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 2012, we continued our Qualcomm Way trainings around the world. 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. Nearly 2,000 employees have participated in our trainings, since they began in June 2011.

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.

In 2012, we made it easier to report concerns by launching posters and badge cards that provide employees with a quick reference on how to use our Business Conduct Hotline. We also added a new tool enabling employees to raise concerns directly to our ethics committee members via our internal website.

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 regularly 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 foster trust in the use of wireless technologies

At Qualcomm, we envision a world where powerful, easy-to-use wireless devices are tailored to end-users’ individual needs and preferences. We believe that personalization of the wireless experience brings a wide array of benefits to both individuals and enterprises. Cultivating trust through a foundation of security and privacy practices helps drive broader adoption and more personalized wireless technology offerings.

We strive to foster trust in the use of wireless technologies by helping to enable responsible information privacy and data security practices that are informed by the following guiding principles:

  • Transparency in the collection, use and sharing of personal information
  • Providing or enabling meaningful choices over the collection, use and sharing of personal information
  • Providing or enabling value to consumers when using their personal information
  • Safeguarding personal information from existing and emerging threats
  • Responsible stewardship of personal information

In addition to developing our privacy principles, we also expanded our internal privacy group in 2012. The group includes dedicated privacy attorneys and specialists who are Certified Information Privacy Professionals. Our privacy group is advised by a cross-divisional steering committee, which addresses privacy from the multiple perspectives that characterize our diverse Company. In addition, more employees throughout our Company have received certification through the International Association of Privacy Professionals, increasing the number of “privacy champions” across our operations.

Most often, the ultimate responsibility for protecting user privacy rests largely with our customers—the companies who make wireless devices and develop wireless applications. Even so, our products are designed with privacy in mind.

One example is our 2net™ Platform from Qualcomm Life. 2net is a set of wireless health solutions that capture medical device data from nearly any wireless medical device and deliver them to integrated portals or databases for storage in a system designed for security. We carefully designed 2net to meet stringent HIPAA security requirements, ensuring information sharing among providers, patients and payors without compromising patient privacy.

Gimbal™, our context awareness platform for Android and iOS devices, helps preserve privacy by enabling application developers to offer users greater personalization without sacrificing privacy. Our TrustZone chipset solution enables mobile payment, conditional access and protection of storage media through advanced security options.

In addition to addressing privacy in our products, we are part of the global conversation about privacy. We lend our voice through trade associations such as CTIA, Tech America and Digital Europe. We also sponsor organizations that promote responsible information privacy practices, including the Future of Privacy Forum, the Center for Democracy and Technology and the International Association of Privacy Professionals.