Qualcomm pushes the boundaries of what’s possible but never makes trade-offs when it comes to ethical conduct.
We are committed to our values of winning together, achieving excellence, making the impossible inevitable, and doing the right thing. This last value means we achieve excellence in the right way, in an ethical manner, and in compliance with the law. Through ethical challenges, our CoBC guides us, helping us act with integrity — that’s The Qualcomm Way.
Upholding clear ethical standards.
We push the boundaries of what is possible in mobile technology but never make trade-offs when it comes to ethical conduct. We are committed to conducting business with unquestioned integrity and to treating others inclusively, with respect and honesty. Our Code of Ethics also commits us to fair and accurate reporting, compliance with all applicable laws, rules, and regulations, and the prompt internal reporting of any violations to the Code. It applies to all Qualcomm employees as well as members of the Company's Board of Directors.
Conducting business, The Qualcomm Way
The Qualcomm Way: Our Code of Business Conduct (CoBC) outlines our responsibilities to customers, business partners, stockholders, communities, and each other. It sets standards of conduct for intellectual property protection, conflicts of interest, anti-corruption practices, antitrust compliance practices, insider trading, harassment, discrimination, and much more. It describes the behaviors we are expected to exhibit and provides guidance on ethical and legal issues that may arise in our daily work activities.
Every Qualcomm employee, as well as each member of our Board of Directors, is required to acknowledge that they have read, understand, and will comply with our CoBC and that they will raise concerns when necessary.
Anti-Corruption and Bribery
Qualcomm was founded with a commitment to the highest standards of integrity and ethics - and we are proud to still operate under those principles today. It is our policy to obey all laws, including those laws that regulate the Company's conduct in the marketing and sales of Company products, services, and technologies in the international marketplace. This includes compliance with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, the South Korea Improper Solicitation and Graft Act, and the anti-corruption laws and regulations of the countries where we do business.
Qualcomm strictly prohibits all bribes, corrupt payments, kickbacks, and other forms of commercial bribery involving private individuals or a Government Official. Our Global FCPA and Anti-Corruption Policy (Anti-Corruption Policy) applies to the entire Company, including all employees, agents, consultants, and representatives, wherever they are located. We obtain the commitment of our third-party contractors and service providers that may act as Qualcomm agents or intermediaries with third parties by contractual obligations relating to compliance with applicable anti-corruption laws and regulations. We also conduct risk-based due diligence for contractors and service providers that will act as Qualcomm's agents or intermediaries with external parties.
Integrating ethics and compliance across the Company
Ethical conduct is a performance imperative. To ensure effective implementation of our CoBC and Anti-Corruption Policy, we embed ethics and CoBC requirements into our employee performance appraisal system, require training for all levels, and ensure continuous reinforcement through employee engagement programs.
We reinforce our commitment to ethical business through regular mandatory training, including on our CoBC and Global Anti-Corruption Policy. This training is required not only during onboarding for employees and contingent workers but also as part of ongoing compliance education. In addition to core training, we offer instructor-led sessions and compliance communications tailored to specific risks, roles, and regions. Our training programs are designed to help individuals understand how integrity is embedded in everything we do.
At Qualcomm, we embed ethics into our employee performance appraisal system as well as our job leveling guides. Everyone is expected to make objective and ethical decisions as it pertains to their area of work and responsibility in alignment with our CoBC and Anti-Corruption Policy. Senior functions and team managers must also hold themselves and others accountable in making appropriate, ethical, and strategic decisions that are always aligned with The Qualcomm Way.
We also monitor employee satisfaction with our compliance program, including their comfort with speaking up. We review survey results with relevant regional leaders and utilize the data to continue enhancing our compliance offerings.
To support ongoing transparency and learning, we maintain the Open Door Portal, an internal webpage offering employees on-demand access to resources and learning opportunities related to our speak-up culture. We update the portal with insights from investigations and developments relevant to our industry.
We conduct periodic risk assessments to review and enhance our compliance efforts, including updating policies, procedures, controls, and training. Internal and third party experts periodically assess our efforts to ensure alignment with applicable laws and regulations, identify specific risks to our business, and provide recommendations.
Making it easy to raise concerns.
Qualcomm's Open-Door culture is designed to empower employees and others to voice any concerns they may have about our Company without fear of retaliation. We promptly respond to reports of misconduct. Concerns may be submitted anonymously through our Business Conduct Hotline or via phone or email to other reporting channels such as HR, Legal, and Compliance.
Concerns raised via our Business Conduct Hotline are reviewed by a cross-functional investigative team comprised of seasoned internal audit, employee relations, ethics and compliance, information technology, and legal personnel. Case outcomes and remedial action plans for incidents that are substantiated are reviewed and approved by our Corporate Ethics Committee.
Maintaining adherence to our Supplier Code of Conduct
As a member of the Responsible Business Alliance (RBA), Qualcomm has adopted the RBA Code of Conduct for our operations and as our Supplier Code of Conduct. We require all our semiconductor manufacturing suppliers to adopt either the RBA Code of Conduct or a similar code. Our Supplier Code of Conduct and The Qualcomm Way: Our CoBC have been cornerstones of our commitment to the RBA and responsible supply chain management for many years.
