Nokia's compliance commitment in this Code extends to all matters, including decisions relating to trade, investment, subcontracting, supplying, business development, and in all other business and employment relationships. Nokia's approach to implementing this Code of Conduct is active, open and ethically sound. Although difficult questions of interpretation may arise, Nokia will do its utmost to resolve any identified ethical, legal, environmental, employment, and human rights issues consistent with this Code of Conduct.

It is the responsibility of each Nokia employee to promote this Code of Conduct. The Nokia Ethics Office exists to support employees in all questions relating to this Code. Nokia employees are always encouraged, when possible and feasible, to raise questions and report issues relating to the Code of Conduct with their superiors. It is the responsibility of all Nokia superiors to support their teams in matters relating to the Code.

It is the responsibility of each Nokia employee to report on violations of this Code:

Nokia employees may report violations of the Code to their superior. It is the responsibility of all Nokia superiors to give advice on the proper procedure in case of violations.

Any issue involving a potential violation of the 'No tolerance of corruption' section in the Code, or any applicable legal rules or regulations, should be reported to the employee's Legal or Business Controller, with a copy being sent to the Assistant General Counsel. The Assistant General Counsel can also be contacted directly.

Furthermore, the employee may report an issue directly, confidentially and anonymously to the Nokia Board of Directors, its non-executive members or sub-committees through an electronic channel and a physical mailing address, both available on the company's website. In particular, issues related to Nokia's accounting, internal controls, or auditing matters are to be addressed to the Audit Committee/Nokia Board of Directors.

Regardless of the reporting channel, all allegations of potential violations of this Code made in good faith will receive a fair and comprehensive investigation conducted with the relevant internal and/or external assistance.

Acts inconsistent with this Code must be promptly corrected and are subject to disciplinary action, up to and including termination of employment. Nokia will ensure that there will be no adverse work-related consequences for any employee making complaints of violations of this Code.