 Notes on April 1, 2019.

This summary is subject to, and qualified in its entirety by reference to, all the provisions of the 2029 Notes and the indenture,

including definitions of certain terms used therein.

General

The 2029 Notes:

•

•

•

•

are senior unsecured obligations;

rank  equally  in  right  of  payment  with  all  of  our  other  senior  unsecured  indebtedness  from  time  to  time  outstanding,
commercial paper issuances and indebtedness under our 2017 credit facility;

are structurally subordinated in right of payment to all existing and future obligations of our subsidiaries, including claims
with respect to trade payables; and

are effectively subordinated in right of payment to all of our existing and future secured indebtedness and other secured
obligations to the extent of the value of the collateral securing any such indebtedness and other obligations.

The 2029 Notes were issued in minimum denominations of €100,000 and integral multiples of €1,000 in excess thereof.

Principal, Maturity and Interest

The 2029 Notes bear interest at a rate of 1.75% per year. Interest on the 2029 Notes is payable annually in arrears on of each year,
beginning  on  March  28,  2020,  and  is  computed  on  the  basis  of  the  actual  number  of  days  in  the  period  for  which  interest  is  being
calculated  and  the  actual  number  of  days  from  and  including  the  last  date  on  which  interest  was  paid  on  the  2029  Notes  (or  the
settlement date if no interest has been paid or duly provided for on the 2029 Notes), to but excluding the next date on which interest is
paid or duly provided  for.  This  payment  convention  is  referred  to  as  ACTUAL/ACTUAL (ICMA) as defined in the rulebook of the
International Capital Market Association. Interest on the 2029 Notes accrues from and including the settlement date and will be paid to
holders of record on the day immediately prior to the applicable interest payment date.

The 2029 Notes will mature on March 28, 2029. On the maturity date of the 2029 Notes, the holders will be entitled to receive

100% of the principal amount of such 2029 Notes. The 2029 Notes will not have the benefit of any sinking fund.

If any interest payment date, redemption date or maturity date falls on a day that is not a business day, then the relevant payment
may be made on the next succeeding business day and no interest will accrue because of such delayed payment. With respect to the
2029 Notes, when we use the term “business day” we mean any day except a Saturday, a Sunday or a day on which

banking institutions in the applicable place of payment are authorized or required by law, regulation or executive order to close.

Claims against the Company for payment of principal, interest and additional amounts, if any, on the 2029 Notes will become void
unless presentment for payment is made (where so required under the indenture) within, in the case of principal and additional amounts,
if any, a period of ten years or, in the case of interest, a period of five years, in each case from the applicable original date of payment
therefor.

Euro Notes—Issuance in Euros

Initial holders of the 2029 Notes paid for the 2029 Notes in euros, and principal, premium, if any, and interest payments and
additional amounts, if any, in respect of the Notes will be payable in euros. If the euro is unavailable to us due to the imposition of
exchange controls or other circumstances beyond our control or the euro is no longer used by the then member states of the European
Monetary  Union  that  have  adopted  the  euro  as  their  currency  or  for  the  settlement  of  transactions  by  public  institutions  within  the
international banking community, then all payments in respect of the 2029 Notes will be made in U.S. dollars until the euro is again
available to us or so used.

The amount payable on any date in euros will be converted to U.S. dollars on the basis of the most recently available market
exchange rate for euros as determined by us in our sole discretion. Any payment in respect of the 2029 Notes so made in U.S. dollars
will not constitute an event of default under the indenture or the 2029 Notes. Neither the trustee nor the paying agent will be responsible
for obtaining exchange rates, effecting conversions or otherwise handling redenominations.

Interest Rate Adjustment

The interest rate payable on the 2029 Notes will be subject to adjustment from time to time if either Moody’s or S&P, or, in either

case, any substitute rating agency downgrades (or subsequently upgrades) the credit rating assigned to the 2029 Notes.

Ranking

The  2029  Notes  are  general  unsecured  obligations  of  ours  and  rank  equally  with  all  of  our  existing  and  future  unsubordinated

obligations.

Holders of any secured indebtedness and other secured obligations of the Company will have claims that are prior to claims as
holders of the 2029 Notes, to the extent of the value of the assets securing such indebtedness and other obligations, in the event of any
bankruptcy, liquidation or similar proceeding.

Further Issues

The 2029 Notes constituted a separate series of debt securities under the indenture, limited to €600 million. Under the indenture,
we may, without the consent of the holders of the 2029 Notes, issue additional 2029 Notes of the same or a different series from time to
time in the future in an unlimited aggregate principal amount; provided, that, if any such additional 2029 Notes are not fungible with
the 2029 Notes (or any other tranche of additional 2029 Notes) for U.S. federal income tax purposes, then such additional 2029 Notes
will have different ISIN and/or Common Code numbers than the 2029 Notes (and any such other tranche of additional 2029 Notes).
The 2029 Notes and any additional 2029 Notes of the same series would rank equally and ratably and would be treated as a single class
for all purposes under the indenture. This means that, in circumstances where the indenture provides for the holders of debt securities of
any series to vote or take any action, any of the outstanding 2029 Notes, as well as any additional 2029 Notes that we may issue by
reopening such series, will vote or take action as a single class.

Redemption

Optional Redemption

The 2029 Notes will be redeemable, in whole at any time or in part from time to time, at our option, at a redemption price (the
“make-whole redemption price”) equal to the greater of (i) 100% of the principal amount of the 2029 Notes, and (ii) as determined by
the Quotation Agent (as defined below), the sum of the present values of the remaining scheduled payments of principal and interest on
the  2029  Notes  (exclusive  of  interest  accrued  and  unpaid  as  of  the  date  of  redemption),  discounted  to  the  date  of  redemption  on  an
annual basis (ACTUAL/ACTUAL (ICMA)) at the Bund Rate (as defined below), plus 30 basis points, plus accrued and unpaid interest
thereon to the date of redemption. However, if the redemption date is after a record date and on or prior to a corresponding interest
payment date, the interest will be paid on the redemption date to the holder of record on the record date.

Notwithstanding  the  foregoing,  at  any  time  on  or  after  December  28,  2028  (three  months  before  their  maturity  date),  the  2029
Notes will be redeemable, in whole or in part, at our option and at any time or from time to time, at a redemption price equal to 100%
of  the  principal  amount  of  the  2029  Notes  to  be  redeemed  plus  accrued  and  unpaid  interest  thereon  to,  but  excluding,  the  date  of
redemption.

Notice of any redemption will be mailed at least 30 days, but not more than 60 days, before the redemption date to each registered
holder of 2029 Notes to be redeemed. Once notice of redemption is mailed, the 2029 Notes called for redemption will become due and
payable  on  the  redemption  date  and  at  the  applicable  redemption  price,  plus  accrued  and  unpaid  interest  to,  but  not  including,  the
redemption date. Unless we default in payment of the redemption price, on and after the redemption date, interest will cease to accrue
on the 2029 Notes (or portion thereof) to be redeemed on such redemption date.

“Bund Rate” means, with respect to any redemption date, the rate per annum equal to the annual equivalent yield to maturity of the
Comparable German Bund Issue, assuming a price for the Comparable German Bund Issue (expressed as a percentage of its principal
amount) equal to the Comparable German Bund Price for such redemption date.

“Comparable  German  Bund  Issue”  means  that  German  Bundesanleihe  security  selected  by  the  Quotation  Agent  as  having  a
maturity  comparable  to  the  remaining  term  of  the  Notes  to  be  redeemed  that  would  be  utilized,  at  the  time  of  selection  and  in
accordance with customary financial practice, in pricing new issues of corporate notes of comparable maturity to the remaining term of
the Notes.

“Comparable German Bund Price” means, with respect to any redemption date, (i) the average of four Reference German Bund
Dealer Quotations for such redemption date, after excluding the highest and lowest such Reference German Bund Dealer Quotations, or
(ii) if the Quotation Agent obtains fewer than four such Reference German Bund Dealer Quotations, the average of all such quotations.

“Quotation Agent” means a Reference German Bund Dealer appointed by us.

“Reference German Bund Dealer” means any dealer of German Bundesanleihe securities selected by us in good faith.

“Reference German Bund Dealer Quotations” means, with respect to each Reference German Bund Dealer and any redemption
date, the average, as determined by us, of the bid and asked prices for the Comparable German Bund Issue (expressed in each case as a
percentage  of  its  principal  amount)  quoted  in  writing  to  the  Quotation  Agent  by  such  Reference  German  Bund  Dealer  at  3:30  p.m.,
Frankfurt, Germany time, on the third business day preceding such redemption date.

If we elect to redeem less than all of the 2029 Notes, and such 2029 Notes are at the time represented by a global note, then the
depositary will select by lot the particular interests to be redeemed. If we elect to redeem less than all of the 2029 Notes, and any of
such 2029 Notes are

not represented by a global note, then the trustee will select the particular 2029 Notes to be redeemed in a manner it deems appropriate
and fair (and the depositary will select by lot the particular interests in any global note to be redeemed).

We may at any time, and from time to time, purchase the 2029 Notes at any price or prices in the open market or otherwise.

Repurchase upon Change of Control Triggering Event

If a Change of Control Triggering Event (as defined below) occurs with respect to the 2029 Notes, unless we have exercised our
right to redeem the 2029 Notes, we are required to make an offer to repurchase all or, at the holder’s option, any part (equal to €100,000
or any integral multiple of €1,000 in excess thereof) of each holder’s 2029 Notes pursuant to the offer described below (the “Change of
Control Offer”).

In the Change of Control Offer, we will be required to offer payment in cash equal to 101% of the aggregate principal amount of

2029 Notes repurchased plus accrued and unpaid interest, if any, on the Notes repurchased to, but not including, the date of purchase
(the “Change of Control Payment”).

“Change of Control” means the occurrence of any of the following: (1) the direct or indirect sale, transfer, conveyance or other
disposition (other than by way of merger or consolidation), in one or a series of related transactions, of all or substantially all of the
assets  of  us  and  our  Subsidiaries  taken  as  a  whole  to  any  Person  or  group  of  related  Persons  for  purposes  of  Section  13(d)  of  the
Exchange Act (a “Group”) other than us or one of our subsidiaries; (2) the approval by the holders of our common stock of any plan or
proposal  for  our  liquidation  or  dissolution;  (3)  the  consummation  of  any  transaction  (including,  without  limitation,  any  merger  or
consolidation) the result of which is that any Person or Group becomes the beneficial owner, directly or indirectly, of more than 50% of
the then outstanding number of shares of our Voting Stock; or (4) the first day on which a majority of the members of our board of
directors are not Continuing Directors.

Notwithstanding  the  foregoing,  a  transaction  will  not  be  deemed  to  involve  a  Change  of  Control  if  (1)  we  become  a  direct  or
indirect wholly owned Subsidiary of a holding company and (2)(A) the direct or indirect holders of the Voting Stock of such holding
company immediately following that transaction are substantially the same as the holders of our Voting Stock immediately prior to that
transaction  or  (B)  immediately  following  that  transaction  no  Person  or  Group  (other  than  a  holding  company  satisfying  the
requirements of this sentence) is the

beneficial owner, directly or indirectly of more than 50% of the Voting Stock of such holding company.

“Change of Control Triggering Event” means the occurrence of both a Change of Control and a Below Investment Grade Rating

Event (as such term is defined in the indenture) occurring in respect of that Change of Control.

“Continuing Directors” means, as of any date of determination, any member of our board of directors who (1) was a member of
our board of directors on the date of the issuance of the Notes; or (2) was nominated or approved for election, elected or appointed to
our board of directors with the approval of a majority of the Continuing Directors who were members of our board of directors at the
time of such nomination, approval, election or appointment (either by a specific vote or by approval of the proxy statement issued by us
in which such member was named as a nominee for election as a director).

“Person” means any individual, firm, limited liability company, corporation, partnership, association, joint venture, tribunal, trust,
government or political subdivision or agency or instrumentality thereof, or any other entity or organization and includes a “person” as
used in Section 13(d)(3) of the Exchange Act.

“Voting Stock” of any specified Person as of any date means the capital stock of such Person that is at the time entitled to vote

generally in the election of the board of directors of such Person.

The definition of “Change of Control” includes a phrase relating to the sale, transfer, conveyance or other disposition of “all or
substantially all” of our consolidated assets. There is no precise, established definition of the phrase “substantially all” under applicable
law. Accordingly, the ability to require us to purchase 2029 Notes as a result of the sale, transfer, conveyance or other disposition of less
than all of our assets may be uncertain.

Certain Covenants

The indenture contains, among others, restrictive covenants regarding (i) our ability to consolidate or merge with another entity or
to  sell,  transfer  or  otherwise  convey  all  or  substantially  all  of  our  assets  to  another  entity;  (ii)  create  or  permit  certain  significant
subsidiaries to create or permit to exist certain liens and (iii) certain sale and lease-back transactions involving certain subsidiaries.

Events of Default

Holders of the 2029 Notes will have specified rights if an Event of Default (as defined below) occurs. The term “Event of Default”

in respect of the Notes means any of the following:

(1)

(2)

(3)

(4)

(5)

(6)

(7)

we do not pay interest on any of the Notes within 30 days of its due date;

we fail to pay the principal (or premium, if any) of any Note, when such principal becomes due and payable, at maturity,
upon acceleration, upon redemption or otherwise;

failure by us to comply with the covenants under the indenture;

we remain in breach of a covenant or warranty in respect of the indenture or 2029 Notes (other than a covenant included
in the indenture solely for the benefit of debt securities of another series) for 90 days after we receive a written notice of
default, which notice must be sent by either the trustee or holders of at least 25% in principal amount of the outstanding
2029 Notes;

we file for bankruptcy, or other events of bankruptcy, insolvency or reorganization specified in the indenture;

we  default  on  any  indebtedness  of  ours  or  of  a  significant  subsidiary  having  an  aggregate  amount  of  at  least
$150,000,000,  constituting  a  default  either  of  payment  of  principal  when  due  and  payable  or  which  results  in
acceleration of the indebtedness unless the default has been cured or waived or the indebtedness discharged in full within
60  days  after  we  have  been  notified  of  the  default  by  the  trustee  or  holders  of  at  least  25%  of  the  outstanding  2029
Notes; or

one  or  more  final  judgments  for  the  payment  of  money  in  an  aggregate  amount  in  excess  of  $150,000,000  above
available insurance or indemnity coverage shall be rendered against us or any significant subsidiary and the same shall
remain undischarged for a period of 60 consecutive days during which execution shall not be effectively stayed.

If an Event of Default (other than an Event of Default specified in clause (5) above) with respect to the 2029 Notes has occurred, the
Trustee or the holders of at least 25% in principal amount of
the 2029 Notes may declare the entire unpaid principal amount of (and premium, if any), and all the accrued interest on, the Notes to be
due and immediately payable. This is called a declaration

of acceleration of maturity. There is no action on the part of the trustee or any holder of the 2029 Notes required for such declaration if
the Event of Default is the Company’s bankruptcy, insolvency or reorganization. Holders of a majority in principal amount of the Notes
may  also  waive  certain  past  defaults  under  the  indenture  with  respect  to  the  2029  Notes  on  behalf  of  all  of  the  holders  of  the  2029
Notes. A declaration of acceleration of maturity may be canceled, under specified circumstances, by the holders of at least a majority in
principal amount of the 2029 Notes and the trustee.

Except in cases of default, where the trustee has special duties, the trustee is not required to take any action under the indenture at
the  request  of  holders  unless  the  holders  offer  the  trustee  protection  from  expenses  and  liability  satisfactory  to  the  trustee.  If  an
indemnity  satisfactory  to  the  trustee  is  provided,  the  holders  of  a  majority  in  principal  amount  of  2029  Notes  may  direct  the  time,
method and place of conducting any lawsuit or other formal legal action seeking any remedy available to the trustee. The trustee may
refuse to follow those directions in certain circumstances specified in the indenture. No delay or omission in exercising any right or
remedy will be treated as a waiver of the right, remedy or Event of Default.

Before holders of the 2029 Notes are allowed to bypass the trustee and bring a lawsuit or other formal legal action or take other

steps to enforce their rights or protect their interests relating to the 2029 Notes, the following must occur:

•

•

such holders must give the trustee written notice that an Event of Default has occurred and remains uncured;

holders  of  at  least  25%  in  principal  amount  of  the  2029  Notes  must  make  a  written  request  that  the  trustee  take  action
because of the default and must offer the Trustee indemnity satisfactory to the trustee against the cost and other liabilities
of taking that action; and

•

the trustee must have failed to take action for 60 days after receipt of the notice and offer of indemnity.

Holders are, however, entitled at any time to bring a lawsuit for the payment of money due on the 2029 Notes on or after the due

date.

Modification of the Indenture and Waiver of Rights of Holders

 
Under  certain  circumstances,  we  can  make  changes  to  the  indenture  and  the  2029  Notes.  Some  types  of  changes  require  the
approval  of  each  holder  of  2029  Notes,  some  require  approval  by  a  vote  of  a  majority  of  the  holders  of  the  2029  Notes,  and  some
changes do not require any approval at all.

Subsidiaries of Nasdaq, Inc.*
As of February 15, 2024

Exhibit 21.1

U.S. Entities

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.

Adenza Group, Inc. (organized in Delaware)
Adenza Holdings, LLC (organized in Delaware)
Adenza Intermediate I, LLC (organized in Delaware)
Adenza Intermediate II, LLC (organized in Delaware)
Adenza, Inc. (organized in Delaware)
BoardVantage, Inc (organized in Delaware)
Boston Stock Exchange Clearing Corporation (organized in Massachusetts)
Content Services, LLC (organized in Delaware)
Curzon Street Acquisition, LLC (organized in Delaware)
Directors Desk, LLC (organized in Delaware)
Dorsey, Wright & Associates, LLC (organized in Virginia)
eVestment Alliance, LLC (organized in Delaware)
eVestment, Inc. (organized in Delaware)
FINRA/Nasdaq Trade Reporting Facility LLC (organized in Delaware)
FRAMLxchange Inc. (organized in Delaware)
FTEN, Inc. (organized in Delaware)
Granite Redux, Inc. (organized in Delaware)
GraniteBlock, Inc. (organized in Delaware)
International Securities Exchange Holdings, Inc. (organized in Delaware)
Longitude LLC (organized in Delaware)
Nasdaq BX, Inc. (organized in Delaware)
Nasdaq Capital Markets Advisory LLC (organized in Delaware)
Nasdaq Corporate Services, LLC (organized in Delaware)
Nasdaq Corporate Solutions, LLC (organized in Delaware)
Nasdaq Digital Asset Holdings, LLC (organized in Delaware)
NASDAQ Energy Futures, LLC (organized in Delaware)
Nasdaq Execution Services, LLC (organized in Delaware)
Nasdaq Fund Secondaries, LLC (organized in Delaware)
NASDAQ Futures, Inc. (organized in Delaware)
Nasdaq GEMX, LLC (organized in Delaware)
NASDAQ Global, Inc. (organized in Delaware)
Nasdaq Governance Solutions, Inc. (organized in Delaware)
Nasdaq Information, LLC (organized in Delaware)
Nasdaq ISE, LLC (organized in Delaware)
Nasdaq MRX, LLC (organized in Delaware)
Nasdaq PHLX LLC (organized in Delaware)
Nasdaq Private Market, LLC (organized in Delaware)
Nasdaq SB Holdings, LLC (organized in Delaware)
Nasdaq SPS, LLC (organized in Delaware)
Nasdaq Technology Services, LLC (organized in Delaware)
NFSTX, LLC (organized in Delaware)
OneReport, LLC (organized in Delaware)
Operations & Compliance Network, LLC (organized in Delaware)
QDiligence LLC (organized in Illinois)
Solovis, Inc. (organized in Delaware)
Stock Clearing Corporation of Philadelphia (organized in Pennsylvania)
Strategic Financial Solutions, LLC (organized in Nevada)
Sybenetix Inc. (organized in Delaware)
The Center for Board Evaluation, Inc. (organized in North Carolina)
The Nasdaq Options Market LLC (organized in Delaware)
The Nasdaq Stock Market LLC (organized in Delaware)
U.S. Exchange Holdings, Inc. (organized in Delaware)
Verafin AcquisitionCo LLC (organized in Delaware)
Verafin USA Inc. (organized in Delaware)

Non-U.S. Subsidiaries

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.

AB Nasdaq Vilnius (organized in Lithuania)
Adenza Australia Pty Ltd. (organized in Australia)
Adenza Brasil Ltda (organized in Brazil)
Adenza Canada, Inc. (organized in Canada)
Adenza Chile SpA (organized in Chile)
Adenza Colombia S.A.S. (organized in Colombia)
Adenza France SARL (organized in France)
Adenza Georgia LLC (organized in Georgia)
Adenza Gemany GmbH (organized in Germany)
Adenza Hong Kong (organized in Hong Kong)
Adenza India Private Ltd. (organized in India)
Adenza Ireland Ltd. (organized in Ireland)
Adenza Israel Ltd. (organized in Israel)
Adenza Japan KK (organized in Japan)
Adenza Korea LLC (organized in South Korea)
Adenza Ltd. (organized in the United Kingdom)
Adenza Netherlands B.V. (organized in the Netherlands)
ADENZA POLAND SOO SPOLKA Z OGRANICZONA ODPOWIEDZIALNOSCIA (organized in Poland)
Adenza Portugal S.A. (organized in Portugal)
Adenza Singapore Pte. Ltd. (organized in Singapore)
Adenza Spain S.L. (organized in Spain)
Adenza Technology (DIFC) Ltd. (organized in Dubai)
Adenza Technology de Mexico, S. de R.L. de C.V. (organized in Mexico)
AS Pensionikeskus AS (organized in Estonia)
Axioma SD, Ltd. (organized in Russia)
AxiomSL Holdings B.V. (organized in the Netherlands)
AxiomSL Ltd. (Hong Kong) (organized in Hong Kong)
AxiomSL Ltd. (UK) (organized in the United Kingdom)
AxiomSL Pty Ltd. (organized in Australia)
AxiomSL Software Spain, S.L. (organized in Spain)
Calypso Group UK Ltd. (organized in the United Kingdom)
Calypso Holdco Ltd. (organized in the United Kingdom)
Calypso Software (Beijing) Co Ltd. (organized in China)
Calypso Technology International Ltd. (organized in Ireland)
Calypso Technology Pte. Ltd. (organized in Singapore)
Calypso UK MidCo. Ltd. (organized in the United Kingdom)
Calypso UK TopCo. Ltd. (organized in the United Kingdom)
Capri Bidco Ltd. (UK) (organized in the United Kingdom)
Capri Holdco Ltd. (UK) (organized in the United Kingdom)
Cinnober Financial Technology AB (organized in Sweden)
Curzon Street Holdings Limited (organized in the United Kingdom)
Ensoleillement Inc. (organized in Canada)
eVestment Alliance (UK) Limited (organized in the United Kingdom)
eVestment Alliance Australia Pty Ltd (organized in Australia)
eVestment Alliance Hong Kong Limited (organized in Hong Kong)
Indxis Ltd (organized in the United Kingdom)
Metrio Software Inc. (organized in Quebec)
Nasdaq (Asia Pacific) Pte. Ltd. (organized in Singapore)
Nasdaq AB (organized in Sweden)
Nasdaq Australia Holding Pty Ltd (organized in Australia)
NASDAQ Canada Inc. (organized in Canada)
Nasdaq Clearing AB (organized in Sweden)
Nasdaq Copenhagen A/S (organized in Denmark)
Nasdaq Corporate Solutions (India) Private Limited (organized in India)
Nasdaq Corporate Solutions International Limited (organized in the United Kingdom)
Nasdaq CSD SE (organized in Latvia)
Nasdaq CXC Limited (organized in Canada)
Nasdaq Exchange and Clearing Services AB (organized in Sweden)
Nasdaq France SAS (organized in France)
Nasdaq Germany GmbH (organized in Germany)
Nasdaq Helsinki Ltd (organized in Finland)

62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101. Whittaker & Garnier Limited (organized in the United Kingdom)

Nasdaq Holding AB (organized in Sweden)
Nasdaq Holding Denmark A/S (organized in Denmark)
Nasdaq Holding Luxembourg Sárl (organized in Luxembourg)
Nasdaq Iceland hf. (organized in Iceland)
Nasdaq International Ltd (organized in the United Kingdom)
NASDAQ Korea Ltd (organized in South Korea)
Nasdaq Ltd (organized in Hong Kong)
Nasdaq Nordic Ltd (organized in Finland)
NASDAQ OMX Europe Ltd (organized in the United Kingdom)
Nasdaq Oslo ASA (organized in Norway)
Nasdaq Pty Ltd (organized in Australia)
Nasdaq Riga, AS (organized in Latvia) (92.98% owned, directly or indirectly, by Nasdaq, Inc.)
Nasdaq Spot AB (organized in Sweden)
Nasdaq Stockholm AB (organized in Sweden)
Nasdaq Tallinn AS (organized in Estonia)
Nasdaq Technology (Japan) Ltd (organized in Japan)
Nasdaq Technology AB (organized in Sweden)
Nasdaq Technology Energy Systems AS (organized in Norway)
Nasdaq Technology Italy Srl (organized in Italy)
Nasdaq Teknoloji Servisi Limited Sirketi (organized in Turkey)
Nasdaq Treasury AB (organized in Sweden)
Nasdaq Vilnius Services UAB (organized in Lithuania)
Nasdaq Wizer Solutions AB (organized in Sweden)
OMX Netherlands B.V. (organized in the Netherlands)
OMX Netherlands Holding B.V. (organized in the Netherlands)
OMX Treasury Euro AB (organized in Sweden) (99.9% owned, directly or indirectly, by Nasdaq, Inc.)
OMX Treasury Euro Holding AB (organized in Sweden)
Puro.earth (organized in Finland) (70% owned, directly or indirectly, by Nasdaq, Inc.)
Quandl, Inc. (organized in Canada, Federal)
RF Nordic Express AB (organized in Sweden) (50.1% owned, directly or indirectly, by Nasdaq, Inc.)
Shareholder.com B.V. (organized in the Netherlands)
Simplitium Ltd (organized in the United Kingdom)
SMARTS Broker Compliance Pty Ltd (organized in Australia)
SMARTS Market Surveillance Pty Ltd (organized in Australia)
Sybenetix Limited (organized in the United Kingdom)
Sybenetix Ukraine (organized in the Ukraine)
TopQ Software Limited (organized in the United Kingdom)
TOV AxiomSL (organized in the Ukraine)
Verafin Solutions ULC (organized in Canada)

The list of subsidiaries does not include not-for-profit entities or foreign branches of subsidiaries, or entities in which Nasdaq owns less than 50% of the entity.

Exhibit 23.1

We consent to the incorporation by reference in the following Registration Statements:           

Consent of Independent Registered Public Accounting Firm

(1)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

Registration Statement (Form S-3 No. 333-255666)     of Nasdaq, Inc.,

Registration Statement (Form S-8 No. 333-239891) pertaining to Nasdaq, Inc. Employee Stock Purchase Plan,

Registration Statement (Form S-8 No. 333-225218) pertaining to Nasdaq, Inc. Equity Incentive Plan,

Registration Statement (Form S-8 No. 333-196838) pertaining to Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, Inc.) Equity
Incentive Plan,

Registration  Statement  (Form  S-8  No.  333-167724)  pertaining  to  Nasdaq,  Inc.  (f/k/a  The  NASDAQ  OMX  Group,  Inc.)
Employee Stock Purchase Plan,

Registration Statement (Form S-8 No. 333-167723) pertaining to Nasdaq, Inc. (f/k/a The NASDAQ OMX Group, Inc.) Equity
Incentive Plan,

Registration Statement (Form S-8 No. 333-110602) pertaining to The Nasdaq Stock Market, Inc. Equity Incentive Plan,

Registration  Statement  (Form  S-8  No.  333-106945)  pertaining  to  the  Employment  Agreement  with  Robert  Greifeld  of  The
Nasdaq Stock Market, Inc.,

Registration Statement (Form S-8 No. 333-76064) pertaining to The Nasdaq Stock Market, Inc. 2000 Employee Stock Purchase
Plan,

(10) Registration Statement (Form S-8 No. 333-72852) pertaining to The Nasdaq Stock Market, Inc. 2000 Employee Stock Purchase

Plan, and

(11) Registration Statement (Form S-8 No. 333-70992) pertaining to The Nasdaq Stock Market, Inc. Equity Incentive Plan;

(12) Registration Statement (Form S-8 No. 333-265824) pertaining to The Nasdaq, Inc. Deferred Compensation Plan;

of our reports dated February 21, 2024, with respect to the consolidated financial statements of Nasdaq, Inc. and the effectiveness of
internal control over financial reporting of Nasdaq, Inc. included in this Annual Report (Form 10-K) of Nasdaq, Inc. for the year ended
December 31, 2023.

/s/ Ernst & Young LLP

New York, New York
February 21, 2024

 
POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

Exhibit 24.1

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for her and in her name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 20, 2024.

            /s/ Melissa M. Arnoldi
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for her and in her name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 20, 2024.

            /s/ Charlene T. Begley
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 19, 2024.

            /s/ Steven D. Black
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 16, 2024.

            /s/ Essa Kazim
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 20, 2024.

            /s/ Thomas A. Kloet
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 20, 2024.

            /s/ Holden Spaht
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 15, 2024.

            /s/ Michael R. Splinter
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 19, 2024.

            /s/ Johan Torgeby
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for her and in her name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 19, 2024.

            /s/ Toni Townes-Whitley
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 20, 2024.

            /s/ Jeffrey W. Yabuki
            Signature

POWER OF ATTORNEY
ANNUAL REPORT ON FORM 10-K
NASDAQ, INC.

    Know all persons by these presents, that the undersigned, a director of Nasdaq, Inc., a Delaware corporation, hereby constitutes and
appoints John A. Zecca and Erika Moore, and each of them acting individually, the undersigned’s true and lawful attorneys-in-fact and
agents, each with full power and substitution and resubstitution, for him and in his name, place, and stead, in any case and all capacities
to:

    (1) execute for and on behalf of the undersigned, an Annual Report on Form 10-K of Nasdaq, Inc. for the fiscal year ended December
31, 2023, including any and all amendments and additions thereto (collectively, the “Annual Report”) in accordance with the Securities
Exchange Act of 1934, as amended, and the rules thereunder;

    (2) do and perform any and all acts for and on behalf of the undersigned which may be necessary or desirable to file, or cause to be
filed, the Annual Report with all exhibits thereto (including this Power of Attorney), and other documents in connection therewith, with
the United States Securities and Exchange Commission; and

    (3) take any other action or any type whatsoever in connection with the foregoing which, in the opinion of such attorneys-in-fact,
may be of benefit to, in the best interest of, or legally required by, the undersigned, it being understood that the documents executed by
such  attorneys-in-fact  on  behalf  of  the  undersigned  pursuant  to  this  Power  of  Attorney  shall  be  in  such  form  and  shall  contain  such
terms and conditions as such attorneys-in-fact may approve in such attorneys-in-fact’s discretion.

        The  undersigned  hereby  grants  to  each  attorney-in-fact  full  power  and  authority  to  do  and  perform  any  and  every  act  and  thing
whatsoever requisite, necessary or proper to be done in the exercise of any of the rights and powers herein granted, as fully to all intents
and purposes as the undersigned might or could do if personally present, with full power of substitution or revocation, hereby ratifying
and confirming all that such shall lawfully do or cause to be done by virtue of this Power of Attorney and the rights and powers herein
granted.

    IN WITNESS WHEREOF, the undersigned has caused this Power of Attorney to be executed as of February 15, 2024.

            /s/ Alfred W. Zollar
            Signature

Exhibit 31.1

I, Adena T. Friedman, certify that:

1. I have reviewed this Annual Report on Form 10-K of Nasdaq, Inc.;

CERTIFICATION

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the

statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the

financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange
Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and
have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to

ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our

supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes
in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the

effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent
fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the
registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the

registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably

likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control

over financial reporting.

Name:
Title:

 /s/    Adena T. Friedman
Adena T. Friedman
Chief Executive Officer

Date: February 21, 2024

 
 
 
 
 
 
 
 
 
CERTIFICATION

Exhibit 31.2

I, Sarah Youngwood, certify that:

1. I have reviewed this Annual Report on Form 10-K of Nasdaq, Inc.;

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the

statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the

financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange
Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and
have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to

ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our

supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes
in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the

effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent
fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the
registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the

registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably

likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control

over financial reporting.

Name:
Title:

 /s/ Sarah Youngwood
Sarah Youngwood
Executive Vice President and Chief Financial Officer

Date: February 21, 2024

 
 
 
Certification of CEO and CFO Pursuant to
18 U.S.C. Section 1350
as Adopted Pursuant to
Section 906 of the Sarbanes-Oxley Act of 2002

Exhibit 32.1

In connection with the Annual Report on Form 10-K of Nasdaq, Inc. (the “Company”) for the period ended December 31, 2023 as filed with the Securities

and Exchange Commission on the date hereof (the “Report”), Adena T. Friedman, as Chief Executive Officer of the Company, and Sarah Youngwood, as
Executive Vice President and Chief Financial Officer of the Company, each hereby certifies, pursuant to 18 U.S.C. § 1350, as adopted pursuant to § 906 of the
Sarbanes-Oxley Act of 2002, that, to the best of her knowledge:

(1) The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

(2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of the operations of the

Company.

Name:
Title:
Date:

Name:
Title:
Date:

/s/   Adena T. Friedman
Adena T. Friedman
Chief Executive Officer
February 21, 2024

/s/   Sarah Youngwood
Sarah Youngwood
Executive Vice President and Chief Financial Officer
February 21, 2024

This certification accompanies the Report pursuant to § 906 of the Sarbanes-Oxley Act of 2002 and shall not, except to the extent required by the Sarbanes-Oxley
Act of 2002, be deemed filed by the Company for purposes of § 18 of the Securities Exchange Act of 1934, as amended.

 
 
 
 
NASDAQ, INC.

SUPPLEMENTAL EXECUTIVE OFFICER RECOUPMENT POLICY

Exhibit 97.1

The Management Compensation Committee of the Board (the “Committee”) of the Board of Directors (the “Board”) of Nasdaq,
Inc. (the “Company”) believes that it is appropriate for the Company to adopt this Supplemental Executive Officer Recoupment Policy
(the “Policy”) to be applied to the Executive Officers of the Company and adopts this Policy to be effective as of the Effective Date.

1. Definitions

For purposes of this Policy, the following definitions shall apply:

a) “Company Group” means the Company and each of its Subsidiaries, as applicable.

b) “Covered Compensation” means any Incentive-Based Compensation granted, vested or paid to a person who served as an
Executive Officer at any time during the performance period for the Incentive-Based Compensation and that was Received
(i) on or after the Effective Date, (ii) after the person became an Executive Officer and (iii) at a time that the Company had a
class of securities listed on a national securities exchange or a national securities association.

c) “Effective Date” means October 2, 2023, the effective date of the Nasdaq listing standard.

d) “Erroneously Awarded Compensation” means the amount of Covered Compensation granted, vested or paid to a person
during the fiscal period when the applicable Financial Reporting Measure relating to such Covered Compensation was
attained that exceeds the amount of Covered Compensation that otherwise would have been granted, vested or paid to the
person had such amount been determined based on the applicable Restatement, computed without regard to any taxes paid
(i.e., on a pre-tax basis). For Covered Compensation based on stock price or total shareholder return, where the amount of
Erroneously Awarded Compensation is not subject to mathematical recalculation directly from the information in a
Restatement, the Committee will determine the amount of such Covered Compensation that constitutes Erroneously
Awarded Compensation, if any, based on a reasonable estimate of the effect of the Restatement on the stock price or total
shareholder return upon which the Covered Compensation was granted, vested or paid and the Committee shall maintain
documentation of such determination and provide such documentation to the Nasdaq.

e) “Exchange Act” means the Securities Exchange Act of 1934.

f) “Executive Officer” means each “officer” of the Company as defined under Rule 16a-1(f) under Section 16 of the Exchange
Act, which shall be deemed to include any individuals identified by the Company as executive officers pursuant to Item
401(b) of Regulation S-K under the Exchange Act. Both current and former Executive Officers are subject to the Policy in
accordance with its terms.

g) “Financial Reporting Measure” means (i) any measure that is determined and presented in accordance with the accounting
principles used in preparing the Company’s financial statements, and any measures derived wholly or in part from such
measures and may consist of GAAP or non-GAAP financial measures (as defined under Regulation G of the Exchange Act
and Item 10 of Regulation S-K under the Exchange Act), (ii) stock price or (iii) total

 
 
shareholder return. Financial Reporting Measures may or may not be filed with the SEC and may be presented outside the
Company’s financial statements, such as in Managements’ Discussion and Analysis of Financial Conditions and Result of
Operations or in the performance graph required under Item 201(e) of Regulation S-K under the Exchange Act.

h) “Home Country” means the Company’s jurisdiction of incorporation.

i) “Incentive-Based Compensation” means any compensation that is granted, earned or vested based wholly or in part upon the

attainment of a Financial Reporting Measure.

j) “Lookback Period” means the three completed fiscal years (plus any transition period of less than nine months that is within
or immediately following the three completed fiscal years and that results from a change in the Company’s fiscal year)
immediately preceding the date on which the Company is required to prepare a Restatement for a given reporting period,
with such date being the earlier of: (i) the date the Board, a committee of the Board, or the officer or officers of the
Company authorized to take such action if Board action is not required, concludes, or reasonably should have concluded,
that the Company is required to prepare a Restatement, or (ii) the date a court, regulator or other legally authorized body
directs the Company to prepare a Restatement. Recovery of any Erroneously Awarded Compensation under the Policy is not
dependent on if or when the Restatement is actually filed.

k) “Nasdaq” means the Nasdaq Stock Market LLC.

l) “Received” Incentive-Based Compensation is deemed “Received” in the Company’s fiscal period during which the

Financial Reporting Measure specified in or otherwise relating to the Incentive-Based Compensation award is attained, even
if the grant, vesting or payment of the Incentive-Based Compensation occurs after the end of that period.

m) “Restatement” means a required accounting restatement of any Company financial statement due to the material

noncompliance of the Company with any financial reporting requirement under the securities laws, including (i) to correct
an error in previously issued financial statements that is material to the previously issued financial statements (commonly
referred to as a “Big R” restatement) or (ii) to correct an error in previously issued financial statements that is not material to
the previously issued financial statements but that would result in a material misstatement if the error were corrected in the
current period or left uncorrected in the current period (commonly referred to as a “little r” restatement). Changes to the
Company’s financial statements that do not represent error corrections under the then-current relevant accounting standards
will not constitute Restatements. Recovery of any Erroneously Awarded Compensation under the Policy is not dependent on
fraud or misconduct by any person in connection with the Restatement.

n) “SEC” means the United States Securities and Exchange Commission.

o) “Subsidiary” means any domestic or foreign corporation, partnership, association, joint stock company, joint venture, trust

or unincorporated organization “affiliated” with the Company, that is, directly or indirectly, through one or more
intermediaries, “controlling”, “controlled by” or “under common control with”, the Company. “Control” for this purpose
means the possession, direct or indirect, of the power to direct or cause the direction of the management and policies of such
person, whether through the ownership of voting securities, contract or otherwise.

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2. Recoupment of Erroneously Awarded Compensation

In the event of a Restatement, any Erroneously Awarded Compensation Received during the Lookback Period prior to the

Restatement (a) that is then-outstanding but has not yet been paid shall be automatically and immediately forfeited and (b) that has been
paid to any person shall be subject to reasonably prompt repayment to the Company Group in accordance with Section 3 of this Policy.
The Committee must pursue (and shall not have the discretion to waive) the forfeiture and/or repayment of such Erroneously Awarded
Compensation in accordance with Section 3 of this Policy, except as provided below.

Notwithstanding the foregoing, the Committee (or, if the Committee is not a committee of the Board responsible for the Company’s

executive compensation decisions and composed entirely of independent directors, a majority of the independent directors serving on
the Board) may determine not to pursue the forfeiture and/or recovery of Erroneously Awarded Compensation from any person if the
Committee determines that such forfeiture and/or recovery would be impracticable due to any of the following circumstances: (i) the
direct expense paid to a third party (for example, reasonable legal expenses and consulting fees) to assist in enforcing the Policy would
exceed the amount to be recovered (following reasonable attempts by the Company Group to recover such Erroneously Awarded
Compensation, the documentation of such attempts, and the provision of such documentation to Nasdaq), (ii) pursuing such recovery
would violate the Company’s Home Country laws adopted prior to November 28, 2022 (provided that the Company obtains an opinion
of Home Country counsel acceptable to the Nasdaq that recovery would result in such a violation and provides such opinion to the
Nasdaq), or (iii) recovery would likely cause any otherwise tax-qualified retirement plan, under which benefits are broadly available to
employees of Company Group, to fail to meet the requirements of 26 U.S.C. 401(a)(13) or 26 U.S.C. 411(a) and regulations thereunder.

3. Means of Repayment

In the event that the Committee determines that any person shall repay any Erroneously Awarded Compensation, the Committee
shall provide written notice to such person by email or certified mail to the physical address on file with the Company Group for such
person, and the person shall satisfy such repayment in a manner and on such terms as required by the Committee, and the Company
Group shall be entitled to set off the repayment amount against any amount owed to the person by the Company Group, to require the
forfeiture of any award granted by the Company Group to the person, or to take any and all necessary actions to reasonably promptly
recoup the repayment amount from the person, in each case, to the fullest extent permitted under applicable law, including without
limitation, Section 409A of the Internal Revenue Code and the regulations and guidance thereunder. If the Committee does not specify
a repayment timing in the written notice described above, the applicable person shall be required to repay the Erroneously Awarded
Compensation to the Company Group by wire, cash or cashier’s check no later than thirty (30) days after receipt of such notice.

4. No Indemnification

No person shall be indemnified, insured or reimbursed by the Company Group in respect of any loss of compensation by such
person in accordance with this Policy, nor shall any person receive any advancement of expenses for disputes related to any loss of
compensation by such person in accordance with this Policy, and no person shall be paid or reimbursed by the Company Group for any
premiums paid by such person for any third-party insurance policy covering potential recovery obligations under this Policy. For this
purpose, “indemnification” includes any modification to current compensation arrangements or other means that would amount to de
facto indemnification (for example, providing the person a new cash award which would be cancelled to effect the recovery of any
Erroneously Awarded

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Compensation). In no event shall the Company Group be required to award any person an additional payment if any Restatement would
result in a higher incentive compensation payment.

5. Miscellaneous

This Policy generally will be administered and interpreted by the Committee, provided that the Board may, from time to time,
exercise discretion to administer and interpret this Policy, in which case, all references herein to “Committee” shall be deemed to refer
to the Board. Any determination by the Committee with respect to this Policy shall be final, conclusive and binding on all interested
parties. Any discretionary determinations of the Committee under this Policy, if any, need not be uniform with respect to all persons,
and may be made selectively amongst persons, whether or not such persons are similarly situated.

This Policy is intended to satisfy the requirements of Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection

Act, as it may be amended from time to time, and any related rules or regulations promulgated by the SEC or Nasdaq, including any
additional or new requirements that become effective after the Effective Date which upon effectiveness shall be deemed to
automatically amend this Policy to the extent necessary to comply with such additional or new requirements.

The provisions in this Policy are intended to be applied to the fullest extent of the law. To the extent that any provision of this Policy

is found to be unenforceable or invalid under any applicable law, such provision will be applied to the maximum extent permitted and
shall automatically be deemed amended in a manner consistent with its objectives to the extent necessary to conform to applicable law.
The invalidity or unenforceability of any provision of this Policy shall not affect the validity or enforceability of any other provision of
this Policy. Recoupment of Erroneously Awarded Compensation under this Policy is not dependent upon the Company Group satisfying
any conditions in this Policy, including any requirements to provide applicable documentation to Nasdaq.

The rights of the Company Group under this Policy to seek forfeiture or reimbursement are in addition to, and not in lieu of, any
rights of recoupment, or remedies or rights other than recoupment, that may be available to the Company Group pursuant to the terms
of any law, government regulation or stock exchange listing requirement, the Company’s Compensation Recoupment Policy or any
other policy, code of conduct, employee handbook, employment agreement, equity award agreement, or other plan or agreement of the
Company Group.

6. Amendment and Termination

To the extent permitted by, and in a manner consistent with applicable law, including SEC and Nasdaq rules, the Committee may

terminate, suspend or amend this Policy at any time in its discretion.

7. Successors

This Policy shall be binding and enforceable against all persons and their respective beneficiaries, heirs, executors, administrators or

other legal representatives with respect to any Covered Compensation granted, vested or paid to or administered by such persons or
entities.

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