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Ethical business

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Our commitment to upholding the highest principles of business ethics and integrity defines us as a company and distinguishes us from many of our competitors. Throughout our more than 150-year history, we have nurtured a culture of high integrity where every employee is held accountable and responsible for upholding our ethical values. 

We have a Code of Conduct that is applicable to all our employees, directors and management, as well as a Code of Ethics applicable to the President and CEO, Chief Financial Officer and Corporate Controller. We apply our Code of Conduct, not just to our own employees, but also in our daily activities and business dealings with all our external stakeholders. Leadership involvement and oversight on ethics and compliance are provided by the Board of Directors via the Audit Committee. Compliance management is further supported by both global and regional compliance committees. 

We have five simple principles which run through everything we do and define how our employees are expected to behave:

  • Obey laws and follow policies
  • Be fair and honest
  • Treat each other with respect
  • Declare conflicts of interest and avoid appearance of impropriety
  • Report any concerns promptly

In 2017, we executed ambitious goals in a year of significant change by building on the theme of Compliance Reimagined. Key initiatives supporting these goals were implemented throughout the year, including: Strengthening leadership accountability by finalizing the compliance governance model, and establishing business-owned Compliance Operating Reviews as the cornerstone of the global compliance program, continuing deployment of the Nokia Compliance Controls Framework (CCF) and addressing identified gaps to mitigate compliance risks, establishing a specialized Center of Excellence (CoE) to address anti-corruption risks, and building a mindset of compliance as a strategic business partner. We also enhanced key program elements, including: right-sizing the risk assessment program for the new company, re-energizing the compliance program owner network of subject matter experts, and creating a robust and comprehensive communications calendar.

We were honored by the Ethisphere Institute as one of 2018’s World’s Most Ethical Companies owing to our past achievements, present strong program, and bold vision for the future. The award is given annually by Ethisphere, the leading organization for corporate ethics and compliance, to a small and select group of companies, following a rigorous evaluation process into the company’s policies, processes, social responsibility, governance, and compliance culture.

For more details on our ethics and compliance programs, look at pages 77–89 of the People & Planet Report 2017.

Building on a Solid Foundation of Integrity by Jeffrey Eglash, Chief Compliance Officer.

The evolution of compliance at Nokia reflects the company’s journey from humble beginnings as a paper and rubber maker to a global leader in telecommunications infrastructure and technology. While integrity has long been a core value, our compliance program has had to adapt as the company has entered new industries and markets.

Compliance at Nokia has remained agile against the backdrop of an ever-shifting risk landscape, as issues such as privacy, information security and trade compliance take on ever-greater importance. If the only constant in today’s world is change, then adaptability and flexibility must be the watchwords of an effective compliance program.

Our compliance program has two aims: enabling business, while also protecting the company. Rather than ignoring the tension between these aims, recognizing it and balancing the competing aims is central to our role. We strike the balance by understanding our business colleagues’ goals and the strategies they use to deliver them and by working closely with them to assess, analyze, and mitigate compliance risks they may encounter along the way. 

We have a well-deserved reputation for integrity, and as a team we feel a strong responsibility to preserve and enhance it. We are, therefore, proud to have been named by Ethisphere as one of 2018’s World’s Most Ethical Companies, recognizing us as a global leader in corporate ethics – the second time Nokia has been so honored.

Though our compliance program has several key elements, including effective and engaging compliance training and communications, robust audits and risk assessment processes, and more, it ultimately comes to this: at Nokia, compliance is a shared responsibility. It starts with every employee. They are expected to know and understand the rules, to ask questions when they are uncertain, and to speak up whenever they see something that doesn’t seem right.

Our leaders at every level – managers, supervisors, and executives – “own” compliance, meaning they, rather than lawyers or compliance officers, are responsible for making and being accountable for decisions. We expect them to set the tone and to lead by example. Supporting the entire company are compliance experts, responsible for educating employees and leaders to enable sound and responsible decision-making and for escalating matters, if needed, to ensure that decisions are always consistent with the company’s commitment to integrity. 

It is this vision of compliance as a shared responsibility that serves as our foundation for compliance. Nokia is recognized for offering world-class products and services and cutting-edge technology. As we build on our long tradition of integrity, we strive every day to ensure that excellence and innovation also define compliance at Nokia.

Employees and business partners are empowered to speak up in Nokia’s open reporting culture.

Nokia is firmly committed to fostering an environment that encourages and welcomes views and inputs from all our employees, as well as others with whom we do business, about any potential violations of our Code of Conduct. 

Our Code of Conduct sets the tone for how we conduct business globally. Our commitment to compliance with all relevant laws and regulations and to building and maintaining trust and credibility with our customers, partners, employees, suppliers, shareholders, and other stakeholders is unwavering. 

An important component of building a culture of trust is ensuring that employees and business partners are empowered to speak up when something is not right. To that end, our Code of Conduct and related compliance policies provide for various mechanisms for reporting compliance concerns, or simply for asking questions or requesting guidance about ethical dilemmas.

  • The various mechanisms for bringing an issue to the attention of the compliance team are listed below. Whichever avenue one selects, the report or concern is handled confidentially by a diverse team of compliance professionals.



  • The Nokia Business Ethics Helpline is managed by an independent supplier and is available 24 hours a day, 7 days a week. Calls and conversations are entirely confidential, and a reporter may remain anonymous. The Helpline enables persons to report concerns in more than 23 different languages.
  • In addition to the Nokia Business Ethics Helpline, concerns may always be raised with line managers, HR personnel, Legal and Compliance members, and local Ombuds representatives, who provide a local, impartial, and non-judgmental means for employees to raise questions or concerns.

We have zero tolerance for retaliation, and we encourage anybody who has concerns regarding compliance reporting retaliation to immediately contact a member of the compliance team. We are dedicated to ensuring that our employees are aware of the multiple reporting channels available to them and that they have confidence in our non-retaliation policy and feel comfortable in raising matters.

At Nokia, we continuously strive to reinforce our open reporting culture and encourage employees to report potential issues that violate our policies or the laws of any of the countries in which we operate. We stress the importance of operating within the law and staying true to our ethical culture because it is vital for the continued success of our business, our company identity, and our reputation. Our open reporting program and processes support our commitment to doing business the right way.  

Effective and engaging compliance training for all employees is an essential component of Nokia’s compliance program.

We require that every employee complete annual training in ethical business practices, as well as other targeted training, on topics such as anti-bribery, competition law, conflict of interest, and privacy. 

Annual mandatory training supports employees in achieving the high ethical standards expected at Nokia. By participating in mandatory and recommended training, employees are equipped with the skills and knowledge to make informed decisions, reduce liability risks, and operate more effectively, thereby protecting themselves and the company. 

All new hires are assigned an onboarding curriculum, designed to help them understand Nokia, its legacy, and its values. Board members are also required to complete annual compliance training. 

Compliance training is developed based on defined compliance topics of importance, new and/or updated policies, potential risks identified, and any changes to laws or regulations. Annual mandatory training is assigned to all employees globally with a predefined due date.

In addition, targeted training may be assigned to specific roles and areas to address risk, and recommended training can be assigned and completed at any time during the year. 

Web-based trainings are delivered by NokiaEDU, the company’s learning organization. NokiaEDU provides continuous learning, professional development, and business-impacting learning solutions. To encourage 100 percent participation, NokiaEDU tracks mandatory completion results and publishes statistics.

Beyond web-based training modules, we emphasize live trainings to increase engagement and understanding. Live trainings help to build our compliance culture and provide the opportunity for employees to discuss business issues, ask questions and find practical solutions, often in high-risk areas.

We have developed live training resources across a wide range of topics which can be customized for local use. Live training is conducted on an “as-needed” basis and is also provided to employees who do not have web access.

We also utilize engaging videos, real-life scenarios, and an easily accessible policy app as part of our training and awareness program. To further enhance engagement and promote integrity, we host a company-wide “Integrity Week” that includes a full suite of messaging, compliance-related activities, local informative sessions, and a compliance hero award program.

Compliance training provides an opportunity to lay the groundwork for a healthy workplace culture, encourage discussions, and proactively identify and address potential issues before they arise. 

“The aim of education is the knowledge, not of facts, but of values.” 
William S. Burroughs 

Fostering a speak-up culture and providing employees with a local and confidential network to safely raise compliance questions and concerns.

Nokia’s Ombuds program is designed to champion a speak-up culture that empowers employees to openly raise and discuss compliance questions and concerns. In addition to the normal channels for reporting, the Ombuds program provides a supplemental channel, comprised of a global network of on-site, local Ombuds Leaders. With more than 130 local Ombuds Leaders, the Ombuds network continues to grow.

We want to ensure that employees feel confident raising issues if they perceive misconduct has taken place and that they understand that Nokia has zero tolerance for retaliation against those employees who do speak up. Ombuds Leaders provide a safe and strictly confidential space to speak up. They remain completely neutral, impartial, and non-judgmental.

In addition to the standard reporting channels of Line Managers, Legal & Compliance, HR and the Ethics Helpline, the global network of Ombuds Leaders is a key pillar of our open reporting culture. Ombuds Leaders provide not only another means for employees to report suspected policy or law violations but also offer a safe place where employees can talk through compliance questions and concerns and receive guidance on compliance issues.

We are dedicated to ensuring that employees are aware of the multiple reporting channels available to them, understand and have confidence in our non-retaliation policy, and feel comfortable raising matters. It is extremely important for employees to speak up and raise concerns, as doing so allows the company to find and remedy problems early before they become more difficult to solve.

The aim of the Ombuds Program is to provide a confidential avenue for employees to raise concerns, to keep Nokia and its employees safe, and to assure that suspected wrongdoing is reported and addressed in a timely manner, as appropriate, without retaliation of any kind.

We rely on the voice of our employees.

Nokia is recognized as one of the 2018 World’s Most Ethical Companies.

The World's Most Ethical Companies® designation honors companies who recognize their critical role to influence and drive positive change in the business community and societies around the world and who work to maximize their impact wherever possible.

The World’s Most Ethical Company award is given annually by Ethisphere, the leading organization for corporate ethics and compliance. Following a rigorous and comprehensive evaluation of our compliance program, corporate governance, and culture of integrity, Nokia was one of five companies in the telecommunications sector to receive the 2018 award.

Companies are assessed based upon the Ethisphere Institute’s Ethics Quotient® (EQ) framework, which offers a quantitative way to assess a company’s performance in an objective, consistent and standardized manner. Questions included in the Ethics Quotient are periodically reviewed and updated based on changing regulations, expectations, and best practices.

Scores are generated in five key categories: Ethics and compliance program (35 percent); corporate citizenship and responsibility (20 percent); culture of ethics (20 percent); governance (15 percent); and leadership, innovation and reputation (10 percent).

Research has found that, when indexed, listed World’s Most Ethical Companies outperformed the U.S. Large Cap Index over five years by 10.72 percent and over three years by 4.88 percent. Ethisphere refers to this as the Ethics Premium.

Our customers and partners can rely on us and our employees not only for innovation and quality but also for our resolute commitment to routinely translate Nokia values into actions. Ethics, integrity, and compliance are embedded deep within our culture. This award represents our continuing commitment to values-based leadership and ethical practices.

We are proud to have been honored with this prestigious award and will remain vigilant and proactive when it comes to preserving and enhancing our core values as the foundation of our ethical culture, our strategies, and our actions.