Conflicts of Interest

Receipt of Gifts

Corporate Opportunities

Confidential Information

Reporting Illegal or Unethical Behavior

Enforcement of the Ethics Code

Waivers of the Ethics Code

Relationship to Other CME Policies, Procedures and Guidelines

The Board of Directors of CME Group Inc. ("CME Group") is committed to the highest standards of conduct in our relationships with CME Group employees, customers, members, shareholders, regulators and the public. This means conducting our business in accordance with all applicable laws and regulations, and it also means commitment to the spirit of the law. Our actions should reflect CME Group's values, demonstrate ethical leadership, and promote a work environment that upholds CME Group's reputation for integrity, ethical conduct and trust. This Code is intended to provide a statement of the fundamental principles applicable to our directors.

Directors are encouraged to bring questions about particular circumstances that may involve one or more of the provisions of this Code to the Chairman of the Board or the Chairman of the Governance Committee, who may consult with legal counsel. Directors who also serve as officers of CME Group must also comply with the CME Group Employee Code of Conduct.

Conflicts of Interest

In order to maintain the highest degree of integrity in the conduct of CME Group's business and to maintain your independent judgment, directors must avoid any activity or personal interest that creates or appears to create a conflict between a director's own interests and the interests of CME Group as determined by CME Group. It is to be understood that a director may be a member, officer or owner of a member firm or a customer of Chicago Mercantile Exchange Inc., or Board of Trade of the City of Chicago, Inc. or the New York Mercantile Exchange Inc., without creating a conflict or the appearance of a conflict. A conflict of interest arises when a director's loyalties or interests are divided between CME Group's best interest and his or her personal interests or those of another. Conflicts of interest may also arise when a director, or members of his or her family, or an organization with which he or she is affiliated receives an improper personal benefit as a result of his or her position as a director of CME Group. Certain situations are so likely to create the appearance of a conflict of interest that they must be avoided. For example, a director may not accept employment with, accept an interest in or purchase an interest in any enterprise that is negotiating or is likely to negotiate any business relationship with CME Group, without the prior consent of the Governance Committee. Additionally, a director may not accept employment with or provide consulting services to an equity or derivatives exchange, other than an exchange owned by CME Group, without the prior consent of the Governance Committee.

Any situation that involves, or may involve, a conflict of interest should be promptly disclosed to the General Counsel. The Board of Directors has adopted the CME Group Conflict of Interest Policy to provide additional guidance as to when a specific situation may involve a conflict of interest and the appropriate procedures for resolving that conflict.

Receipt of Gifts

The purpose of business entertainment and gifts in a commercial setting is to create goodwill and sound working relationships. Therefore, directors and members of their immediate families may accept unsolicited business courtesies and gifts that are reasonable and customary. Directors and members of their immediate families, however, may not accept gifts from persons or entities where any such gift is being made in order to influence the director's actions as a member of the Board, or where such gift could create the appearance of such influence. For these purposes, a gift shall include compensation or other award for services where such compensation or award is disproportionate to the services rendered.

Corporate Opportunities

Directors are prohibited from competing with CME Group or taking for themselves personally or for the organizations with which they are affiliated opportunities that are discovered through the use of CME Group property, information or position without the consent of the Board of Directors. No director may use CME Group property, information or position for improper personal gain. Directors owe a duty to CME Group to advance its legitimate interests when the opportunity to do so arises.

Confidential Information

Board members may often receive or have access to confidential, sensitive and non-public information about CME Group and others. Board members should presume that any information they receive about CME Group or about CME Group's customers, members or others through their work as a Board member is confidential and, therefore, should not be disclosed or made public, except when disclosure is authorized or legally required. Board members have an obligation to safeguard confidential information, whether generated internally or acquired from others, and to use it only in the performance of their responsibilities as a Board member. The obligation to preserve CME Group's confidential information is ongoing even after an individual's service as a director ends.

Reporting Illegal or Unethical Behavior

Directors should promote ethical behavior and encourage an environment in which CME Group encourages employees to talk to supervisors, managers or other appropriate personnel about illegal or unethical behavior. CME Group has established avenues of communication to enable employees or others to report suspected misconduct, including CME Group's Compliance & Ethics Helpline (1.877.338.4545). No one will be subject to retaliation for a good faith report of suspected misconduct. Directors should communicate any suspected violations of this Code promptly to the Chairman of the Board or the Chairman of the Governance Committee.

Enforcement of the Ethics Code

The Governance Committee of the Board of Directors shall determine appropriate actions to be taken in the event of violations of this Code of Ethics. Such actions shall be reasonably designed to deter wrongdoing and to promote accountability for adherence to the Code. In determining what action is appropriate in a particular case, the Governance Committee shall take into account all relevant information, including the nature and severity of the violation, whether the violation appears to have been intentional or inadvertent, and whether the individual in question had been advised prior to the violation as to the proper course of action.

Waivers of the Ethics Code

CME Group will waive application of the policies set forth in this Code only where circumstances warrant granting a waiver. Waivers of the Code for Board members may be made only by the Governance Committee of the Board of Directors and will be promptly disclosed as required by law or regulation.

Relationship to Other CME Policies, Procedures and Guidelines

The responsibilities described in this Code are in addition to and not instead of, any responsibilities described in any other CME Group policy, procedures or guidelines that apply to you.

Revised as of December 3, 2008