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Compliance policies:

We respect our people and community

Environment

Nokia’s longstanding commitment to the protection of the environment and management of environmental issues actively, openly, and ethically meets and often exceeds legal and regulatory requirements.

Nokia continuously seeks to prevent pollution and to reduce the environmental impacts of its products and services during design, procurement, manufacturing, use, and end-of-life.

We also expect our business partners and suppliers to share our commitment to the environment.

What to watch out for

  • Failing to promptly address environmental complaints or concerns from employees, suppliers, customers, or other third parties.
  • Suppliers or contractors that do not engage in sound or sustainable environmental practices.
  • Ignoring applicable environmental regulations or company guidelines.
  • Missing opportunities to decrease the environmental impact of our products and services by reducing waste, increasing energy or material efficiency, or preventing pollution.
  • Obtaining, maintaining, renewing, and extending all environmental permits, licenses, or other clearances (such as environmental impact studies) on the timely basis that is necessary to Nokia’s operations.

What you need to know

  • Nokia meets or exceeds the legal requirements for protecting the environment. Nokia expects its employees, suppliers, contractors, and other business partners to follow the same or equivalent standards, placing a high priority on protecting the environment.
  • By working continuously to reduce the environmental impacts of Nokia products throughout their life cycles – including design, procurement, manufacturing, use, and end-oflife – Nokia enables customers and users to reduce their environmental footprints.
  • Be aware of the environmental impacts relevant to your work and how specific environmental requirements are met in your work function, such as product requirements in research and development or transportation selection in logistics.
  • Take immediate action to remedy situations in which incidents, audits, and feedback highlight areas for improvement in Nokia’s environmental management.

Scenario

I am part of a research and development team that is finalizing a new product. I am concerned that the environmental impact of the product is being downplayed or overlooked; there are certain aspects of the product design that could have a negative environmental impact. Should I do anything?

Answer

Yes. Nokia is wholly committed to protecting the environment and will not compromise on damaging our planet for profit. We will only develop products that have been fully and properly assessed for environmental impact. The R&D team will not be permitted to bypass correct environmental processes. You can raise your concern with the development project manager, your line manager, or Legal and Compliance to ensure that your concerns are considered, and that this environmental aspect is not overlooked.

Nokia employees - you can find more information on this topic HERE.

Fair employment

Integrity and respect are integral to our essentials of being open, fearless, and empowered.

We respect all individuals regardless of age, disability, gender identity, characteristics or expression, marital or civil partnership status, pregnancy or parental status, race, religion or belief, sex, sexual orientation, or any other characteristic protected by law.

Bullying, harassment, discrimination, and retaliation, in any form, are prohibited.

What to watch out for

  • Harassment, which is improper or unwanted conduct that may or may not be of a sexual nature or otherwise related to a protected characteristic that is intended to or does violate the dignity of another person, or creates an intimidating, hostile, degrading, humiliating or offensive environment. Harassment may, for example, include unwanted and inappropriate comments, jokes, or touching. Harassment can be a one-time or repeated occurrence, inside or outside of the workplace.
  • Bullying, which may include any unwanted behavior that is offensive, intimidating, malicious or insulting, or is an abuse or misuse of power that undermines, humiliates, or causes physical or emotional harm. Bullying may be a one-time incident or a regular pattern of behavior that occurs inside or outside the workplace, in person or virtual, can be physical or verbal, obvious or subtle, intentional or unintentional.
  • Abusive micro-behaviors such as comments, questions or behaviors that are offensive or inappropriate and communicate a hostile, derogatory or negative attitude towards somebody else, whether or not intentional. Such behaviors could involve conduct such as excluding people from activities, persistently interrupting colleagues, taking credit for the work of others, repeatedly disregarding the non-working time of others, or other detrimental treatment, whether or not related to a protected characteristic.
  • Any decisions related to someone’s employment which are not based on merit, principles of equal opportunity, or made for other legitimate business reasons.

What you need to know

  • Nokia strives to maintain an ethical and inclusive work environment free from any unlawful discriminatory, hostile, degrading, intimidating or offensive behavior everywhere we do business.
  • All our people, regardless of their role or seniority, are expected to be guided by Nokia’s essentials of being open, fearless and empowered. This means we treat each other with respect, dignity and courtesy and this includes all communications and other interactions, whether face-to-face or electronically, and whether verbal or non-verbal.
  • Nokia provides equal opportunities to all employees and all employment decisions are made without regard to a person’s age, disability, gender identity, characteristics or expression, marital or civil partnership status, pregnancy or parental status, race (color, nationality or ethnic or national origins), religion or belief, sex or sexual orientation, or any other characteristic protected by law. No one should be treated less favorably on the grounds of such characteristics.
  • Nokia expects everyone, including our officers, employees, customers, suppliers and business partners, to create a psychologically safe work environment which allows to challenge abusive or discriminatory behavior. Nokia wants everyone to feel empowered to raise genuine concerns without fear of retaliation.
  • Nokia encourages everyone to be an “ally,” support inclusion, and speak up for those who are excluded. Allyship involves actively and consistently operating in solidarity with groups of which you are not a part, including calling out discrimination when you witness it.

Scenario

You are in a Teams video meeting when you witness your manager ridiculing a team member because of their sexual orientation after the team member mentioned in passing going to dinner with their same-sex partner the night before. The manager then posts further derogatory jokes on the Teams chat. The team member in question reaches out to you saying how upset they are but that they are scared to speak up fearing further humiliation. What should you do?

Answer

These comments and behavior are against Nokia policy and should not be tolerated. Act as an ally to the person, speak with the People organization, your manager, Legal and Compliance, an Ombuds leader or raise your concern to the Ethics Helpline. Be assured that you will not face any reprisals for raising such a concern.

Nokia employees - you can find more information on this topic HERE.

Health, safety and labor conditions

We are passionate about making sure that everyone who works for, or on behalf of, Nokia goes home safely at the end of the day.

We earn the respect of each other, our contractors, our partners, our customers, and members of the public by providing a safe, healthy, and fair working environment.

We do this through the robust and consistent implementation of our internal processes – processes that meet or exceed applicable regulatory requirements. We also expect the same of our contractors and suppliers.

What to watch out for

  • Situations that could be dangerous, such as a colleague not wearing a safety belt in a taxi, participating in a conference call while driving, or working at steep heights without the proper safeguards in place.
  • Anyone who disregards our policies or legal requirements or otherwise acts in a way that places others at risk, such as a manager requesting someone to work when that person is not fit for duty.
  • Colleagues who appear to be struggling at work or are not coping because they feel overloaded, are concerned about organizational change, or have pressures outside of work that are contributing to a feeling of being overwhelmed and in need of support.
  • Opportunities in your daily work routines that will increase the likelihood of everyone going home safely following a good day at work.

What you need to know

  • Health and safety management is integrated into our business and processes; this includes the design, production, distribution, installation, and support of our products and systems.
  • We continuously improve our health and safety performance through robust, consistent, and transparent risk management, constantly seeking to learn and share to prevent work-related accidents, and implementing (where possible) new working practices and technologies.
  • We want everyone to have a good day at work, and to be able to achieve an optimal balance between high performance and a healthy, happy, and fulfilling home life.
  • We take immediate action to correct situations in which incidents, audits, and feedback identify areas for improvement, and we build sustainable, scalable, and repeatable solutions.
  • We expect our suppliers, contractors, and other business partners to meet the same standards and place equally high priority on health, safety, and labor conditions in their operations.

Scenario

As the project manager, I am under immense pressure from my customer to complete outstanding tasks on various sites. I have explained to our engineering teams how important it is that we get the work done quickly – it will largely determine whether we win future contracts from the customer. I have asked them to work very long hours and over weekends. Although I expected this to be for one or two weeks, it has now been going on for well over a month. Is this practice OK?

Answer

You may have acted outside of the Nokia Code of Conduct, as your actions may place the engineers at risk, jeopardizing their health, safety, and well-being. They might make mistakes because of fatigue, exhaustion, or other factors, and those mistakes could have serious health and safety consequences. You should have considered alternatives, such as negotiating a project extension with the customer or bringing in additional resources.

Nokia employees - you can find more information on this topic HERE.

Human rights

Nokia provides products and services that expand opportunities to communicate and contribute directly to the exercise of such fundamental rights as free expression, privacy, access to information, exchange of ideas and economic development. We recognize, however, that technology can be misused and as a communications technology provider we have a responsibility to ensure our products and services are not misappropriated or abused.

Nokia is committed to the principles of the Universal Declaration of Human Rights and the United Nations Guiding Principles for Business and Human Rights, and we expect our suppliers and business partners to share these values.

Nokia seeks to ensure that materials used in our products come from socially responsible sources. We do not tolerate, contribute to, or facilitate any activity that fuels conflict or violates human rights. Nokia does not tolerate, in any context, the use of servitude, child labor, forced labor, human trafficking, or slavery in our operations in any region in which we operate or in any part of our global supply chain.

What to watch out for

  • Conducting business in countries where the rule of law is weak or where the government is not a result of free and open democratic processes.
  • Requests for subscriber data beyond that which is provided in the normal course of business in cases where Nokia manages the network.
  • Requests from operators in higher-risk countries for specific features, such as location-based data or more detailed subscriber data on traffic or events, in addition to standard functionality.
  • Suppliers or contractors that appear to employ underage workers or fail to provide safe or healthy workplaces or adequate employment documentation upon request, including records of wages paid.
  • Use of minerals from conflict countries that are regulated by international authorities.

What you need to know

  • Nokia provides limited, core “lawful intercept” capabilities based on clear standards and on a transparent foundation in law. Operators are required in most countries, as part of their license to operate, to provide such capabilities and to assist authorities in legitimate law enforcement.
  • Nokia conducts due diligence in the pre-sales process and follows international standards to help ensure that our products are used to enhance, and not infringe, human rights.
  • Nokia also conducts due diligence on its suppliers and business partners to ensure that they share Nokia’s commitment to human rights.
  • Nokia complies with applicable laws and participates in industry initiatives to support human rights and to validate that the minerals and metals used in our products do not contribute to conflict.
  • Nokia does not unlawfully or improperly use or exploit natural resources. Nokia tracks the origin of the metals in our products through the supply chain back to smelters.

Scenario

I have heard that one of our suppliers withholds employees’ passports for ‘safekeeping,’ and their wages are held in accounts controlled by the employer. Is this a concern?

Answer

Yes. It is your obligation to raise this issue with Legal and Compliance or through one of the reporting channels. Employers who retain travel documents and have other unacceptable controls over employees might be committing modern slavery offenses. It is an obligation to report this to the company.

Nokia employees - you can find more information on this topic HERE.

Privacy and data protection

At Nokia, we believe that privacy is everyone’s business.  We consider privacy as enabling trust in our technology, business, and operations.  Privacy is important for all of us as individuals. Nokia holds itself up to the highest standards of protecting personal data. Our business is built on trust. Respecting privacy and protecting personal data is not simply about being compliant with data protection laws; it is a fundamental value for Nokia as a trustworthy and ethical company.

Nokia collects, uses, holds, and processes data responsibly, ethically, and in compliance with data protection laws.

Nokia’s Privacy Policy embodies our Privacy principles. We build privacy and security into the design of our products and services and employ appropriate safeguards to protect personal data against unauthorized use or disclosure while keeping it confidential.

Such safeguards ensure a level of security appropriate to the risks presented by processing activities and the nature of the personal data.

What to watch out for

  • Always follow the requirements defined in our customer agreements about how we access, collect, and handle personal data. Do not collect, process, or store personal data in a way that is incompatible with our customer commitments or our internal privacy processes and policies.
  • When storing personal data, ensure it is in a protected environment. Do not leave personal data on a printer, shared server, or publicly accessible computer or website. 
  • When personal data is no longer necessary for the purpose it was collected, it should be deleted, destroyed, or anonymized.
  • Only disclose personal data to those persons and organizations authorized to access it.
  • If you receive a privacy-related request from a customer, provider or any other individual, direct the request to your privacy lead or the Global Privacy Office.
  • Employees are bound by a duty of confidentiality and are required to ensure protection of personal data. 
  • If you suspect a breach of personal data, you should report it immediately to your line manager or the Information Security team or by sending an email to cyber.incident@nokia.com.

What you need to know

  • Personal data refers to any data that could identify an individual. This may include direct business and human resources-related information such as contact details, personal profiles, or the voice, image, and location of an individual. However, it also includes indirect information such as a national security number, an IP address, a device, or application identifier. When in doubt, you should treat information as personal data.
  • Only access and use the personal data that is necessary to fulfill the purpose it was collected for.
  • Any personal data of our employees, customers, and suppliers must be collected fairly and based on a lawful ground (such as consent, contract, legitimate interest).
  • Data collected must be specific, relevant, adequate, and limited to what is necessary for the legitimate purposes for which it is collected and used.
  • Nokia must be transparent and open with individuals about how and why personal data is collected and used, including individuals and systems that will have access to the data, individual’s privacy rights and where the data may be processed.
  • The cost of privacy violations can be substantial and may expose both the company and you to civil and criminal penalties in certain cases.
  • Know and follow Nokia’s privacy policies, statements, and principles, which can be found here.

Scenario

I am a member of a team that is developing an app to help users troubleshoot their internet access. My colleagues would like to collect the GPS location of users in order to see which users are the most active geographically. Although the app includes a general consent for data collection, it does not specify or allow for an opt out of GPS location data. Should I raise a data protection concern?

Answer

Yes. Collecting GPS location data is not necessary for the core function of the app and goes beyond the delivery of the core service provided (support troubleshooting). Since users are not given the option to refuse only the GPS location data, they cannot use the app unless they consent to all the data collection. Thus, the consent cannot be considered as being freely given and therefore is not valid.

Nokia employees - you can find more information on this topic HERE.