Effective October 1, 2012, QUALCOMM Incorporated completed a corporate reorganization in which the assets of certain of its businesses and groups, as well as the stock of certain of its direct and indirect subsidiaries, were contributed to Qualcomm Technologies, Inc. (QTI), a wholly-owned subsidiary of QUALCOMM Incorporated. Learn more about these changes

Ethics and Integrity

Following the rules, even as we change the game

Lasting success is built on integrity. In an exponentially growing industry where boundaries sometimes blur and innovations can create new questions, our high ethical standards, values-based culture and The Qualcomm Way: Our Code of Business Conduct guide all of us at Qualcomm as we strive to do the right thing.

Going global with The Qualcomm Way: Our Code of Business Conduct

Across our Company, we make it clear that we are committed to upholding the highest ethical standards in everything we do. Still, as workers in a complex and quickly evolving industry, our employees can often use a guide to help them navigate ethical matters. Fortunately, they have one in The Qualcomm Way: Our Code of Business Conduct.

The Qualcomm Way: Our Code of Business Conduct advises employees on the ethical and legal situations they face daily, and sets forth the behaviors expected of all of us. We fully revised and updated The Qualcomm Way: Our Code of Business Conduct in 2010, making it comprehensive and more user-friendly. In early 2011, we made The Qualcomm Way: Our Code of Business Conduct available to every Qualcomm employee worldwide. We also required that every employee electronically acknowledge that they have read it through our online learning portal.

“We weave integrity into everything we do. Ethical conduct is a core value that is evidenced throughout the organization. We’re proud of our tradition of ethical behavior and the best practices exemplified by employees in all parts of the world.”

Dan Sullivan, Executive Vice President, Human Resources

In the latter half of 2011, we continued our Qualcomm Way trainings. These in-person, interactive trainings did more than reiterate the content of The Qualcomm Way: Our Code of Business Conduct. They facilitated dialogue, employing hypothetical situations that showed employees how ethical issues are not always clear-cut in a global economy where customs and regulations vary. The trainings also encouraged openness and collaboration in ethical matters and informed employees about multiple channels for raising concerns about such issues.

In Asia, we reached more than 780 employees with our Qualcomm Way ethics trainings. We incorporated this training into orientation meetings for employees that were a part of the Atheros acquisition in this region to help them understand and live The Qualcomm Way: Our Code of Business Conduct early in their employment. The response to the training has been positive, and we continue to offer it in other locations around the world, including India, Europe and the United States.

Making it easier to report ethical concerns

We foster an open-door culture and want our employees and business associates to know that they can report ethical concerns without fear of retaliation. Our Business Conduct Hotline enables employees and others to get information about our ethical guidelines and to register concerns about our business practices. In 2011, we expanded the hotline to offer toll-free calling for employees outside the United States. The hotline also accommodates callers who speak languages other than English. In addition to the expanded phone line, we introduced a new online business conduct reporting system for employees. Online or by phone, employees can report concerns anonymously where the law allows.

Working proactively against corruption

We annually evaluate our Company for risks related to corruption. We also assess additional areas on a case-by-case basis. All employees determined to be in positions where corruption may be a risk are required to regularly review and certify compliance with our anticorruption policies.

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 other laws, including those that regulate our conduct in the marketing of our products, services and technologies in the international marketplace.

There has never been any legal case for corruption brought against our employees or our Company.

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 49 percent of our workforce. To date, nearly 100 percent of those employees have responded and reported compliance with the policy.

Helping to preserve the privacy of mobile users

Thinking Ahead

Helping to preserve the privacy of mobile users

We recognize that much of what is revolutionary about mobile devices—especially their ability to offer personalized services and experiences—also has the potential to pose privacy risks. That’s why we’re developing new ways to address privacy issues and help our customers meet their privacy obligations.

Some of our products contain TrustZone technology that provides a high degree of security for processing personal or sensitive data. Also, Xiam, one of our subsidiaries, offers an app recommendation engine for mobile app stores that includes a choice of data collections and algorithms, enabling mobile companies to set privacy restrictions according to their own policies and applicable laws. Qualcomm Life, one of our newest wholly-owned subsidiaries, is developing products for the wireless health industry that are designed to meet the rigorous privacy and security requirements of the Health Insurance Portability and Accountability ACT (HIPAA) in the United States and other similar laws for the protection of personal health information. With devices and applications evolving quickly, we’re striving to consider privacy issues early in our product development process and inventing new ways to make options for privacy protection integral to our products.

Our global privacy program is overseen by a cross-divisional, cross-subsidiary steering committee, which addresses privacy from multiple aspects of our diverse businesses. Our dedicated privacy attorney, a Certified Information Privacy Professional, advises the committee and our business groups. In addition, we sponsor organizations that promote online privacy, including Future of Privacy Forum, the Center for Democracy and Technology and the International Association of Privacy Professionals. We’re part of the global conversation about privacy through many of the trade groups to which we belong, such as CTIA, Tech America and Digital Europe.