Whistleblower Policy

A “whistleblower” is a person who discloses information he or she reasonably believes evidences a potential violation of law, rules or policy, or evidences mismanagement, inaccurate reporting, or waste of funds, or theft, or evidences a danger to safety or security or relates to wrongdoing, dishonesty, illegality or unethical conduct.
 
Xperi Coporation which includes its direct and indirect subsidiaries and affiliates (together, “Xperi” or our “Company”), is committed to ethical behavior. Our Company strives to foster an environment where concerns can be raised and issues addressed without fear of retaliation. This Whistleblower Policy translates this attitude into process, reflects our adherence to the highest prevailing standards, and demonstrates our commitment to an open culture of compliance.
 
This Whistleblower Policy is applicable to our entire Company worldwide. All of us—employees, officers and directors—are subject to it. We are expected to become familiar with and comply with this Whistleblower Policy, both in letter and spirit. In addition, we at Xperi have a responsibility to participate in training, and to communicate the values underlying this Whistleblower Policy in our interactions with fellow Xperi people and third parties outside the Company.
 
While all of us at Xperi are expected to know and follow this Whistleblower Policy, some exceptions may exist. For example, if specific conduct is permitted under this Whistleblower Policy, but is prohibited by local law, you must comply with local law. The laws of certain countries may limit Xperi’s ability to protect your identity or keep reports you make confidential. If you are located in our European offices, please note carefully the specific provisions contained in this Whistleblower Policy applicable to you, as a result of data privacy and other laws in the European Union (“EU”) or the country in which you are working.

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