Qualcomm’s 2023 Corporate Responsibility Report: Ethical Governance

Originally published in Qualcomm's 2023 Corporate Responsibility Report

We believe that ethical conduct is a cultural imperative, and all employees are responsible for following the CoBC. Our commitment to purposeful innovation, passionate execution, collaborative community and unquestioned integrity underlies everything we do. Through more than three decades of innovation, we have continued to create technologies that revolutionize the way people live, work and connect. But it’s how we make all this possible that defines us — that’s The Qualcomm Way.

Compliance with global anti-corruption laws also continues to be a top priority for the Company. To this end, our Global Foreign Corrupt Practices Act (FCPA) and our AntiCorruption Policy applies to the entire Company, including all employees, agents, consultants and representatives, wherever they are located. It is our policy to obey all laws, including those laws that regulate the Company’s conduct in the marketing and selling of Company products, services and technologies.

e strictly prohibit all bribes, corrupt payments, kickbacks and other forms of improper influence involving government officials or private individuals. We obtain that commitment of our third party contractors and service providers who may act as Qualcomm agents or intermediaries 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 who act as Qualcomm’s agents or intermediaries with external parties.

Our corporate compliance program (Program) — including policies, procedures, controls, risk assessments and training — is evaluated for efficacy by our Internal Audit function periodically. We also commission a third party expert Program assessment from time to time to help the Program mature in line with the risks of our business. We use the findings and recommendations from these assessments to stay apprised of best practices and pursue continuous improvements.

Ethical conduct and decision-making are expected of all employees and are core elements of our performance assessment framework for leaders. Team managers and senior leaders are encouraged to create an environment where employees can feel free to raise ethical questions or concerns. They are also reminded to have purposeful conversations with their organizations around the importance of ethical conduct and decision-making, as we believe this is key to building trust as well as the long-term success of the Company.

Training, education and employee outreach are essential to reinforce an ethical culture. In addition to mandatory Program and ethics training during the onboarding process for employees and temporary workers, we require the completion of a policy training and certification process every 1-2 years covering our CoBC and Anti-Corruption policies as well as the FCPA. These training requirements are mandatory for all our regular and temporary employees. In 2023, we issued companywide mandatory training on our CoBC to help employees recognize and understand how we build integrity into everything we do as a Company. Adhering to these policies is critical to maintaining our long-standing reputation for conducting business with the utmost integrity.

To support our workforce’s education and knowledge of our policies and provide easily accessible on-demand information whenever and wherever it is needed, in 2023, we introduced a micro-learning library covering commonly asked questions. It includes instructional short videos related to the FCPA, our Anti-Corruption policy and our Conflict-of-Interest policy. Topics covered through this repository include conflict situations and reporting, anti-corruption compliance related to event sponsorships, managing third parties and introductory training on compliance basics, among others.

Beyond mandatory Company-wide training, employees who have externally facing roles periodically complete supplemental Anti-Corruption and Compliance training. In 2023, we offered a total of 29 sessions that were attended by more than 2,500 employees in externally facing business functions (Business Development, Government Affairs, Marketing, Sales and Ventures) and assurance partners (Finance, HR Talent Acquisition, Legal and Procurement).

To gauge ethical culture and comfort in raising legal or ethical concerns, we include ethics-related questions in employee engagement surveys. The survey results are analyzed to identify opportunities for additional outreach, to better understand employee perceptions of Company culture and to raise awareness of the systems in place to investigate concerns and remediate risks. In the 2023 pulse survey, 81 percent of employees highlighted that they can freely raise ethical concerns without negative consequences. This represents a 5 percent increase from the previous year.

We celebrated “We Love Compliance” Week for the fifth consecutive year. This initiative showcases the importance of exemplifying Company values, connecting with the Compliance team, recognizing compliance champions and being familiar with the Company’s Program. It exists to highlight that compliance is everyone’s responsibility. With the onsite return of most employees in 2023, we saw record engagement and participation since the inception of the Program. This year, this celebration of compliance and integrity included more live and onsite employee engagement events.

We continued to consolidate and formalize our Ethics Liaison program with the goal of reinforcing and promoting a positive ethical culture in our operations across the globe. The Ethics Liaison program is composed of 18 representatives from various functions, business units and offices around the world who provide timely updates to the corporate compliance team on local business operations or emerging risks. They also serve as trusted peers to whom employees can reach out in their local office for guidance, decision support, and the application of compliance-related policies and program requirements.

Our open-door culture is designed to empower employees and other stakeholders to voice any concerns they may have about our Company, without fear of retaliation. Concerns may be submitted anonymously (where permitted by law) through our Business Conduct Hotline, via phone or via email to other reporting groups, such as Management, HR, Legal and Compliance, and we strive to respond promptly and as appropriate.

Ethics concerns are reviewed and investigated by a centralized cross-functional team composed of experienced Internal Audit, Risk and Compliance and Legal personnel. This team also reviews and approves case determinations and remedial action plans for substantiated incidents. Business Conduct Hotline data can be found in our ESG Performance Summary.

Through resources like the Open-Door Portal, an internal webpage, employees have access to additional information and learning opportunities regarding our speak-up culture. We regularly update the resources in the portal to present concerns that were investigated to conclusion. The cases represent a small subset of the total internal ethics investigations that are conducted and are chosen because we believe they will be the most helpful to employees in learning about the types of challenges or perceptions that can arise when we do not align our conduct with Qualcomm’s values. The goal is to inform and educate our community while also serving as examples of how our Company addresses concerns diligently and appropriately.

Learn more about how Qualcomm is driving innovation, societal advancement and sustainability in the 2023 Corporate Responsibility Report