Whistleblower Complaint Policy and Procedures

Statement of Support and Protection for Whistleblowers

NYMEX Holdings, Inc., and its subsidiaries (the “Company”) fully supports ethical conduct, compliance with all applicable laws, and transparency and accountability in business practices. The Company encourages any person, including employees, consultants, or vendors, to make a good faith complaint regarding a violation or potential violation of accounting standards, internal accounting controls, or audit standards, and of other laws prohibiting fraud, as described in detail below, (this is sometimes referred to as “blowing the whistle” or “acting as a whistleblower”), no matter whom it involves, without fear of retaliation due to such reporting.

Scope of Matters Covered by This Policy

1. Accounting, Internal Accounting Controls, or Auditing Matters

Consistent with Section 301 of the Sarbanes-Oxley Act of 2002 (the “Act”), the Company’s Audit Committee has established the procedures described below for (a) the receipt, retention and treatment of complaints, reports and concerns regarding accounting, internal accounting controls or auditing matters; and (b) the confidential, anonymous submission of complaints, reports and concerns regarding questionable accounting, internal accounting controls or auditing matters.

These reporting procedures apply to complaints about questionable accounting, internal accounting controls or auditing matters, including but not limited to, fraud or error in the preparation, evaluation, review or audit of any financial statement of the Company, or deficiencies in, or noncompliance with, the Company's internal accounting controls.

2. Violations of Other Laws

Consistent with Section 806 of the Act, the Company prohibits retaliation against an employee for acting in good faith to provide information, or otherwise assist in an investigation, regarding an alleged violation of laws prohibiting mail fraud, wire fraud, bank fraud, securities fraud, rules or regulations of the Securities and Exchange Commission, or federal laws relating to fraud against shareholders.

These reporting procedures apply to complaints about alleged violations of laws prohibiting mail fraud, wire fraud, bank fraud, securities fraud, rules or regulations of the Securities and Exchange Commission, or federal laws relating to fraud against shareholders.

Receipt of Complaints

Any person may make a good faith complaint regarding the matters described above without fear of dismissal or retaliation, on a confidential or anonymous basis. Making a complaint on a confidential basis means that you identify yourself to the Audit Committee, but you request that your identity be kept confidential. Making a complaint on an anonymous basis means that you do not identify yourself to the Audit Committee.

Complaints are to be made to the Chairman of the Audit Committee of the Board of Directors, by contacting him through any of the following three methods: (1) the toll-free NYMEX Whistleblower Hotline at 1-800-477-1860; (2) by mail to PO Box 3390 Church Street Station, New York, NY 10008; or (3) by sending an e-mail to the following independent address: nymerc_fintegrity@yahoo.com.

Treatment of Complaints

The Chairman of the Audit Committee will monitor the email address, the toll-free hotline and the PO Box listed above, and will make a determination as to whether the complaint pertains to violations of accounting, internal accounting controls or auditing matters. Complaints relating to accounting, internal accounting controls or auditing matters will be reviewed under Audit Committee oversight. The Audit Committee will oversee the communication, evaluation, investigation, and any corrective action required pursuant to the results of its investigation.

Complaints relating to other matters may be referred to the Company's general counsel or to other parties, as determined by the Audit Committee, for prompt and appropriate action.

The Company will, to the extent it is able, and consistent with its legal responsibilities, maintain the anonymity or confidentiality, as the case may be, of the persons submitting complaints in accordance with this Policy.

In accordance with federal law, the Company prohibits retaliation against anyone as a result of his or her good faith complaint pursuant to this Policy. Therefore, even if the identity of a person submitting complaints in accordance with this Policy is revealed, such person cannot be retaliated against due to having filed such a complaint. Any person who is concerned that he or she has been, or is likely to be, retaliated against as a result of his or her submission of a good faith complaint pursuant to this Policy, should report such concern to the Audit Committee, using the same procedures described above.

Document Retention Policy

The Company will retain related documents for a period of at least seven (7) years from receipt of the complaint.

Amendments

The Audit Committee may amend these procedures at any time, consistent with requirements of applicable laws, rules and regulations.

Questions About This Policy

Any questions about this Policy should be addressed to the Office of Corporate Governance, at 212-299-2211, or to the General Counsel, at 212-299-2200.

Revised Effective December 1, 2004