Nasdaq Copenhagen A/S

Management's review

Financial HighlightsDKK'000 2023 2022 2021 2020 2019Key figuresRevenue 350,530 362,108 373,023 360,274 329,708Gross profit/(loss) 334,556 349,472 363,878 355,026 320,059Operating profit/(loss) 232,362 248,580 265,175 264,609 233,256Net financial income/(expense) 10,570 1,499 (99) (113) (123)Profit/(loss) for the year 189,900 195,247 207,398 206,659 182,072Total assets 343,249 362,316 383,628 408,087 344,317Investment in tangible fixed assets 88 724 275 77 119Equity 288,947 319,047 330,384 329,986 303,327RatiosGross profit margin (%) 95 97 98 99 97Operating profit margin (%) 66 69 71 73 71Net profit margin (%) 54 54 56 57 55Return on equity (%) 62 60 63 65 60Equity ratio (%) 84 88 86 81 88Gross profit margin (%) :Gross profit/(loss) for the year * 100RevenueOperating profit margin (%) :Operating profit/(loss) for the year * 100 RevenueNet profit margin (%) :Profit/(loss) for the year * 100 RevenueReturn on equity (%) : Profit/(loss) for the year * 100 Average equityEquity ratio (%) : Equity * 100 Total assetsDevelopment in activitiesTrading Services:There were 250 trading days on Nasdaq Copenhagen in 2023, which was two fewer trading days compared to 2022.Cash equity tradingThe Copenhagen all share index and market experienced continued uncertainty from 2022 and throughout 2023, as a result the ongoing market volatility, as well as the elevated level of inflation. Investor interest and volumes remained low throughout the year due to increased interest rate levels during 2023, which decreased both retail and institutional investors' risk appetite on the equity market. A strong rebound in prices was noted during the fourth quarter of 2023 with the Copenhagen All-Shares CAP index closing with an index price of 1,403.40 at the end of 2023, which is a year–over–year increase of 2.3%. The uncapped Copenhagen All-Shares Index grew in comparison by 16.8% in 2023, which can be primarily attributed to Novo Nordisk's share price development and increase in market capitalization during 2023. Nasdaq Copenhagen remains the second largest stock market in the Nordic region following Nasdaq Stockholm.Total On- & Off Exchange Share trading on Nasdaq Copenhagen (Turnover DKK & Nbr of Trades)2,000451,800401,600351,400301,2001,00025800206001540010200052012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023Large Cap Shares Mid Cap Shares Small Cap SharesOther shares Total Nbr of trades (all share segments)The total turnover in all Danish listed shares on Nasdaq Copenhagen was DKK 1,584 billion in 2023 vs DKK 1,689 billion in 2022, equivalent to a 6.2% decline. The total number of trades was 27.5 million in 2023, which was a decrease of 21.5% year-over-year in the total number of trades. During 2023, 98.7% of all listed Large-Cap shares was traded on Nasdaq Copenhagen, which was an increase of 1.2% compared to 2022. The trading in Large-Cap shares declined year-over-year by 5.1% resulting in a total turnover of DKK 1,564 billion. The Danish Mid-Cap shares turnover declined to DKK 16 billion, equivalent to a total decline of 57.1% year-over-year.As a consequence of different liquidity enhancing initiatives and the general market uncertainty, all Nasdaq Nordic primary markets noted an increase in both Lit, as well as Lit & Auction market share during 2023. Nasdaq Copenhagen's Lit & Auction market share increased year-over-year by 4.0% from 5.5% at the end of 2022 to 69.6% at the end of 2023. Nasdaq Copenhagen's Lit market share grew by 3.5 % to 57.9% at the end of 2023. Nasdaq Copenhagen total price forming market share capture in Danish shares was 48.7% at the end of 2023, which was a slight increase of 3.0% compared to 2022.Listing and trading in Exchange Traded Funds (ETFs)Nasdaq Copenhagen has a passive XACT OMXC25 tracker ETF listed and traded. The turnover and number of trades has decreased during 2023, with a total of 38,636 trades and DKK 2.05 billion in total turnover. The XACT C25 volumes declined year–over–year in terms of total numbers of trades by 27.8% in 2023, and with an equivalent decline of 13.6% in traded turnover. The listed DKK Market Cap (AUM) of XACT C25 increased year-over-year by 5.4 million DKK, equivalent to a 10.6% increase.The Danish Investment funds marketThe total Danish UCITS–ETF and AIF market on Nasdaq Copenhagen is continuously developing, with new issuers of active and passive managed funds entering the market. In 2023 a new issuer listed 4 new Investment Funds, with several other issuers listing, consolidating and delisting several funds resulting in a net inflow of one additional fund in 2023, compared to the end of 2022. At the end of 2023, Nasdaq Copenhagen had a total of 479 listed funds, with a total AUM of 513.4 DKK billion, equivalent to an increase of total listed AUM of 7.2% year-over-year.On–Exchange Order Book turnover declined in 2023 to DKK 57.1 billion, equivalent to a 28.9% decline compared to 2022. The total number of Order Book trades in 2023 was 944,433, equal to a 22.3% decline from 2022.The total Nasdaq Copenhagen On– & Off-Exchange trading activity (Order Book, as well as On- & Off-Exchange Reporting) was in total DKK 111.4 billion during 2023, equivalent to 1,117,744 trades. The Total Turnover on Nasdaq Copenhagen declined by 25.4% year-over-year and a decline of 22.3% in terms of total number of trades.Nasdaq Copenhagen listed UCITS-ETF & AIF funds Traded Turnover DKK & Nbr of Trades4002.502.253502.003001.752501.502001.251501.001000.75500.5000.252013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023On-Exchange - Order Book Turnover DKKOn-Exchange - Manual Trade reporting Turnover DKKOff-Exchange - OTC & SI Trade reporting Turnover DKK On-Exchange - Nbr of Order Book TradesTotal On- & Off Exchange number of tradesThe development in Danish Exchange Traded Products (ETPs)The total turnover in listed ETPs on Nasdaq Copenhagen was DKK 8.3 billion in 2023, which was a decline of 38.4% from the trading activity during 2022. The total number of trades in 2023 was 253,322, compared to 413,971 in 2022, a decline of 38.8%. The trend of declining trading activity in ETPs during 2023, was also noted outside of Denmark, due to the general decrease in retail investors' risk appetite for trading both equities, as well as leveraged exchange-traded products.Total On- & Off Exchange Share trading on Nasdaq Copenhagen (Turnover DKK & Nbr of Trades)18.055050016.045014.040012.035010.03008.02502006.01504.01002.0500.002013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023On-Exchange - Order Book Turnover DKKTotal On- & Off Exchange - Trade Reporting Turnover DKKTotal Nbr of Trades (On & Off Exchange)Fixed Income TradingThe total Fixed Income cash bond trading during 2023 amounted to DKK 4,193 billion which translates to a decrease of more than 18.8% compared to 2022. In 2022 the conversion activity in the Mortgage Bond market drove activities to an elevated level however, this activity decreased significantly in 2023 resulting in a decrease in turnover figures. At the end of 2023, a total number of 1,495 bonds are listed on Nasdaq Copenhagen. Nasdaq DKK Repo clearing business has experienced a decrease in the number of contracts, as a consequence of the above-mentioned drop in conversion activities in the mortgage market. By the end of 2023, there were 1,422,368 contracts compared to 1,744,583 contracts in 2022, resulting in a decrease of 18.5%. As a result of the increased interest rate levels during 2023, Nasdaq Copenhagen has experienced increased activity in the pricing and trading of bonds within our main market, compared to the insignificant activity during 2022.Data & Listing Services:Listing servicesDuring 2023, Nasdaq Copenhagen had 5 initial public offerings (IPO) which were listed on Nasdaq's Main Market. On the Main Market we listed Gubra, whose IPO raised EUR 67m, Asetek, Pharma Equity Group and Better Collective. Shape Robotics was transferred from Nasdaq First North to the Main Market. This is compared to 3 listings during 2022, of which 1 listing was on Nasdaq's First North Growth Market and 2 listings on the Main Market.As a result of the increased number of listings in 2023, capital raised to support newly listed companies' growth, raised from DKK 215 million in 2022 to DKK 500 million in 2023. During 2023 DKK 21.7 billion in capital was raised on Nasdaq Copenhagen Main Market, compared with 2.7 billion in 2022. During 2023 15 companies were delisted, 5 on Main Market and 10 on First North, compared to 5 companies that delisted during 2022.Market dataThe Nasdaq European Data Products business produces a wide variety of reliable, high-quality data products. These offerings include data from several asset classes including equities, bonds, derivatives, commodities for the Nordic & Baltic markets, precious metal information for the London and Zurich market, and ESG tools covering global equity and Fixed Income. Nasdaq offers its innovative market data products to professional and private investors worldwide to enable investors to have the essential tools to identify trends in the market and make qualified investment decisions. During 2023, we maintained, and continued to expand, our portfolio of ESG services and solutions for our clients and stakeholders, including: the Nasdaq Sustainable Bond Network, which connects issuers of sustainable bonds with investors, empowering them to evaluate potential impacts and make informed investment decisions. In addition, we launched a new pricing model for customers that choose to count subscribers by natural user, and launched a data product that delivers customer carbon removal index data from Puro.Earth. Surveillance:The overarching mission of the Surveillance function is to protect the integrity of Nasdaq marketplaces. Safeguarding the integrity of our markets is not only a regulatory requirement for Nasdaq, but also a necessity for fair and efficient trading and to support our business model. Surveillance work has involved training and education of new issuers and stakeholders. Surveillance has high focus on proactively having dialogue with market participants, including listed companies, advisors, trading members and other customers and clients. In 2023, Surveillance hosted 22 educational seminars and presentations with more than 600 participants. During 2023 a total of 10 disciplinary rulings were decided by the Copenhagen Disciplinary Committee.Environmental and Climate StrategyClimate change and resource scarcity are challenges to society and to business. As a responsible corporate citizen operating technology and exchange businesses across the globe, Nasdaq Copenhagen endeavors to lessen our environmental impact and make our operations efficient. We understand the importance of taking efforts to reduce our carbon footprint and actively promoting sustainable business operations. Nasdaq’s climate strategy aims to reduce our energy consumption, energy demand and corresponding greenhouse gas (GHG) emissions throughout our business operations and supply chain, as well as mitigate our corporate climate and biodiversity risk exposure. Our climate strategy is driven by two environmental programs: • Carbon net-zero program: By driving initiatives that are designed to optimize and reduce GHG emissions across Nasdaq’s business operations and supply chain, we aim to achieve our short-term and long-term net-zero science-based targets, which have been verified and approved by the Science Based Targets initiative (SBTi). • Carbon neutrality program: By calculating our annual carbon footprint, procuring 100% renewable electricity and investing in high-quality carbon offsets, Nasdaq strives to achieve carbon neutrality on our reported GHG emissions on an annual basis. Internally, the Global Green team brings together Nasdaq employees who are passionate about the environment, publishes internal knowledge-based resources, and works to drive sustainable initiatives through our local offices and communities. Nasdaq supports the Green Team’s commitment to creating positive change throughout the Company as we drive to achieve our longer-term net-zero goals.With respect to our business functions, we have a relatively small, manageable environmental impact due to the minimal use of natural resources in our global operations. We focus our environmental efforts on a few key areas, including the way we use resources, manage our workspaces, and conduct business travel. These efforts seek to lessen the environmental impact of our organization by reducing atmospheric carbon emissions, and managing water and waste associated with our business. Nasdaq Copenhagen conserves natural resources by leveraging innovation, technology, education, and a culture of continuous improvement.In 2023, Nasdaq, Inc., including Nasdaq Copenhagen, continued its carbon neutrality program for the sixth consecutive year and expects to retire its remaining carbon offsets for its 2023 GHG emissions by the end of the third quarter of 2024. The table below indicates our electricity consumption for 2023.Total Scope 2 Total Location-Total Scope 2 Total Energy Electricity Renewable % Based Market-Based Consumption Consumption Electricity RenewableEmissions ¹Emissions ²2023MWh/YearMWh/YearMWh/YearElectricity(MT CO2e)(MT CO2e)Denmark 221 40 40 100 % 36 33Total 221 40 40 100 % 36 33¹ According to GHG Protocol Scope 2 Guidance, location-based method quantifies Scope 2 GHG emissions based on average energy generation emission factors for defined locations, including local, subnational, or national boundaries. ² According to GHG Protocol Scope 2 Guidance, market-based method quantifies Scope 2 GHG emissions based on GHG emissions emitted by the generators from which the reporter contractually purchases electricity bundled with instruments, or unbundled instruments on their own.Nasdaq also encourages its suppliers to adopt sustainability and environmental practices in line with our Environmental Practices Statement and our Supplier Code of Ethics (“Supplier Code”). Suppliers must attest to our Supplier Code, confirming they have policies and practices consistent with our Environmental Practices Statement and to the extent they do not, will adhere to the applicable standards in our Supplier Code of Ethics. To the extent practical and feasible, suppliers provide us with information to support our reporting and transparency commitments related to sustainability and environmental impacts. ESG Products & ServicesNasdaq’s position at the intersection of markets and technology provides us with a unique perspective on the evolution of the ESG ecosystem. Our role offers compelling opportunities to support our clients as they navigate their own sustainability journeys through a suite of ESG-related solutions designed to minimize complexity and reduce friction. Our ESG-focused capabilities suite encompasses a wide range of marketplace, technology, data & analytics products and solutions that clients leverage as they develop, execute and advance their own ESG strategies and platforms. ESG Solutions for the Investor CommunitySustainable Debt MarketsThe Nasdaq Sustainable Debt Market lists green, social, sustainability and sustainability-linked bonds, structured products and commercial papers and is designed to highlight sustainable investment opportunities to investors with a green, social or sustainable investment focus. Nasdaq Sustainable Debt Market is open to all types of issuers that seek to issue securities that meet our listing criteria, which are based on the Green and Social Bond Principles as well as the Sustainability – Linked Bond Principles, for which the International Capital Markets Association (ICMA) acts as a secretariat. The number of sustainable debt instruments listed on Nasdaq grew by 12% during 2023 as compared to 2022 and the total listed outstanding sustainable debt volume grew by 28% as compared to 2022.31 December,31 December,20232022 Listings on the Sustainable Debt Market 529 471Issuers on the Sustainable Debt Market 145 129Sustainable Bond NetworkThe Nasdaq Sustainable Bond Network connects issuers of sustainable bonds with investors, empowering them to evaluate impact and make informed investment decisions on sustainable bonds. The platform allows issuers of sustainable bonds to make their sustainable bond data more accessible to investors and other stakeholders. Investors can use the platform to evaluate, track and create impact reports based on issuers’ ESG bond reporting. The database simplifies sustainable investing with an intuitive, easy-to-use solution that allows investors to discover, compile and compare sustainable bonds as well as generate impact reports. The platform also provides issuer-level information on UN Sustainable Development Goals allocation as well as EU Taxonomy.31 December,31 December,20232022 Issuers on the Nasdaq Sustainable Bond Network 1,721 1,550Bonds on the Nasdaq Sustainable Bond Network 16,295 14,222Green Equity DesignationsNasdaq launched Green Equity Designations on the Nordic markets in 2021 in response to increased demand for sustainable investments and extensive growth in Nasdaq Sustainable Bond Markets. With issuers and investors searching for more green performance indicators on the equity market, Green Equity Designations aim to enable visibility and transparency for investors with two voluntary designations, Nasdaq Green Equity Designation and Nasdaq Green Equity Transition Designation. Through these designations, Nasdaq can highlight environmentally sustainable companies or companies committed to transition to increase their visibility, transparency and credibility towards investors, business and other stakeholders. The Nasdaq Green Equity Designation is currently available for companies on the Nasdaq Nordic stock exchanges. As the financial ecosystem prepares for upcoming sustainability and climate-related regulations, Nasdaq sees increasing interest in green equity classification from companies and investors outside the Nasdaq Nordic exchanges. In March 2023, the World Federation of Exchanges (WFE) launched its classification standard for Green Equity with reference to the existing model from Nasdaq’s Green Equity Designation, highlighting Green Equity Designation’s importance in helping investors assess companies that are generating revenue from products and services that contribute to positive environmental outcomes.Nasdaq ESG Data Hub is a data solution, offering investors and other stakeholders' easy access to a wide range of unique and comprehensive ESG data sets, accompanied by detailed product descriptions, unique selling points and use cases. The platform enables users to find data sets relevant to specific UN Sustainable Development Goals (SDGs) as well as diversity and inclusion, sustainability and climate. This broad array of data provides investors with visibility on the ESG impacts of their investments.Nasdaq ESG Footprint offers a suite of data solutions which measure ESG performance at portfolio, fund and individual security level. This data enables investors and managers to better understand the real-world effects of their investments, report on sustainable finance regulations, align with leading international frameworks including the SDGs and build pioneering sustainability solutions. The data, provided by Matter, a sustainability analysis and reporting provider, is available via datasets, or using the intuitive portfolio analysis platform, allowing the user to generate ESG reports.ESG Solutions for the Corporate CommunityESG Advisory is a service solution that pairs companies with consultative ESG expertise to help analyze, assess and action best–practice ESG programs with the goals of attracting long–term capital and enhancing value. Services include ESG strategy development, Board engagement strategies, ESG investor engagement advice, and ESG reporting guidance for companies.Nasdaq Metrio is a SaaS-based, end-to-end sustainability reporting platform. It 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.Social and Employee ConditionsDiversity, Equity and InclusionThe company's most valuable asset is its people, and Nasdaq Copenhagen has made deliberate investments to ensure that it remains an employer of choice to attract, retain and develop top talent. A critical operational risk for Nasdaq Copenhagen relates to the inability of employees to perform tasks or processes due to a suboptimal work environment. Nasdaq Copenhagen strives to create a work environment in which individuals are empowered to establish their own work objectives, aligned with Nasdaq Copenhagen's overall business strategy and within the context of their area of discipline. Our compensation program includes annual grants of equity in Nasdaq for every employee to, encourage our employees to "act like an owner," reinforcing a shared sense of belonging and commitment to our collective success.The Diversity, Equity and Inclusion team continued Nasdaq’s training curriculum in 2023, offering courses such as Inclusive Leadership and Clifton Strengths Finder Training for Teams, which guide employees through common areas of interest, including enhancing emotional intelligence and effective utilization of talent. To support managers, Nasdaq offers Conscious Inclusion for Managers training and the Inclusive Leadership course, designed to drive awareness around opportunities for inclusion. Managers are also offered Empowering Inclusive Teams training focused on practical tips to drive a culture of engagement.Attracting and Retaining EmployeesOur people are the primary driver of our success. Nasdaq is committed to attracting top talent and retaining, developing and motivating our employees. In 2023, Nasdaq maintained our historical levels of employee retention. We are actively working to establish Nasdaq Copenhagen as a destination employer, having created a dedicated Talent Attraction team and establishing key partnerships to attract talent across all markets in which we operate. We seek to hire locally wherever possible, for all levels of individual contributor, manager and executive. Additionally, we introduced new hire and employee exit surveys to better understand why employees join, and leave, Nasdaq. The table below summarizes our 2023 and 2022 new hire and turnover data for all global operations, age groups, and employee categories.Workforce Attrition (Denmark)1,2• 2022: 7% 1,2• 2023: 7% 1 The Nasdaq Group enterprise average rate was 11% for 2022 and 7% for 2023.2 This number combines 5% (7%) voluntary attrition and 2% (0%) involuntary attrition.Growth and AdvancementNasdaq Copenhagen's Performance Management program was established to enhance the job performance and professional growth of each employee. Under this program, every employee is asked to create a professional development plan for themselves each year, in concert with their manager, and record this plan in our HR software. In 2023, we continued to assess the current state of our talent, define the skills needed to achieve our strategic goals, set performance objectives to measure individual growth, provide opportunities for skills development and utilize the process to advance talent equitably. In order to identify our talent needs, Nasdaq makes extensive use of people analytics data in the following areas: measuring employee performance, strategic workforce planning, identifying flight risks and critical roles, and uncovering individual as well as organizational skills gaps. The Career Hub (part of our enterprise Human Resources technology platform) provides AI-enabled, customized career development recommendations and planning resources for every employee. It also provides recommendations for training programs, mentors, informal networking and short-term gigs via the Talent Marketplace where employees can find project opportunities outside of their day-to-day roles to develop their skills directly and encourage mobility through visibility of internal open job requisitions.In addition to providing mechanisms for ongoing feedback throughout the year, managers informally assess his or her employees during the mid–year period and complete a formal year–end performance review by the end of each calendar year. Managers incorporate a multi-dimensional review process of getting feedback on an employee’s performance from peers, direct reports, or others who interact with them regularly. The employee’s performance review aims to ensure that they clearly understand what is expected by their manager and that their activities align to their respective business division goals. The review also helps inform each employee what knowledge and skills they must acquire or improve to grow in the present job, move into a lateral role or advance at Nasdaq.Training and EducationNasdaq Copenhagen supports the development of its employees through each important transition in their careers – as new entrants to the organization, as developing professionals, as managers of teams and people and as leaders who lead the global organization.We have invested heavily in professional development for our employees, creating a dedicated Career Development internal website that serves as a central point for dozens of career resources. These Nasdaq resources include offering access to professional in–person and online employee development programs and job–specific training, providing tuition assistance to employees enrolled in degree–granting academic programs, holding internal career fairs and career networking programs, providing one–on–one mentoring, and access to professional coaching opportunities.In 2023, we continued developmental programs for employees, including executive mentoring. We also continued our key leadership development programs to enhance accelerated growth and career advancement opportunities. We launched our flagship High Potential program, LEAD (Lead, Enrich, Access & Develop), which focuses on preparing mid-level managers for future leadership roles through a curriculum based on building business acumen, leadership skills, peer networking, senior leader mentorship and job shadowing opportunities. Over the six-month period, we had 56 full-time employees participate in LEAD out of over 200 nominees. We surveyed LEAD participants pre- and post-program to understand their strengths and areas of opportunity. We also expanded our Emerging Leaders Program, which provides early to mid-level employees access to executive coaching and individual professional development.Human RightsNasdaq supports fundamental human rights–both inside and outside our company–and demonstrates its commitment by enacting responsible workplace practices across our global enterprise. Nasdaq believes in the fundamental dignity of every human being and the rights of every individual to live and work safely and humanely, without fear of oppression or coercion.A risk for human rights relates to supply chains which are complex, continually evolving and global human rights conditions change which requires continued vigilant human rights due diligence. Our Vision, Mission and Values Statements, along with our Code of Ethics and Employee Handbooks, emphasize responsibility, integrity, and values–based decision–making and set forth our standards for conducting our business ethically and consistent with our moral principles.These principles and standards shape our interactions with fellow employees, clients, suppliers, communities, and markets around the world–and with our community of shareholders, too. They are foundational to our company and enable our continued success. Nasdaq, Inc. has incorporated within its Code of Ethics, corporate policies, or programs specific requirements to put the following principles into practice:• Equal Employment Opportunity and Discrimination• Harassment• Non–Retaliation• Diversity and Inclusion• Data Privacy• Health and Safety• Labor StandardsWe provide training and promote effective employee communication related to these topics, including through town halls and topic specific webinars. We plan to continuously evaluate processes and technologies that could enable us to enhance our current risk-monitoring capabilities in the future. We acknowledge the responsibility to respect human rights as outlined in the UNGP. In 2023 and 2022, no direct adverse impacts on human rights were identified/detected.Business Ethics and ComplianceThe Nasdaq Ethics and Compliance program is designed to meet or exceed available standards, including guidelines by European regulators. Nasdaq Copenhagen embraces good governance by holding ourselves to the highest ethical standards in all interactions. Our Global Ethics Program supports and promotes meaningful implementation of the Code of Ethics throughout our business. In 2023, we furthered the use of automation and analytics in supporting compliance programs to drive effectiveness and reduce risk. Additionally, we aim to enhance employee training programs through additional focus on targeted topics.Our Global Employee Ethics Program is based on industry-leading practices and led by our Chief Legal, Regulatory & Risk Officer and is supported by a cross-functional, geographically diverse team, with oversight by Nasdaq's Audit & Risk Committee of the Board of Directors (the "Audit & Risk Committee"). External compliance experts are also regularly consulted. This Program provides values-based guidance, heightens compliance risk awareness, strengthens decision-making and drives sound business performance through five pillars: Executive and Board Leadership; Policies, Procedures and Controls; Risk Assessment; Outreach and Training; and Monitoring, Audit and Response. Nasdaq leaders strive to create an ethical culture in which employees understand our commitment to integrity as foundational to our Purpose, Vision, Mission and Values, and feel comfortable raising issues or concerns without fear of retaliation. Managers encourage ethical conduct and compliance with the law by modeling integrity and personally leading ethics and compliance efforts; including cyber and information security, when evaluating and rewarding employees; and ensuring employees understand that business results are never more important than ethical conduct and compliance with Nasdaq policies and the law.The Nasdaq Code of Ethics and related policies are applicable to all of Nasdaq’s officers, directors, employees and other associates in conducting business in accordance with the highest standards of ethics and compliance. Our Code of Ethics and related policies outline requirements related to our ethical standards, conflicts of interest, employee trading activities, personal securities trading activities, self-regulatory organization responsibilities, regulatory transparency, whistleblowing responsibilities and protections, antitrust laws, anti-bribery and corruption controls, privacy, data security, sanctions, and trade control laws. Nasdaq also embeds its commitment to governance transparency, integrity and ethical values business practices in a series of robust policy documents, all freely available for download on our ESG Resource Center at https://www.nasdaq.com/esg/resource-center. During 2023 and 2022 no breaches to our ethical values were reported/identified.Anti–corruptionThere are corporate risks related to violations of rules and laws governing corruption, bribery and similar unlawful activities. Companies risk losing their license to operate, could face exposure and punishment by market forces, and be subject to potential prosecution and imprisonment for the individuals involved.We face risks related to compliance with economic sanctions, export controls, corruption and money laundering. 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.Nasdaq Group and Nasdaq Copenhagen seeks to comply with Foreign Corrupt Practices Act (FCPA), UK Bribery Act, and other anti–bribery and anti-corruption laws, including reviewing "red flags" for corruption and situations where extra diligence must be exercised. Nasdaq Copenhagen regularly evaluates the efficacy of its operation, impact, products and services in order to increase positive outcomes and decrease negative outcomes. Nasdaq's Supplier Code outlines our expectations for Business Partners including those expectations related to bribery and corruption. The following three main risks and mitigating actions have been defined:• Unlawful Gifts or Inducements to Government Officials: Under Nasdaq's Code of Ethics and its Gifts, Business–Related Events & Anti–Bribery and Corruption Policy, the company has a zero–tolerance policy towards corruption.• Improper Gifts or Inducements to Commercial Counterparties: Nasdaq Denmark staff are prohibited from giving gifts in exchange for favorable treatment, that violate contractual agreements with counterparties or that are contrary to corporate policies applicable to the recipient.• Engagement of Suppliers and Third–Party Representatives: No Nasdaq Denmark employee may authorize any third party to engage in conduct that the Nasdaq Denmark employee could not do his/herself. To protect against this risk, all Nasdaq Denmark vendors are screened for corruption risk prior to engagement and continuously monitored for corruption issues during the period of their work for the company.Raising concerns about potential violations of these Codes or other policies is critical to protecting individual and company interests and upholding our commitment to act with integrity. All Nasdaq employees, contractors and third parties doing business with Nasdaq have multiple channels for raising ethics and compliance concerns or allegations of misconduct. These channels include directly contacting our Global Ethics Team through dedicated communications channels and reporting through our SpeakUp! Line. The SpeakUp! Line is operated by a third–party hotline provider that enables Nasdaq to communicate with an individual reporting an issue on an anonymous basis. In addition to the SpeakUp! Program, individuals can directly and confidentially contact our Audit & Risk Committee Chair via email or mail. During 2023 and 2022, no potential violations were reported/identified.Anti–Financial Crime and Money LaunderingNasdaq Copenhagen is deeply committed to ensuring that markets operate fairly and do not facilitate financial crime including money laundering and terrorism financing. Nasdaq’s Code of Ethics, Trade Controls and Sanctions Compliance Policy and Global Anti-Money Laundering (AML) Policy, as well as applicable regional policies require compliance with all AML laws and regulations that apply to our business. For covered operations, this includes conducting any required know–your–customer (KYC) diligence, monitoring transactions, and reporting suspicious activities. Members of Nasdaq's exchanges are required to have in place AML and other diligence programs to screen their clients and market participants in accordance with the applicable US and EU laws and regulations. Nasdaq is committed to detecting and deterring money laundering and terrorism financing at the onset of a business relationship, as well as throughout its duration.Across our global enterprise, Nasdaq has implemented comprehensive policies and screening programs to enable compliance with economic sanctions that apply to its business. This includes screening all customers, vendors and other business partners against applicable sanctions lists such as those published by the United Nations, US Department of Treasury, Office of Foreign Assets Control, the European Union and the United Kingdom along with other jurisdictions where Nasdaq operates. Nasdaq has appointed senior level employees to oversee its sanctions compliance program and reviews its sanction compliance policy annually with the Board of Directors. In 2023, Nasdaq delivered mandatory high-level sanctions and AML compliance training to all of its employees.In operating our markets, Nasdaq maintains robust surveillance teams that monitor our markets for potential suspicious trading activity and compliance with our market rules. Our surveillance teams use sophisticated software that leverages models and analytics to identify suspected risks, which are then escalated and reviewed. Nasdaq cooperates with the U.S. SEC, financial supervisory authorities, Financial Industry Regulatory Authority, The European Securities and Markets Authority and other exchanges to address suspected violations, to deter, identify and prosecute unlawful activity affecting the securities market. Nasdaq also licenses its technology to regulators and financial firms to help them monitor their markets and activity.  Nasdaq believes it is important for our employees to stay informed regarding the latest developments in anti–financial crime and money laundering and provides regular updates and training sessions on this topic. Under this global program, vendor payments and employee expense reimbursements are reviewed on a monthly basis with a risk–based sample audited. As validated by this testing, Nasdaq Copenhagen has not identified any transactions that violate applicable corruption laws during 2023 and 2022.Information and Cyber SecurityThe Information Security Department is responsible for coordinating the protection of the Nasdaq Group's core business operations and information against real–world cyber threats, by employing technology, policy, processes, education programs, and sound design techniques across the organization. Nasdaq’s Chief Information Security Officer (CISO) who reports directly to Nasdaq’s Chief Information Officer within Nasdaq’s centralized Global Technology organization manages the Information Security Department (ISD). The ISD team is responsible for:   • Performing and coordinating security assessments and vulnerability scans of Nasdaq’s internal, external and third-party applications; • Implementing and maintaining Nasdaq’s various information security-related policies and standards;• Middleware and vulnerability management in addition to special projects as designated by the CISO;• Nasdaq’s compliance efforts for European and UK General Data Privacy Regulation (GDPR) and all supporting data privacy and protection efforts; • Configuring Nasdaq Group infrastructure and the applications running thereon in accordance with Nasdaq’s configurations policies, processes and standards;• Development of internal tools and solutions to drive efficiency and enhance monitoring and visibility through operational metrics and compliance; • Operating Nasdaq’s Global Security Operations Center (GSOC), which monitors security event logs, 24/7/365, from Nasdaq networks, systems, applications and databases and creates log files of known and unknown events; and• Monitoring threats against Nasdaq, its technology stack and its peer organizations, and providing recommendations for securing potentially vulnerable populations at Nasdaq in the context of emerging threats. On an annual basis, the Information Security team reviews and updates its governance documents, such as 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.  Our Audit & Risk Committee receives quarterly reports, as well as additional reports as needed, on cybersecurity and information security matters from our Chief Information Security Officer. This regular reporting to the Audit & Risk Committee includes a cybersecurity dashboard that contains information on cybersecurity controls and from time to time also includes information on projects to strengthen internal cybersecurity, ongoing prevention and mitigation efforts, security features of the products and services we provide our customers, or security events during the period. The 2023-2025 Cybersecurity Strategic Plan, was reviewed and approved by the Audit & Risk Committee in June 2023. The team has established specific projects with assigned owners associated with each goal outlined in the Cybersecurity Strategic Plan. Projects will be executed from 2023 through 2025. The Nasdaq Information Security Management System (ISMS) that governs the global enterprise infrastructure and supports key global information security processes and includes technology, personnel, locations and data centers, conforms to ISO 27001 requirements and is ISO 27001 certified. The processes in scope for the Nasdaq ISO 27001 certification include: Access Management, Human Resources, Product Development Lifecycle (PDLC), Change Management, Supplier Risk Management, Configuration/Build Management, Asset Management, Incident Management, Physical Security, Security Operations, Risk Assessment, Internal Audit, Disaster Recovery, Scanning, Backup/Restore and Application Security. Nasdaq personnel corporate equipment and connectivity to the production infrastructure are also in scope. Additionally, certain Nasdaq products undergo an annual SOC 2 Type II audit. The final reports are made available to customers under non-disclosure agreements.Nasdaq and its affiliates require employees to annually take Security Awareness Training annually. Nasdaq's Security Awareness Training is created in-house by the Information Security Department. New employees are provided an Information Security training as part of their onboarding and complete a quiz to validate their understanding of Nasdaq’s security protocols. New employees must review Nasdaq’s Information Security Policies and assert compliance with such Policies by signing the Information Services Agreement form. Additional training activities carried out during the year include monthly simulated spear-phishing (email) attacks. Role-based security training is provided for Nasdaq and its affiliates developers and Information Security staff in line with industry best practices via our secure coding training program. Nasdaq hosts various cybersecurity awareness events throughout the month of October to celebrate Cybersecurity Awareness Month.

Description of significant activities of entity

Main activityThe main purpose for Nasdaq Copenhagen is to provide an effective and transparent exchange infrastructure for issuers, members and investors. The company primarily generates income from two main areas: trading services and data & listing services. Nasdaq Copenhagen also provides services to other entities within the Nasdaq Group.