Implementing a new code of business conduct

We completed a comprehensive, 12-month process of assessing and updating our code of conduct. The result? A fully revised, comprehensive corporate code of conduct we call The Qualcomm Way: Our Code of Business Conduct.

By unequivocally describing obligations under the law as well as our responsibilities to our Company, our stockholders and our communities, The Qualcomm Way: Our Code of Business Conduct helps all of us navigate the ethical and legal landscape of our business. It makes our values and ethical boundaries clear and provides reporting instructions for employees, suppliers and any Qualcomm stakeholders who have concerns about ethical matters within our Company. All employees are required to acknowledge Our Code of Business Conduct online, through a compelling presentation designed to help them better understand the content. We also encourage employees to refer regularly to The Qualcomm Way: Our Code of Business Conduct as a tool to help them do their jobs day to day.

Every year, our internal audit department evaluates 100 percent of our business units for risks related to corruption. We also assess additional areas on a case-by-case basis. All employees in positions where corruption may be a risk are required to regularly review and certify compliance with our anticorruption policies. Due in large part to this practice, there has never been any legal case for corruption brought against our employees or our Company.

One hundred percent of our business units are evaluated for risks related to corruption.

It is our policy to comply with anticorruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), other applicable U.S. laws and the anticorruption laws and regulations of the countries where we do business. It is also our policy to obey all laws, including those that regulate our conduct in the marketing of our products, services and technologies in the international marketplace.

We expect employees, agents, consultants and representatives deemed relevant to anticorruption concerns and FCPA-type risks to review, understand and follow our FCPA policy. These individuals annually certify that they understand our policy and are not aware of any violations of it. In the most recent certification process, we identified active employees who might expose Qualcomm to FCPA-type risks—about 40 percent of our workforce. Of those employees, 99.7 percent certified their compliance with the policy.

We’re committed to protecting the privacy and personal information of the consumers who benefit from our innovations. Respect for privacy helps us maintain the trust of our business partners and customers, distinguishes our products and services in the marketplace and helps ensure legal compliance.

A cross-divisional privacy steering committee helps set our privacy policy. Due in part to this team’s work, we did not receive any substantiated complaints regarding breaches of customer privacy or data in 2010 or in the two years prior.