Conducting our business with integrity
Trust, responsibility, and ethical behavior define how we operate across our value chain.
Our business is built on the foundation of trust. Our Code of Conduct expresses our personal commitment to earn this trust every day, in all of our business activities and in every country where we work. It reflects our values through clear and simple direction for all of our employees and business partners and defines the principles of ethical and compliant business practices.
In February 2021 we were named for the fourth consecutive year (2018-2021) and the fifth time overall as one of the World’s Most Ethical Companies® by Ethisphere and were one of three winners in the telecommunications industry and the only Finnish company to be honored.
World’s Most Ethical Companies” and “Ethisphere” names and marks are registered trademarks of Ethisphere LLC.
Code of Conduct
Our Code of Conduct is applicable to all our employees, directors and management, and is available in 23 languages here.
Our compliance corner
Explore more about our ethics and compliance activities through blogs and opinion pieces by our Chief Compliance Officer & Deputy CLO and other experts.
We also have a Code of Ethics applicable to the President and CEO, Chief Financial Officer and Corporate Controller. 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.
Ethics and compliance - what we do
Nokia has created and maintains an Anti-Corruption policy and related standard operating procedures. Our Anti-Corruption Center of Excellence reviews hundreds of transactions, third parties, and requests to give or receive gifts, travel and entertainment, to name just some of the work happening every day.
All Nokia employees are prohibited from offering, giving, or receiving improper payments. Any agent acting on behalf of Nokia must meet the same standards.
Dealing with government officials
Giving to a third party “anything of value” that is intended to influence a business action may be considered bribery. Nokia employees are expected to exercise extraordinary caution when dealing with government officials which can include employees of a state-owned customer enterprise.
Nokia’s Ombuds program is designed to champion a speak-up culture that empowers employees to raise and discuss compliance questions and concerns. The vast network of local ombuds leaders promotes the program and serves as confidential and neutral resource for any compliance questions, concerns and requests for guidance.
Nokia’s compliance training portfolio consists of online mandatory and targeted training and live sessions. To supplement our annual mandatory Ethical Business Training, we also deploy online microlearning modules on high-risk topics to specific target audiences based on location and/or job function.
Conflict of interest
Nokia has a Conflict of Interest (COI) policy which provides important information and guidance to help employees understand, recognize, disclose and resolve conflicts of interest. Consistent with the COI policy, all employees are required to disclose conflicts of interest using the confidential web-based COI disclosure tool.
All Nokia employees are empowered to raise concerns and speak up about potential violations of our Code of Conduct. Retaliation of any kind is not permitted, and we take seriously all allegations regarding any form of reprisal and investigate such concerns thoroughly.
How we protect the data of our customers, employees and other sensitive data is critical to our business and reputation. With the growth in the deployment of new technologies towards a world where everything and everyone are connected and interconnected, data privacy and security issues are also on the increase.
Providing the tools to enable a speak-up culture
All employees are empowered to raise concerns and speak up about potential violations of our Code of Conduct. Retaliation of any kind is not permitted, and we take seriously all allegations regarding any form of reprisal and investigate such concerns thoroughly.
Our commitment to compliance with all relevant laws and regulations and to building and maintaining trust and credibility with all stakeholders is unwavering. We ensure the tools and means are available for any employee or other stakeholder to raise a concern and bring an issue to the attention of the compliance team. Whichever way the individual chooses to report a concern, it is handled confidentially by a diverse team of compliance professionals. Reporting of concerns can be done anonymously. We offer email, website and call options as well as an expanding network of ombuds individuals who can be approached personally for advice and support.
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 and ombuds representatives, concerns may always be raised with line managers, HR personnel, and Legal and Compliance members.
Our global Ombuds Program
At the end of 2020 we had 200+ local ombuds leaders and 85% of our employees work in locations with an onsite Ombuds Leader. Ombuds Leaders provide a safe and strictly confidential space to speak up. They remain completely neutral, impartial, and non-judgmental. Over 1 500 questions and concerns have been raised to the Ombuds network over the past three years.
We are committed to respect and support the Human Rights principles and values laid out in the International Bill of Human Rights (consisting of the Universal Declaration of Human Rights and its related covenants), the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, Organization for the Economic Co-Operation and Development (OECD) guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights.
We fundamentally believe that connectivity and the technologies we provide are a social good that can support human rights by enabling free expression, exchange of ideas, education and economic development. Simply put, our technology allows billions of people around the world to communicate and access information and we are proud of this.
While we embrace fully our technological advancements, we are humbled by the responsibility that comes with this and acknowledge the risks. The most salient human rights risks related to our company and business involve the potential misuse of the technology we provide to infringe on the right to freedom of expression and right to privacy. As with any large enterprise, Human Rights risks also exist across our entire operations from our supply chain to our own operations. We have processes and policies in place for those.
Human rights across our business
For more information on Human Rights across aspects of our business visit the pages below.
Human Rights Due Diligence
The Nokia Human Rights Due Diligence (HRDD) process is a non-commercial cross company investigative process covering sales as well as R&D. This process is pre-emptive and rigorous. It is used to identify the potential risk level of human rights violations through the misuse of our technology before any sale is done or a solution is developed, while also attempting to identify ways to mitigate these risks to ensure compliance to our Human Rights Policy.
HRDD case investigations in 2020, internal training and continued experience with our due diligence processes may have helped sales teams identify cases that would likely be denied and either therefore avoid them completely or structure the offerings to avoid undue risk to human rights. Hence, in 2020, there have been more cases that require conditions attached and no cases which were determined to be a “No go.”
were resolved as “Go”
as “No go”
as “Go with conditions”.
HRDD is centrally managed by a full-time Head of Human Rights who reports to a senior manager, using a global process to ensure accountability, reportability and consistent practices across Nokia. The Head of Human Rights function is part of the Sustainability team in Corporate Affairs and works across the entire business ecosystem from business groups to sales to ensure adherence to the Human Rights Policy. The Human Rights Panel, chaired by the Head of Human Rights, is a cross functional senior group including technical, legal, marketing and communications senior experts that is called upon when needed to analyze cases from all angles in terms of potential risk to Human Rights. In addition, the Human Rights Governance Council consists of senior executives who review cases where agreement could not be reached earlier, with the final decision being made by the Nokia President and CEO.
Training and transparency
Training is a key aspect of ensuring our commitments to Human Rights are upheld. Training, tracking results, communication of Human Rights Due Diligence findings, checkpoints are reviewed and, where needed, improved on an ongoing basis.
Nokia communicates more on its commitment to transparency in our annual People and Planet Sustainability report. Anonymized Human Rights Due Diligence case outcomes are also published in this report. Nokia was the first telco equipment vendor to publish these.
We aim to be transparent and active by working with key industry stakeholders including, amongst others, through membership in the Global Network Initiative (GNI). GNI is a unique multi-stakeholder group involving leading ICT companies, investors, academics and civil society groups.
In April 2020 the public version of our first ever GNI human rights assessment conducted by the independent assessor Foley Hoag LLP was released. We are honoured to report that the GNI Board found Nokia has made good faith efforts over time to implement the GNI Principles on freedom of expression and privacy.
Responsible supply chain
Our supply chain is an important but complex part of our business and our reputation, and despite its complexity and depth we work hard to try to ensure it is transparent, and ethically, socially and environmentally well-managed.
We have robust procedures and processes in place and we continually improve them where necessary. These are supported by clear, well communicated policies. We identify and understand the risks associated with our supply chain and build and implement the programs and actions that help mitigate those risks. We employ a variety of audits and assessments to verify the integrity of our supply chain. We engage and increase supplier capabilities through learning and where necessary instigate remediation activities.
We maintain a Corporate Responsibility risk map of our suppliers which we update regularly. See below