Ethics Helpline

What is the Ethics Helpline? 

The Ethics Helpline is a comprehensive and confidential reporting tool developed by i-Sight that assists in concern reporting and case management of compliance and other investigations.

Why do we need a system like the Ethics Helpline?

• We believe that our employees and our reputation for integrity are among our most important assets at Nokia. By creating open channels for communication and concern reporting, we can promote a culture of integrity and a positive work environment.
• Publicly traded companies are generally required by law to have an anonymous reporting channel to identify concerns about accounting and auditing fraud, among other compliance concerns.
• An effective reporting system will augment our other efforts to foster a culture of integrity and ethical decision-making.

Reporting – General

May I report using either the Internet or the telephone?

Yes. With the Ethics Helpline, you have the ability to file a confidential, anonymous report via either the telephone or the Internet.

What type of situations should I report?

The Ethics Helpline is designed for employees to report any violation of our Code of Conduct, policies, SOP’s, or other concerns that require guidance.

If I see a violation, shouldn't I just report it to my manager, security, or the People organization and let them deal with it?

When you observe some behavior that you believe violates our Code of Conduct, you are required to report it. Ideally, you should bring any concerns forward to your direct manager, or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with i-Sight. We would rather you report the concern than keep the information to yourself. The Ethics Helpline provides the ability to report concerns anonymously.

Why should I report what I know? What’s in it for me?
Reporting concerns about potential ethics and compliance concerns is not only the right thing to do, but also required by our Code of Conduct.

Speaking up also helps protect Nokia’s reputation as an ethical company. Corporate misconduct can threaten the livelihood of an entire company.

Does management really want me to report?

Yes, we do. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the Ethics Helpline secure server to prevent any possible breach in security. The Ethics Helpline makes these reports available only to specific individuals within the company who are charged with evaluating and investigating (where appropriate) the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Isn’t this system just an example of someone watching over me?

The Ethics Helpline system concentrates on being a positive aspect of our overall philosophy, and allows us to assure a safe, secure, and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

Reporting Security & Confidentiality

Is it true that any report I send from a company computer generates a server log that shows every website that my PC connects with, and won’t this log identify me as a report originator?

The Ethics Helpline does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to the Ethics Helpline is available. If you feel uncomfortable making a report on your work PC, however, you have the option of using a PC outside our work environment (such as one located at an Internet café, at a friend’s house, etc.) through the Ethics Helpline secure website.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any other Internet portal will remain secure and anonymous. The Ethics Helpline system strips away and does not maintain Internet addresses so that anonymity is totally maintained.

I am concerned that the information I provide the Ethics Helpline will ultimately reveal my identity. How can you assure me that will not happen?

The Ethics Helpline system is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the telephone toll-free hotline confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet based report and an interviewer will type your responses into the Ethics Helpline Web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself if you wish.

Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Our company chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy company. So if you know of any incidents of misconduct or ethical violations, it is your obligation under our Code of Conduct to report it.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. The Ethics Helpline can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The Ethics Helpline system and report distribution are designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report at the Ethics Helpline Web site or through the Ethics Helpline Call Center, you receive a unique report key and are asked to choose a password. You can return to the Ethics Helpline system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into a dialogue where situations are not only identified, but can also be resolved, no matter how complex. An anonymous reporter’s identity is still unknown during this dialogue process.

Are these follow-ups on reports as secure as the first one?

All Ethics Helpline correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

Can I still file a report if I don’t have access to the Internet?

You can file an Ethics Helpline report from any device that can access the Internet. You can file from anywhere you can access the internet. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable, you can call the Ethics Helpline tollfree hotline, which is available 24 hours a day, 365 day.