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 strive for continuous improvement of our compliance program, including our training curriculum and compliance-related processes, procedures, and controls. For example, ethics and compliance questions are included in our annual employee and/or climate surveys to understand and monitor our employees' perception on issues like raising concerns, ethical culture, and ease of understanding or administration of compliance processes and procedures.
We also maintain a corporate compliance portal that is curated with a wide variety of ethics and compliance educational resources and information. In 2019, we developed "The Open Door," a quarterly internal publication that allows employees to read about “real life” compliance incidents and lessons learned that have occurred at Qualcomm.
Our internal audit function conducts separate annual assessments for both our Corporate Compliance and Anti-Corruption compliance programs and practices to ensure continuous improvement. We also engage a third-party expert to conduct an evaluation of our compliance program every three years and provide recommendations for the implementation of current best practices across the industry. Having a routine third-party program review helps us proactively identify potential gaps and address any improvement or program maturity opportunities.