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Responding department: Sustainability and Reporting (also with input from Legal, Government Affairs, Human Resources, Global Social Responsibility, Quality and Reliability, Compliance)

Stock exchange symbol: (QCOM:US)

Does your company have a publicly available commitment to respect human rights?

Qualcomm’s Commitment to Human Rights ([link]) is a stand-alone “human rights” policy that references the company’s human rights commitments articulated in The Qualcomm Way: Our Code of Business Conduct ([link]), our annual Qualcomm Sustainability Report (QSR) ([link]), and the Electronic Industry Citizenship Code of Conduct ([link]), as well as on our Sustainability website ([link]).

How are human rights governed in your company?

We incorporate sustainability throughout our business. Our sustainability initiatives are guided by our cross-divisional Qualcomm Sustainability and Reporting (QSR) Leadership Committee, which reports annually to the Governance Committee of our Board of Directors. The Committee’s leadership and access to the Board help ensure that sustainability (including human rights) is a key component of Qualcomm’s business strategy. In fiscal 2014, we formalized and centralized the various ethics and compliance functions at our Company within a new Compliance Department. Leading our Compliance team is our first Chief Compliance Officer, who reports directly to the Audit Committee of our Board of Directors. Qualcomm seeks to be an engaged and supportive citizen of the communities where we do business by engaging in local philanthropy, encouraging volunteerism and respecting the human rights of those we encounter, either as employees or contractors.

How are human rights managed within your company?

Human rights at Qualcomm is managed by a cross-divisional team of experts from our human resources, government affairs, global social responsibility, legal and supplier management teams. Qualcomm’s annual risk assessment of our operations includes the consideration, review and prioritization of various company risks by a cross-functional group of key representatives from compliance, legal, finance, human resources and internal audit.

Our publicly available Commitment to Human Rights ([link]) outlines our guiding principles in the human rights space. We follow the Electronics Industry Citizenship Coalition Code of Conduct and have adopted it as our Supplier Code of Conduct. We require employees to complete training on the Qualcomm Way and we also have extensive resources for employees to comply with the Foreign Corrupt Practices Act. Please see the annual Qualcomm Sustainability Report (QSR) ([link]), as well as our GRI Content Index ([link]) for additional information.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Our membership in the Electronic Industry Citizenship Coalition (EICC) and our participation in BSR’s Human Rights Working Group and the UN Global Compact further augment our human rights efforts. Working with other companies in these multi-industry groups provides us with an opportunity to leverage our efforts within the industry, share best practices and discuss challenges in developing companywide solutions to address human rights concerns.

The Qualcomm Way: Our Code of Business Conduct sets forth our commitment to ethical conduct and human rights. Our employees are required to acknowledge The Qualcomm Way, and our security personnel are trained in our policies and procedures concerning aspects of human rights that are relevant to our operations. Our annual Qualcomm Sustainability (QSR) report communicates the various programs and initiatives we offer that address human rights matters, as well as our progress on the goals we set in those areas. Qualcomm has adopted the EICC Code of Conduct in our own operations and as our Supplier Code of Conduct. The EICC Code is consistent with The Qualcomm Way and provides additional clarity with regard to labor, health and safety, environmental, ethics and management systems expectations of our suppliers. We post to the Qualcomm OnQ blog ([link]) to provide periodic updates on our human rights-related programs and initiatives to external stakeholders. Moreover the Ethical Employment ([link]) section of our website provides information about our program and gives stakeholders an opportunity to contact us directly with questions about our human rights programs. In addition, our open-door culture means anyone with concerns about our Company can voice them without fear of retaliation. We respond to reports of misconduct as quickly and as confidentially as possible. To raise concerns, contact our Business Conduct Hotline, a dedicated phone line and website available 24 hours a day, or email [email protected]. Our Communication on Progress ([link]) provides additional detail on our stakeholder engagement.

Priority human rights issues: What are some of the priority human rights issues for your company?

Please see Qualcomm’s Commitment to Human Rights for a list of our Human Rights priorities. Our 2013 QSR details our materiality assessment and the sustainability issues deemed most relevant to our Company.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Qualcomm communicates our human rights commitments and information about our programs through our annual QSR report, our annual GRI Content Index and our UNGC Communication on Progress. We post to the Qualcomm OnQ blog ([link]) to provide periodic updates on our human rights-related programs and initiatives to external stakeholders. Moreover the Ethical Employment ([link]) section of our website provides information about our program and gives stakeholders an opportunity to contact us directly with questions about our human rights programs. In June 2014, we hosted human rights expert and author Christine Bader, whose presentation helped educate our employees about human rights issues. One of our Compliance Department’s first items of business was to produce a series of training videos featuring our executives discussing topics addressed in The Qualcomm Way: Our Code of Business Conduct. These videos help our employees better understand our Code, their responsibilities under it and the implications of acting in ways that do not align with our Code. The videos are part of a broader ongoing communications campaign on ethics and compliance.

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

Our open-door culture means anyone with concerns about our Company can voice them without fear of retaliation. We respond to reports of misconduct as quickly and as confidentially as possible. To raise concerns, anyone can anonymously contact our Business Conduct Hotline ([link]), a dedicated phone line and website available 24 hours a day, or email [email protected]m.com. To communicate with us about our human rights program, the Ethical Employment [link]) section of our website encourages stakeholders to contact us directly.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

This year, we continued our membership in BSR’s Human Rights Working Group and hosted the group’s June meeting at our corporate headquarters. Kevin Caffey, Vice President of Quality and Reliability, represents Qualcomm as a member of the Board of Directors of the Electronic Industry Citizenship Coalition (EICC). Elisabeth Best also served on the EICC United Nations Guiding Principles Task Force to help strengthen the link between the United Nations Guiding Principles on Business and Human Rights (UNGPs) and EICC’s work. We continue to participate in the United Nations Global Compact (UNGC), and this year we submitted our first Communication on Progress (COP), which detailed our policies, implementation efforts and outcomes related to the 10 Principles of the UNGC during the reporting period of May 2013 through May 2014.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

We developed “Qualcomm’s Commitment to Human Rights,” a statement to formalize our commitment to respecting human rights and avoiding complicity in any human rights abuse throughout our Company, our operations and our communities. This was done, in part, in response to the United Nations Guiding Principles. Another key element of our approach to human rights since 2011 has been our adoption of a companywide goal to increase awareness and visibility of human rights principles within our Company, as well as with contracted vendors and key suppliers. Much progress has been made on this goal to date, with more to come in the future. We joined the UN Global Compact and EICC during this time period also; while this was not in response to the UN Guiding Principles, our participation in both organizations has helped further enhance our approach to incorporating human rights throughout our company and daily actions.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

The ICT industry faces unique human rights challenges, which is why we believe in a collaborative approach to human rights issues. We work within the EICC to facilitate the sharing of information and best practices with our industry peers, and within the BSR Human Rights Working Group to collaborate with other companies both inside and outside our industry on human rights challenges more broadly. We believe it is important that companies share innovative and effective best practices with each other in order to promote respect for human rights across industries as well as to augment individual companies’ programs.