NASDAQ - 1792 Exchange

Rating Overview

NASDAQ is Medium Risk.

NASDAQ 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. NASDAQ 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	High Risk
Employment Protection	High Risk

Corporate Weaponization ⓘ

Corporate Governance and Public Policy Risk Levels
Criteria	Risk Level
Advocacy Bias	High Risk
Funding	High 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:

NASDAQ received a score of 85 on the 2025 Corporate Equality Index (CEI) from the Human Rights Campaign (HRC), a political stakeholder group. The company recruits employees based on sexual identity issues. The company discriminates against vendors that do not promote divisive sex and gender policies, indicating it prioritizes sexual issues over merit (1)(2). The company integrates ESG into all of its business practices and tied senior leadership’s compensation to its DE&I goals (3). NASDAQ is a signatory of the Principles for Responsible Investment, incorporating ESG issues into investment analysis, decision-making, and other business practices (4)(5). However, the company has not publicly canceled customers, suppliers, or vendors based on political views or religious beliefs.

Criteria:

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

Risk Level:

High

Rationale:

NASDAQ‘s HRC 2025 CEI rating indicates the company will not donate to non-religious charities unless they embrace controversial sexual identity policies (1)(2). NASDAQ Foundation does not appear to discriminate against charitable organizations based on views or beliefs (3).

Criteria:

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

Risk Level:

High

Rationale:

NASDAQ‘s HRC 2025 CEI rating indicates the company forces employees to attend multiple, controversial trainings on gender identity, sexual orientation, transgender issues, and divisive racial ideology. The company provides gender transition guidelines for its employees and a specific benefits guide with a comprehensive explanation of transgender services funded by the company (1)(2). Nasdaq “launched Conscious Inclusion and Inclusive Leadership training classes for all employees” and mandates diversity training for all its managers (3)(4). The company does not provide viewpoint protections for its employees (5).

Corporate Governance and Public Policy

Criteria:

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

Risk Level:

High

Rationale:

NASDAQ’s CEO Adena Friedman is a member of the Business Roundtable and signed the Business Roundtable’s 2019 Statement on the Purpose of a Corporation, which promotes stakeholder capitalism over traditional obligations to shareholders (1)(2). NASDAQ hosts an annual LGBTQ Leadership Conference which focuses on the experiences and advice from the LGBTQ+ community (3)(4)(5). The company signed an open letter endorsing the Equality Act, a contentious proposal to amend the 1964 Civil Rights Act by adding sexual orientation and so-called gender identity as protected categories. The legislation would, among other implications, grant biological men access to women-only spaces such as sports teams and public restrooms, and compel healthcare providers to deliver sex-denying healthcare (6). In August 2021, NASDAQ passed a Board Diversity Rule requiring listed companies on its stock exchange to have at least two diverse board members or explain their failure to do so. The rule also required companies to publish statistics on the diversity of their board members. This rule was overturned in December 2024 (7)(8). The company announced that it will match the government’s $1,000 contributions to Trump Accounts for the children of its employees (9)(10).

Criteria:

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

Risk Level:

High

Rationale:

NASDAQ‘s HRC 2025 CEI rating indicates the company covers transgender related costs for its employees and their children, including paid short-term leave, puberty blockers, cross-sex hormones, chest surgeries, genital surgeries, medical visits and lab monitoring, travel and lodging. By allowing a political stakeholder group to dictate operations, the company increases health care costs and risks dividing employees, alienating customers and harming shareholders (1)(2). The company donated to VC Include for training of women, BIPOC, and LGBTQ to teach investment into underrepresented groups (3). NASDAQ is a corporate partner of the NGLCC and the Black Equity Index which measures racial equality in the workplace (4)(5).