The NXP® Code of Conduct (the “Code”) sets out the values that guide us as we work to fulfill our ambitions in the company. It goes beyond purely business issues, covering ethics and even personal relationships. It guides us, not only in achieving compliance with legal requirements and fundamental global standards, but also in raising the bar in our behavior. The Code is an expression of the best that we are: ethical individuals who demonstrate benchmark behavior in our everyday interactions, and a company that operates as a socially responsible corporate citizen of the world.

The Code applies equally to all our activities on behalf of NXP worldwide and governs all our business decisions, including finance, purchasing, and supply management, and specifies policies covering labor and human rights, business ethics, environmental compliance, and workplace safety and health.

Auditable Standards

NXP's Auditable Standards on Social Responsibility is widely regarded as one of the most stringent sets of auditable standards in the industry. It begins with a rigorous deployment of the standards to all NXP facilities, through capacity building and regular audits of our global manufacturing sites, to ensure that the standards are fully adhered to internally in NXP. Then we deploy the standards to our supply chain and external manufacturers.

Audits help us accomplish our objectives by bringing a systematic, disciplined approach to evaluating and improving the effectiveness of risk management, control, and governance processes. At present, we have in place different but complementary internal audit types: system audits that assess the continued and sustained compliance to the NXP and Certification standards, local and execution audits, and audits to improve NXP's Environment, Health & Safety (ESH) performance. Whenever possible and feasible, we combine Quality and ESH audits. Additionally, our customers regularly conduct audits of our facilities, to ensure we meet their standards. As a matter of principle, we work to address any issues identified in the audits. In 2013, all our internal sites were audited; in 2014 there were six internal audits.

The Auditable Standards on Social Responsibility consist of the following categories:

Grievances and whistleblowers

Naturally, it is key for us that our employees are treated well and all our procedures are ethically correct. We have a whistleblower policy in place that lets employees submit complaints, either anonymously or not, regarding violations of the NXP Code of Conduct. The privacy of both the whistleblower and the subject of the complaint will be protected to the fullest extent possible within the legitimate needs of the law and any ensuing investigation. Retaliation against workers who participate in such programs in good faith or refuse an order that is in violation of the NXP Code of Conduct is prohibited. This policy reports with respect to all the relevant components, including labor and human rights, health and safety, environment, and ethics.

At our sites we make use of communication programs to ensure that every employee is fully informed of and understands the policy of non-retaliation. Information about the whistleblower and complaint channels are clearly communicated, free, easily accessible, and visible (grievance box, SpeakUp service, posters, etc.) Workers are trained, upon hire and in a language they understand, on the whistleblower policy.

When a complaint or grievance is received, there are effective procedures for documenting, investigating, and addressing the complaint or grievance, including appropriate disciplinary actions. The NXP Ethics Committee reviews complaints and grievances, and oversees their investigation. The NXP Ethics Committee informs the NXP Board of Management and the Audit Committee on the reported cases. When necessary, corrective actions to prevent the reoccurrence of similar complaints are implemented.