Speaking up

Nokia is committed to maintaining a culture in which our employees feel comfortable raising concerns about potential violations of the Code of Conduct. Nokia will not tolerate any adverse employment action against an employee who raises a compliance concern in good faith. Any employee who retaliates or participates in retaliating against another employee for raising a compliance concern will be subject to strict discipline, up to and including termination of employment.

Concerns can be raised to the Ethics Helpline anonymously (although a small number of jurisdictions impose certain limitations on anonymous reporting). Should you elect to raise your concern anonymously, you will not be required to provide your name or other identifying information. You should, however, provide sufficient details regarding your concern so that Nokia can follow up appropriately. Nokia respects anonymity and uses the Ethics Helpline case management system to communicate with anonymous reporters.

We take each concern seriously. The Legal and Compliance team will review and promptly address your concern for appropriate follow-up and resolution. This may involve assigning an investigator to look into the concern. The investigator may be assisted by auditors or other experts as needed to fully understand the concern. The team will track your concern from initiation to its resolution to ensure that it receives careful and thorough attention.

At the end of the investigation, if it is determined that an employee or third party working with Nokia has violated applicable laws, policies, or the Nokia Code of Conduct, corrective action including disciplinary action may be imposed. We will share feedback, while respecting confidentiality, with the person who raised the concern and share lessons learned with the wider business when possible and appropriate.

An important aspect of our compliance program is taking effective corrective action and, where appropriate, employee disciplinary action. Subject to local law, disciplinary action, up to and including termination of employment, will depend on several factors, including but not limited to:

• The conduct being intentional or deliberate or involving a law violation;
• The conduct involving dishonesty, theft, fraud, or personal gain;
• The conduct being repetitive or systemic or involving efforts to conceal;
• The employee’s full and complete cooperation (or lack thereof) with the investigation;
• The employee’s seniority within the organization; the higher the level of seniority, the higher the responsibility to act and to lead ethically.

Employees will be provided with an opportunity to present any additional relevant information that may not have been considered before a disciplinary decision is made.

Nokia’s speak-up culture and anti-retaliation policy empower employees to openly raise and discuss compliance questions and concerns and to seek guidance. The Ombuds Program is a critical element of our compliance program and culture. It is designed to support and strengthen an environment of fairness, equality, respect, and honesty, where everyone is expected to deliver results without compromising integrity.

Nokia has appointed a global network of local Ombuds leaders who are selected and trained to provide neutral and confidential guidance to its employees on ethical and compliance matters.

In situations where next steps may not be very clear, Ombuds leaders provide guidance to employees, help determine if a matter warrants being reported, and identify appropriate resources if needed.

Email: ombuds@nokia.com

Ombuds leaders are a supplemental channel for raising compliance concerns in addition to managers and the Legal and Compliance and People organizations. Concerns can also be raised to the Nokia  Ethics Helpline via the Ethics Helpline icon on your desktop PC or by telephone. You may also write to our CEO or our Board of Directors. All concerns, irrespective of the channels used to report, are handled confidentially and thoroughly investigated.