Intercontinental Exchange Inc

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