NXP's commitment to the highest standards of ethics and integrity helps us earn the continued confidence of our team members, investors, customers, vendors and communities.
We monitor, assess and track our compliance performance and report progress on a quarterly basis.
We strive to achieve the highest standards of ethical conduct in all our business dealings. The Code of Conduct , available in 12 languages, and related policies guide us to conduct ourselves in a professional manner toward our customers, partners, competitors, vendors, government regulators, shareholders, fellow team members and the community at large.
Our Code outlines our core principles and establishes the expectations we have about how we conduct business. The Code covers business integrity, personal integrity, company assets, employment at NXP, external activity and gives assistance in reporting potential violations. The Code applies to all of our executive officers, directors, team members and contractors, and we expect all third parties we do business with to act in a manner consistent with our code.
We emphasize making ethical decisions, never engaging in corruption, bribery or insider trading, avoiding conflicts of interest, competing in an ethical and lawful manner, complying with international trade regulations, practicing transparency and maintaining accurate business records. To protect our company’s reputation, we have policies related to these issues and we expect all team members to comply with them.
Our commitment to promote a culture of integrity means anyone can voice concerns without fear of retaliation. Grievances can be confidentially lodged using various reporting channels, such as management, an ethics liaison or the NXP Ethics Committee. Grievances can also be submitted using the phone or web option of the SpeakUp line, which is hosted by an independent third party and facilitates anonymous reporting. Employees are encouraged to report potential violations of our CoC using any of our reporting channels. We have a strict non-retaliation policy to protect those who report potential violations.
Our commitment to promote a culture of integrity means anyone can voice concerns without fear of retaliation. Grievances can be confidentially lodged using various reporting channels, such as management, an ethics liaison or the NXP Ethics Committee. Grievances can also be submitted using the phone or web option of the SpeakUp line, which is hosted by an independent third party and facilitates anonymous reporting. Team members are encouraged to report potential violations of our Code using any of our reporting channels. We have a strict non-retaliation policy to protect those who report potential violations.
The general approach to all complaints is based on an initial assessment of the grievance, the appointment of an investigation team with the right expertise and skill set to gather all relevant evidence and an in-depth investigation to define appropriate remedial action(s) in the quickest possible timeframe. While it’s difficult to set a fixed timetable for resolution, since complaints vary in scale and complexity, most can be dealt with in under two months.
Based on the findings of the investigation, a decision is made about whether the grievance is substantiated. If the grievance is substantiated, we take appropriate follow-up actions. These actions can include education, organizational changes, counseling, reprimands, suspension and/or termination, depending on the nature and severity of the finding and the party’s willingness and ability to rectify the issue.
The NXP Ethics Committee reviews grievances and oversees investigations into alleged violations of the Code. The Ethics Committee includes senior leaders from Legal, Internal Audit, Human Resources and Sustainability from the Americas, Europe and Asia-Pacific regions. The Ethics Committee meets bi-weekly to discuss all reports received and to monitor the progress of ongoing investigations.
The NXP Ethics Committee reports quarterly to the General Counsel, Chief Financial Officer, Chief Human Resources Officer and the Audit Committee of the Board of Directors about the number and types of reports and details about key investigations that are in progress or completed.
NXP team members and contractors receive annual training on the Code. NXP launched the Code training in November 2021. The Code training is offered in 12 languages and focuses on NXP values and expectations as set forth in our Code.
The training from 2021 addressed several topics, including anti–bribery and corruption, conflicts of interest, (sexual) harassment, and speaking up at NXP. Team members were required to acknowledge receipt and understanding of the Code. A test is part of the training and a 100% score is required for completion and certification.
NXP’s goal is 100% completion by all enrolled individuals. At the time this report was prepared, we achieved a completion rate of 97.9%. Since the training window opened at the end of the year, we did not yet reach our 100% completion rate. In 2022, we will determine whether those who did not complete the training yet should be given an exemption, for instance because of long–term sick leave or maternity/paternity leave. We will continue to work towards a 100% completion rate.
The NXP Ethics Committee email account: code.compliance@nxp.com
The NXP Legal and Compliance Counsel, NXP Semiconductors, High Tech Campus 60, 5656AG Eindhoven, The Netherlands.
The external SpeakUp