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.
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:
The NXP Code of Conduct and the NXP Supplier Code of Conduct establish standards to ensure that working conditions in NXP's own operations and its supply chain are safe, that workers are treated with respect and dignity, and that business operations are environmentally responsible and conducted ethically. NXP thoroughly checks whether the Codes are understood and deployed correctly in all internal and external sites.
NXP has auditable standards in place for freely chosen employment, child-labor avoidance, working hours, wages and benefits, humane treatment, nondiscrimination, freedom of association and collective bargaining, and diversity. More information about NXP's policy towards labor and human rights can be found in the Labor and human rights chapter.
NXP has auditable standards in place for occupational safety, emergency preparedness, occupational injury and illness, industrial hygiene, physically demanding work, machine safeguarding, sanitation, food, housing, health & safety communication, worker health, and safety committees. More information about NXP's policy towards health and safety can be found in the Health and safety chapter.
The highest standards of integrity are to be upheld in all business interactions. All NXP sites and our suppliers have a "zero tolerance" policy with respect to all forms of bribery, including promising, offering, giving, or accepting any bribes, corruption, extortion, or embezzlement, and all business dealings shall be transparently performed and accurately reflected in business books and records. Monitoring and enforcement controls shall be implemented to ensure compliance with anticorruption laws.
Information regarding business activities, financial situation, or performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices is unacceptable. Intellectual property rights are to be respected, and the transfer of technology and know-how is to be done in a manner that protects intellectual property rights. Standards of fair business, advertising, and competition are to be upheld. Appropriate means to safeguard customer information must be available.
An important part of business ethics is our policy regarding tantalum, tin, tungsten, and gold (3TG minerals) in our products. NXP sites and our suppliers shall exercise due diligence on the source and chain of custody of these minerals and shall make their due-diligence measures available to NXP upon NXP's request. More information about NXP's policy towards 3TG minerals can be found in the Conflict minerals chapter.
When it comes to management systems, NXP wants our internal and external sites to have policy statements, endorsed by executive management, that cover corporate social and environmental responsibility and affirm their commitment to compliance and continual improvement. There also are clearly identified company representatives in place who are responsible for implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.
Additionally, programs should be in place to identify the labor practices and ethics risks associated with the operations performed. There should also be determination of the relative significance for each risk, and implementation of appropriate procedural and physical controls, so as to control the identified risks and ensure regulatory compliance. At all our sites, we expect there to be a process in place for communicating clear and accurate information about policies, practices, expectations, and performance to workers, suppliers, and customers.
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.