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responsible business

Responsible business



An ethical approach to business

We strive to execute all business activities in a trustworthy, ethical, and transparent manner. This includes interactions with our employees, as well as with our business partners, customers, and suppliers. We aim to engage only third parties who share our values and work to ensure compliance with the law as well as reinforcing a commitment to ethical behavior.

Nokia has a strong reputation for and commitment to ESG, built on our policies, practices and management systems, but stakeholders are raising the bar and expectations are increasing. We take a proactive and values-driven role in driving responsible business practices internally and with partners and stakeholders. Our 2022 highlights via our 2022 Sustainability report, People & Planet, include:

responsible business highlights 1

We completed our second external
Human Rights Assesment for the
Global Network Initiative in 2022

Our Annual Ethical Business
was again mandatory for
all employees and was completed by

responsible business highlights 2a

of employees

Responsible business
responsible business highlights 5

We achieved our target for percentage
of women in external hiring
by reaching around 27% of total external hires

responsible business highlights 4

In February 2022 we were again
awarded a Platinum medal on the
EcoVadis sustainability scorecard, with
especially high scores for environment
and sustainable procurement

responsible business


We achieved our conflict minerals tracebility target and extended and conducted due diligence to also cover cobalt and mica


In early 2023 once again we were named as
one of the World's Most Ethical Companies by Ethisphere

We have a long-standing reputation for high ethical standards, relying on transparent rules, robust controls, and clear direction to drive success and maintain trust with all stakeholders. We regularly evaluate risks and proactively work with our business groups to mitigate those risks. We optimize our resources to ensure we focus on early identification and proactive mitigation of risks. We maintain our strong culture of integrity, in part, by encouraging our leaders and employees to speak up and report any concerns, without fear of retaliation. We expect our employees to follow the laws, policies and processes that are in place, and hold them accountable if they fail to do so.

In early 2023 we were named for the seventh time as one of the World’s Most Ethical Companies® by Ethisphere. Nokia is one of two companies in the telecommunications sector to be recognized in 2023.

Code of Conduct

  • Conflict of interest
  • Dealing with government officials
  • Fair competition
  • Improper payments (Anti-corruption)
  • Trade compliance
  • Working with third parties
  • Environment
  • Fair employment
  • Health, safety & labor conditions
  • Human rights
  • Privacy
  • Controllership
  • Intellectual property & confidential information 
  • Insider trading

Our Code of Conduct is applicable to all our employees, directors and management, and is available in 20 languages. We also have an additional Code of Ethics applicable to the President and CEO, Chief Financial Officer and Corporate Controller to highlight additional responsibilities of those functions.

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. 

Nokia has a dedicated Third-Party Code of Conduct to address the unique needs of the relationships with third parties and it is available in eight languages (Arabic, Chinese, English, German, Japanese, Korean, Russian and Spanish).

Robust investigation process

Nokia has a vibrant speak-up culture and employs a robust process for investigating concerns raised either to our Ethics Helpline or via the other available channels for reporting concerns.

All reported potential violations and ethical concerns are reviewed and investigated as appropriate by our Business Integrity Group (BIG) daily. BIG strives to respond promptly, thoroughly, and impartially when employees raise concerns. The People organization, Ethics & Compliance, Security and Privacy, and subject matter experts may be involved as necessary.

Providing the tools to enable a speak-up culture

Every employee plays a vital part in helping to keep our company safe. It is critical to report knowledge or suspicion of any unethical behavior, including violations of our Code of Conduct, the law, or Nokia's policies. We offer multiple channels for any employee or other stakeholder to raise a concern.

The Nokia Business Ethics Helpline tool (i-Sight) 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 if they desire. The Helpline enables people 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 Ombuds leaders who are neutral and confidential resources for advice and support.

Nokia has zero tolerance for retaliation against any employee who raises concerns and speaks up, in good faith, 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 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.

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.


Improper payments

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.


Ombuds program

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.


Training program

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.


Speaking up

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.

Our global Ombuds Program

Our Ombuds program fosters and strengthens our speak-up culture and reinforces our anti-retaliation policy. Our local Ombuds leaders actively promote the program and serve as confidential and neutral resources for employees with compliance questions, concerns, and requests for guidance. The global Ombuds network is a critical pillar in Nokia’s speak-up culture and plays an important role in encouraging our employees to voice their concerns.

At the end of 2022, we had 215 Ombuds leaders around the world, and 90 percent of our employees work in locations with an onsite Ombuds leader.


Anti-Corruption Center of Excellence and Third-Party Program

The Anti-Corruption Center of Excellence (CoE) focuses on addressing risks associated with high-risk third parties, transactions, and events that may pose a risk under applicable laws, including anti-corruption and Nokia policies.

We have clear anti-corruption policies, supported by standard operating procedures and implementation guidance documents for key corruption risk areas. Risks and mitigation measures are reviewed with the company’s senior leadership, Board of Directors, and the Audit Committee.

We work closely with third parties, including commercial third parties, licensees and suppliers, to encourage adherence to the same standards of ethical business across all interactions and to help ensure responsible sourcing and globally acceptable labor practices.


Human rights



Addressing Human Rights

We fundamentally believe that connectivity and the technology we provide are a social good that can support human rights and we acknowledge the responsibility that comes with this. Upholding human rights is a complex issue that covers not only the technology we provide, but also our partners, suppliers and our own operations. Therefore, we strive to continuously learn and improve, and we believe that engaging with the broader stakeholder community is the best way forward.

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. As with any large enterprise, Human Rights risks also exist across our entire value chain from our supply chain to our own operations and we therefore have processes and policies in relation to those risks. Our Human Rights Policy is available here.

We have a Human Rights Due Diligence (HRDD) process that targets the potential misuse of the technology we provide. It is a pre-emptive process applied before any sale is made and is used to identify the possible risk level to human rights through potential misuse of our technology. The process examines a country’s long-term commitment to upholding Human Rights, the intended use of the technology in question and the customer type, in order to identify potential risks early in the process and trigger the required HRDD investigation and senior-level approval/denial review where needed. For country risk ratings, we use an external assessment provider. The HRDD triggers are a mandatory part of the sales approval process. Training, tracking results, communication of findings, checkpoints and triggers for the process are reviewed and, where needed, improved by the Head of Human Rights on an ongoing basis.


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, and checkpoints are reviewed and, where needed, continually improved on.

Nokia communicates more on its commitment to transparency in our annual sustainability report, People and Planet. Anonymized Human Rights Due Diligence case outcomes are also published on page 66 in this report. Nokia was the first telco equipment vendor to publish such cases.


We are a Board member of the Global Network Initiative (GNI) and work with other key industry stakeholders in order to increase transparency and learning. The GNI is a unique multi-stakeholder group involving leading ICT companies, investors, academics and civil society groups. Companies participating in GNI are independently assessed every two to three years on their progress in implementing the GNI Principles.

Nokia was the first telecommunications equipment vendor to successfully complete a GNI assessment in 2019. We completed our second independent assessment in 2022 with Foley Hoag LLP as the assessor and are proud to report that the GNI board found we have made good faith efforts to implement the GNI Principles on freedom of expression and privacy with improvement over time.

Human rights across our business

For more information on Human Rights across aspects of our business visit the pages below.


Responsible Business Innovation



Responsible AI

At Nokia, we believe in collaborating with partners, customers and industry players to accelerate innovation and progress. There is no question that AI has delivered numerous benefits in our everyday lives, but AI also carries risks. For AI to be embraced by our society, we need to make AI ethical. AI systems must be fair, reliable and accountable. They must cause no direct harm. They must be environmentally and socially sustainable. And they must protect our privacy. This is what Nokia Bell Labs calls Responsible AI.

Nokia has defined six principles that should guide all AI research and development in the future. We believe these principles should be applied the moment any new AI solution is conceived and then enforced throughout its development, implementation and operation stages. These principles not only reflect the future of AI standards but also comprehensively account for our industry’s renewed focus on environmental sustainability, social responsibility and good governance.

Responsible AI, however, is more than a business imperative. Rather than being perceived as a set of rules and guidelines that limit innovation, these 6 Pillars should be seen as an opportunity for Nokia to become a leader in ethical business practices in our industry. By embracing responsible AI, we are starting down a path toward building AI systems that offer a true competitive advantage and helping shape the AI conversation for decades to come.

Nokia also participates in international standardization to ensure that these principles are included in the ground rules for using AI and standards which set the basis for responsible use of AI. 

Read more: Responsible AI

We call these principles the 6 Pillars of Responsible AI

1. Fareness

2. Reliability, Safety, and Security

3. Privacy

4. Transparency

5. Sustainability

6. Accountability

responsible supply chain

Responsible Supply Chain

Our supply chain is a critical component of our own reputation and extended impact. We work with both customers and suppliers to drive transparency, sustainability and good ethical business practices in our long and often complex supply chain.

We emphasize active engagement with our value chain, including our suppliers, to raise the standards in our ecosystem in key ESG areas like the environment, labor rights and ethical behavior. We have designed our sustainable sourcing program around 6 core pillars based on materiality assessment and group sustainability priorities: Supplier Due Diligence, Climate, Circularity, Responsible Minerals Sourcing, Supplier Development and Learning, Industry Collaboration.