Ethics Committee, Management, Allegations and Approach

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. 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 Human Resources Officer and the Audit Committee of the Board regarding allegations and investigations that are in progress or completed.

Allegations

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.

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.

Enhancing our Ethics Program

In 2023, we published a standalone Anti-Bribery and Corruption Policy. Ethics and compliance topics were also included in the fourth cycle of our Winning Culture Survey. We had a favorability rating of 95% for a question related to NXP’s commitment on ethical business practices, which was the highest scoring question on the survey. This question scored more positively than the 75th percentile benchmark, composed of companies operating in the technology sector.