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Code of conduct

Letter from the President and CEO

The past few years have been extraordinary. Climate change, trade disputes and a global pandemic have posed serious challenges to businesses of all types.

Faced by these circumstances, the best businesses draw strength from a strong and clear set of values: a worldview that gives all employees a framework in which to approach new and unusual situations. Nokia’s Code of Conduct is an excellent example. The Code states our values, clearly and concisely. It explains why they are important and translates them into standards, policies and rules that all Nokia employees are expected to follow. In other words, the Code unites all of us, in diverse locations and from diverse cultures, behind a common vision.

The Code has been written in a practical style. It identifies specific risks and challenges that employees of international businesses might face. It includes examples. And importantly, it is clear about how we should address those risks, and where to go for help.

By following the principles of the Code, we will succeed collectively, as a company and as individual employees. And we will build trust with customers, suppliers, communities, and each other.

Naturally, the Code cannot provide an answer to every question. In these cases, please stop and think, ask the opinion of colleagues, and act in accordance with Nokia’s values.

And most important of all, always speak up when something doesn’t seem right.

In doing so, you actively contribute to the success of this great, historic and trusted company.

After all, business is all about trust. Trust is built on integrity. Your decisions matter.

Trust is built on integrity. Your decisions matter.

Pekka Lundmark
President and CEO

You can find specific Code policy topics under the tabs for Doing business, People and community, and Safeguarding assets.


Pekka Lundmark, President and CEO

A message from our Chief Legal Officer

Business is all about trust.
Trust is built on integrity.

Your decisions matter.


This Code of Conduct sets out essential rules and provides guidance to ensure that all of us, including everyone acting on behalf of Nokia, act with unyielding integrity, consistent with the numerous laws, regulations, and policies that govern us. Our entire business is built on trust; in fact, our stakeholders will not work with us without it. Our Code of Conduct expresses our personal commitment to earning this trust every day, in each community and in all our business activities. It reflects our values through clear and simple direction for all our employees and business partners and reinforces our Nokia essentials of being open, fearless and empowered.

Scope and applicability

The Code of Conduct outlines standards for ethical behavior by Nokia employees and business partners. It sets out our four key principles and 14 key risk areas, each of which is explained in detail. It explains how compliance is a commitment and a responsibility shared by all of us.

The Code of Conduct applies to directors, officers, and employees of Nokia, as well as employees of Nokia’s wholly-owned affiliates and subsidiaries. The Code also applies to directors, officers, and employees of other business entities (such as joint ventures) in which Nokia owns a majority of the shares or exercises effective control.

Nokia will also make good faith efforts to implement the Code or ensure the adoption of a similar set of policies, in operating entities in which Nokia actively participates but does not own a majority of shares or exercise effective control. Likewise, Nokia will use its best efforts to have third parties such as suppliers, representatives, and other contractors commit to the same values and principles as those enshrined in the Nokia Code of Conduct. All of Nokia’s third parties are bound by our Third-Party Code of Conduct.

Speaking Up

Speaking up

When you speak up, we listen up!