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Code principles

The four principles of our Code of Conduct


We follow the laws

of the countries where we do business and adhere to Nokia’s policies and procedures.


We personally set the example

for each other and our stakeholders by being honest and fair.


We promote a culture of integrity

through mutual respect, trust in each other and high standards of ethics in all our business dealings.


We hold each other accountable

to this Code, and if we become aware of potential violations, we promptly report them.

Your responsibilities

The Code of Conduct sets high standards of integrity for Nokia employees and business partners. It reflects our commitment to acting in an ethical and compliant manner in all our business activities.

Although everyone is expected to know and understand the Code, it does not answer every question or anticipate every difficult situation you might encounter. It sets out a model to help you make the right decisions – decisions that could have a long-lasting impact on you and the company. Know that you are never expected to make tough decisions alone. There are ample resources and channels that are available to you to ask questions and receive guidance.

In all cases, your obligations under the Code include:

  • Reading, understanding, and following the Code of Conduct and its policies and seeking guidance when needed;
  • Promptly raising any and all compliance concerns through one of the many channels provided by Nokia;
  • Avoiding any practices that may lead to unlawful conduct, an appearance of impropriety, or harm to Nokia’s reputation;
  • Fully supporting anyone who raises a compliance concern and never retaliating in any way against anyone who does raise a question or concern;
  • Cooperating fully in all compliance investigations.

Role and responsibility of Nokia leaders and line managers

Nokia’s leaders – including all line managers – have additional responsibilities when it comes to ethics and compliance. They are compliance stewards for their organizations and are responsible not only for achieving business results but also for driving a culture of integrity throughout their organizations. Leaders “own” compliance within their organizations and are fully accountable for compliance failures that result from their failure to instill and advance this culture in their teams. Leaders are also expected to drive an open reporting environment and encourage a “speak-up” culture.

Leaders at every level must, at a minimum:

  • Know and anticipate business compliance risk areas that may affect team operations and take proactive steps to mitigate such risks; set goals to track compliance; and ensure their team is trained to deal with the risk areas;
  • Communicate regularly with their team about the importance of compliance, and demonstrate visibly and actively – through words and behavior – their personal commitment to the Nokia Code of Conduct and its policies;
  • Emphasize the value of reporting potential compliance concerns promptly and foster an environment of open reporting where employees feel comfortable raising concerns without fear of retaliation;
  • Hire and promote only those people who have high standards of integrity and reward and recognize employees who go above and beyond with respect to compliance.

The circle of responsibility

At Nokia, compliance is a shared responsibility. We all have a role to play in upholding our ethical values and policies.


It is up to leaders, at all levels and parts of the company, to be engaged and accountable, and to actively promote a culture of integrity.


It is up to every employee, to know and understand the policies and rules, and to ask questions and raise concerns whenever something doesn’t seem right.

Legal and Compliance

It is the role of Legal & Compliance to educate and empower employees, to establish clear guidelines, and to have effective procedures in place to address the complex and varied risks inherent in today’s business environment.

The Nokia ethical decision-making model