Ethics | NXP Semiconductors

Allegations Approach and Management

Ethics Committee

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, is chaired by NXP's Chief Ethics Officer and supported by a secretary. 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.

Management

The Ethics Committee reports quarterly to the General Counsel, the Chief Financial Officer, the Chief People Officer and the Audit Committee of the Board regarding the number, type, materiality and follow-up of the allegations and investigations that have been received.

Allegations

All reports are assessed and discussed by the NXP Ethics Committee. After the initial assessment of a report, an investigation team, equipped with the right expertise and skill set to conduct an in-depth investigation, is appointed. 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.

Approach

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.