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Compliance policies:

We safeguard our assets

Controllership

Nokia implements appropriate controls to ensure that it represents its financial data accurately, completely, and consistently, protects its assets, and reports its transactions in a timely and objective manner that faithfully reflects their actual impact on business performance.

Nokia is committed to complying with the applicable laws and regulations in all the countries Nokia is operating in that govern its financial accounting and reporting to government agencies, investors, and the public.

Check each tab for all our Code policies.

What to watch out for

  • Financial transactions recorded in error, with the wrong date or with a misleading description, including false expenses and purchase orders or inaccurate time sheets and vouchers.
  • Transactions that do not make fundamental business sense, decisions that are inconsistent with sound business economics, or financial results that do not appear consistent with actual business performance.
  • Efforts to avoid appropriate reviews for a transaction or actions inconsistent with an employee’s level of authority.
  • Physical assets that are not appropriately protected against loss or theft, or any effort to dispose of an asset without proper authorization.
  • Any absence of controls on transactions such as dual signatures on checks or required approvals on expenses, particularly where cash is involved.

What you need to know

  • Make and maintain complete and accurate records of Nokia’s financial transactions and assets, including operating metrics and results, to ensure a complete audit trail.
  • Pay close attention to the safekeeping of Nokia’s financial, physical, and informational assets, including intellectual property.
  • Before signing a document or approving a transaction, verify the facts and completeness of the information, and consider the underlying business rationale for the approval. Check your own signature authority for such a transaction before you sign it.
  • Ensure that Nokia’s accounting and retention procedures, as well as other applicable accounting principles and regulations, are consistently followed; when in doubt, ask.
  • Do not create fraudulent records, falsify documents, or otherwise misrepresent facts, transactions, or financial data. Be candid and transparent.

Scenario

My team did not utilize all the budget approved this year. To maintain the same funding amount next year, is it acceptable for me to ask a vendor to pre-bill Nokia this year for one of next year’s projects?

Answer

No. This would qualify as falsifying expenses recorded in our books and records, misrepresenting when the company would incur the expense. The law requires us to maintain accurate books and records and the company could face significant fines.

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

Intellectual property and confidential information

Nokia invests in and rewards innovation.

Nokia’s intellectual property – which includes patents, software, and other copyrighted materials; know-how and trade secrets; and brands and trademarks – is among its most valuable assets.

We actively protect our intellectual property and follow Nokia classification and handling guidelines for our intellectual property and confidential information. We respect the valid intellectual property and confidential information of others.

What to watch out for

  • Obtaining or using ideas, material, or information belonging to another person or company without proper authorization, which could include copying or using images, open source software, unsolicited ideas from outsiders, or written material obtained from online sources or third parties.
  • Giving licenses, rights, or access to our intellectual property or other information without authorization or accepting intellectual property or confidential information without consulting Legal and Compliance.
  • Sending sensitive information to unattended printers, discussing confidential information openly when others might be able to hear, or creating written material without labeling it according to Nokia information classification and handling instructions.
  • Misuse of Nokia intellectual property or confidential information by others, which might include for example “reverse engineering” of Nokia’s patented products, processes, services, or designs. Report such misuse immediately to Legal and Compliance.
  • Failing to honor your obligations under a nondisclosure agreement or invention assignment agreement between you and Nokia.

What you need to know

  • When dealing with intellectual property or confidential information, ask these questions:
    • Who owns this? May I use it?
    • With whom may I share this? How do I protect its value?
    • Has the term of my licensed use expired?
    • If so, is there any action I need to take?
  • Authorization to grant rights under Nokia-owned intellectual property, particularly rights under patents, is strictly limited, and you must not grant such rights without the required internal approvals.
  • Protect Nokia confidential information and trade secrets from unauthorized disclosure and misuse, and do not share such information with third parties except under approved terms that restrict its disclosure and use.
  • Respect and protect the intellectual property and confidential information of others with the same degree of care we afford our own and according to the terms of any applicable agreement.
  • Follow Nokia’s processes and engage our intellectual property teams to help you properly harvest, protect, and enforce intellectual property and confidential information rights, including the review of any conflict of interest situations that may impact Nokia’s intellectual property.

Scenario

I have just developed an idea to solve a technical problem. How can I find out if the idea should be protected by a patent?

Answer

The first stop should be the Nokia Inventor Central web page, where you will find information on the invention submission process, patent protection, inventor recognition, and more. If you have further questions, reach out to Nokia’s Intellectual Property team. 

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

Insider trading

Nokia is a large, global, publicly traded company. Virtually every country regulates its capital markets, and a key element of such regulations relates to equal access to information about the shares traded on the exchange.

In their work, employees may learn material, non-public information about Nokia or other companies. Using this material, non-public information for personal or financial benefit, for example to buy or sell shares, or sharing this information with others, impairs the integrity of the market, violates our policies, and is likely a violation of the law.

What to watch out for

  • Buying or selling a security based on information you heard or learned at work or anywhere else that you believe will affect the price of the security once that information becomes publicly known.
  • Sharing non-public information about Nokia or other companies with anyone such as friends, family, or business associates who might then use this information to engage in financial trades.
  • “Tipping off” or recommending Nokia or other securities to anyone such as friends, family, or business associates when you might have material, non-public information about Nokia or other companies.
  • Engaging in any trading activities when you are in possession of inside information. If you are a Financial Reporting Person, as defined in the Nokia Insider Policy, you also need to follow the closed window periods specified in the Policy.

What you need to know

  • Inside information means any material, non-public information regarding a company or its securities that, if disclosed, would likely have a significant effect on the price of those securities or influence one’s decision to buy, sell, or hold the securities.
  • While holding inside information, employees are prohibited from:
    • Trading in (purchasing or selling, directly or indirectly) the company’s securities;
    • Recommending or advising others in trades in the securities;
    • Disclosing such inside information to another person.
  • If you believe that there is a legitimate business reason to disclose inside information in the normal course of your employment, please consult with Legal and Compliance or the designated project owner of the related insider project before doing so.

Scenario

I have learned that Nokia is considering acquiring a small, publicly traded software company. As long as it will not benefit me personally, can I share this information with someone who could acquire some shares of this company in anticipation of the acquisition?

Answer

No. The sharing of material, non-public information violates the Nokia Code of Conduct and Nokia policies, and is generally illegal.

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