ETHICS AND GOVERNANCE
At Qualcomm, our values—purposeful innovation, passionate execution, collaborative community, and unquestioned integrity—are at the core of everything we do. Through over three decades of innovation, we have continued to create technologies that revolutionize the way people live, work, and connect. But it is how we make this all possible that defines us… that's The Qualcomm Way.
We bring The Qualcomm Way to life through our culture of innovation, our ability to meet every challenge and persevere, and the passion and dedication of our employees. Along the way, our Code of Business Conduct serves as a guide, helping us build integrity into everything we do as a company.
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.
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.
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.
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.
Training and education are essential to reinforce an ethical culture. In addition to mandatory training during the onboarding process for employees and temporary workers, we issue re-certifications for each policy every other year. In 2019 employees were required to re-certify their training on our Anti-Corruption Policy , and in 2020, we implemented a company-wide re-training initiative for our CoBC). These training requirements are mandatory for all our regular and temporary Qualcomm employees. Additionally, employees who have externally facing roles are required to complete instructor-led Anti-Corruption and Compliance training on an annual basis.
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.
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.
|
Business Conduct Hotline Cases |
FY18 |
YY19 |
FY20 |
Total |
| Anonymous | 69 (87.3%) | 59 (75.6%) | 105 (74.5%) | 233 (78.2%) |
| Identified | 10 (12.6%) | 19 (24.4%) | 36 (25.5%) | 65 (21.8%) |
| Total | 79 | 78 | 141 | 298 |
|
FY 20 Issue Types |
Percentage of FY20 total |
| Accounting and Auditing Matters | 0.7% |
| Antitrust, Competition or Regulatory Compliance
|
1.4% |
| Ask a Question
|
16.3% |
| Conflict of Interest
|
6.4% |
| Discrimination or Harassment
|
22.7% |
| Falsification of Contracts, Reports or Records
|
2.8% |
| Misconduct or Inappropriate Behavior
|
28.4% |
| Misleading sales, marketing or advertisement
|
0.7% |
| Misuse of Intellectual Property
|
0.7% |
| Theft
|
2.8% |
| Other/Unknown
|
17% |
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.
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