Intercontinental Exchange, Inc.

Rating Overview

Intercontinental Exchange, Inc. is Medium Risk.

Intercontinental Exchange, Inc. is Medium Risk. The company often yields to political activism in shaping corporate governance, potentially alienating consumers, dividing employees, and harming shareholders. The company implements race and identity-based policies that replace merit, excellence, and integrity with preferential treatment and outcomes. The company occasionally embraces corporate initiatives that redirect its central focus from business goals to partisan policies and divisive issues at times. This approach fails to safeguard free exercise, free speech, and free enterprise.

Rating Criteria

Corporate Weaponization Risk Levels
Criteria	Risk Level
Cancellations	Medium Risk
Discriminatory Philanthropy	Lower Risk
Employment Protection	High Risk

Corporate Weaponization ⓘ

Corporate Governance and Public Policy Risk Levels
Criteria	Risk Level
Advocacy Bias	High Risk
Funding	Lower Risk
Political Actions	Lower Risk

Corporate Governance and Public Policy ⓘ

Rating Criteria Detail

Criteria Risk Level Rationale

Corporate Weaponization

Criteria:

Has canceled customers, suppliers, or vendors due to their political views or religious beliefs OR corporately boycotts, divests, or sanctions regions, people groups, or industries.

Risk Level:

Medium

Rationale:

Intercontinental integrates ESG into its business practices. From its 2024 Proxy Statement: “Our ESG strategy is guided by an ESG Governance Committee made up of senior officials from across the company” (1). However, Intercontinental has not canceled customers, suppliers, or vendors based on political views or religious beliefs (2).

Criteria:

Charitable giving (including employee matching programs) policies or practices discriminate against charitable organizations based on views or religious beliefs.

Risk Level:

Lower

Rationale:

Intercontinental does not discriminate against charitable organizations based on views or beliefs (1).

Criteria:

Employment policies fail to protect against viewpoint or other discrimination and/or are ideological in nature.

Risk Level:

High

Rationale:

Intercontinental offers DEI training to its hiring managers (1). Intercontinental appears to prioritize diversity over merit in its promotions. From its 2024 Proxy Statement: “continue including at least two diverse candidates when interviewing for any open officer position” (2). Intercontinental is an affirmative action employer. “As ICE’s Chief Executive Officer, I reaffirm that the above policy and the Affirmative Action Program executed simultaneously herewith reflect the Company’s attitude” (3). Intercontinental does not provide viewpoint protections for its employees (4).

Corporate Governance and Public Policy

Criteria:

Uses corporate reputation to support causes, organizations, or policies hostile to freedom of expression.

Risk Level:

High

Rationale:

Intercontinental supports DEI within its business practices. From its 2024 Proxy Statement: “Our Nominating & Corporate Governance Committee considers a number of demographics including, but not limited to, race, gender, ethnicity, culture and nationality in seeking to develop a board that, as a whole, reflects diverse viewpoints” (1). Intercontinental supports ESG within its business practices. From its 2024 Proxy Statement: “Our ESG strategy is guided by an ESG Governance Committee made up of senior officials from across the company” (2).

Criteria:

Uses corporate funds to advance ideological causes, organizations, or policies hostile to freedom of expression.

Risk Level:

Lower

Rationale:

Intercontinental has not used corporate funds to advance ideological causes, organizations, or policies (1).

Criteria:

Uses corporate political actions and/or financial contributions for ideological, non-business purposes.

Risk Level:

Lower

Rationale:

Intercontinental has not used its PAC donations for ideological purposes and does not engage in lobbying at this time (1)(2)(3).