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.
In 2022, 121 reports were opened and received by the Ethics Committee. Of these reports, 62% were substantiated and 96% were closed.
Most reported violation types included violations of internal policies, theft, conflict of interest, and harassment.
We aim to compete in an ethical and lawful manner, comply with international trade regulations, practice transparency, maintain accurate business records and never engage in bribery or corruption or insider trading.
NXP’s Code of Conduct (the Code) sets out the principles that guide us as we work to fulfill our ambitions as a responsible and ethical company. It serves as a framework and details the behavior expected from every team member, director, contractor or anyone else who works on behalf of NXP. The Code is available in 12 languages. The Code is available in 12 languages.
The Code addresses business and personal integrity, use of company assets, employment at NXP, and external activities, and provides guidance on reporting potential violations. The Code was last revised in 2021. To incorporate the Code into our way of working, we train our team members on the principles of the Code.
We are committed to promoting a culture of integrity, and encourage our team members, as well as external business partners and third parties, to express any concerns they have related to potential violations of the Code, NXP policies or the law.
Concerns and grievances can be confidentially lodged using various reporting channels, such as management, ethics liaisons, or the NXP Ethics Committee. They can also be submitted using the phone or web option of SpeakUp , a system hosted by an independent third party that facilitates anonymous reporting. Team members are encouraged to report potential violations of our Code using any of our reporting channels.
The NXP Ethics Committee reviews reports and grievances and oversees investigations into alleged violations of the Code. The Ethics Committee consists of five senior leaders from Legal, Internal Audit, Human Resources and Sustainability. Members are based in 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 Ethics Committee reports quarterly to the General Counsel, the Chief Financial Officer, the Chief Human Resources Officer and the Audit Committee of the Board regarding allegations and investigations that are in progress or completed.
All reports are assessed and discussed by the NXP Ethics Committee. After the initial assessment of a report, an investigation team is appointed with the right expertise and skill set to conduct an in-depth investigation. While it is 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 report can be substantiated. If so, we take appropriate follow-up actions. These actions can include education, organizational changes, counseling, reprimand, suspension, and/or termination, depending on the nature and severity of the finding and the party’s willingness and ability to rectify the issue.
In October 2022, the annual Code of Conduct training was rolled out to our team members. The training was offered in 11 languages and focused on NXP values and expectations as set forth in the Code.
The 2022 training addressed several topics, including trade compliance, fair competition, the use of social media, and speaking up in NXP. Team members were required to acknowledge receipt and understanding of the Code. A test is part of the training and team members need to pass the test to receive certification.
NXP's goal is 100% completion by all enrolled individuals. In 2022, we achieved a completion rate of 97%. Since the training window opened in Q4, we did not reach our 100% completion rate at the end of 2022. In 2023, we will determine whether those who did not yet complete the training should be given an exemption, for instance because of long-term sick leave or parental leave as we continue to work towards a 100% completion rate.
Email:
NXP Ethics Committee: code.compliance@nxp.com
Phone:
SpeakUp
Mail:
NXP Legal and Compliance Counsel
NXP Semiconductors
High Tech Campus 60
5656AG Eindhoven
The Netherlands