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:
We completed our second external
Human Rights Assesment for the
Global Network Initiative in 2022
Our Annual Ethical Business
Training was again mandatory for
all employees and was completed by
of employees
We achieved our target for percentage
of women in external hiring
by reaching around 27% of total external hires
In February 2022 we were again
awarded a Platinum medal on the
EcoVadis sustainability scorecard, with
especially high scores for environment
and sustainable procurement
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 (placeholder).
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 23 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.
Contact us
Web:
https://nokiacms.i-sight.com/portal
Phone:
https://nokiacms.i-sight.com/portal/dialing-instructions
Email:
ethics@nokia.com
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
Anti-corruption
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.
Privacy
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.
Collaboration
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
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
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.
Our supply chain approach
Monitoring, assessments, and audits
Robust procedures and processes
Robust procedures and processes
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.
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.
In 2022, we had business with around 11 000 suppliers, and 80% of our total supplier spend was distributed across around 300 suppliers. Our suppliers fall into six broad categories:
- final assembly suppliers
- hardware suppliers for product materials (such as standard components, optical components, semiconductors, electromechanics)
- market services suppliers who support the provision of services to our customers such as in installation and construction,
- managed services around the networks we sell
- IT suppliers
- indirect sourcing suppliers for everyday goods and services we need to run our business such as consulting, legal and marketing.
Our manufacturing suppliers are mainly based in Asia and services suppliers are based around the world. Our final assembly includes our own factories in Finland, India and Poland as well as Flextronics, Foxconn, Jabil and Sanmina supplier sites across 12 countries.
Our largest strategic Original Design Manufacturers, Original Equipment Manufacturers and Components suppliers are published on our website to further increase stakeholder transparency.
Read more in the Responsible sourcing section of our latest sustainability report (FY 2022) pages 68 to 75.
We expect our suppliers to adhere to our Third-Party Code of Conduct and provide them with our Supplier Requirements, including the Responsible Business Alliance (RBA) Code of Conduct and additional, Nokia specific sustainability requirements. The requirements cover topics such as environment, health, safety and security, privacy, risk management, labor and human rights management, and ethics. They are communicated to our suppliers and integrated into our contractual requirements.
We encourage our tier one suppliers (including our final assembly, materials and services suppliers) to apply and cascade the same requirements to their own suppliers. We check this through audits and EcoVadis documentation audits. Transparency and compliance requirements are firmly applied to all supplier relationships, and gifts or entertainment are neither given nor received beyond nominal value items. We investigate and qualify all suppliers, requiring them to comply with all applicable laws and regulations, and show they share the values stated in our Code of Conduct. Ethics and anti-corruption related requirements for our suppliers are detailed in our Third-Party Code of Conduct.
Overview of Nokia supplier requirements
EcoVadis, the world’s largest provider of business sustainability ratings monitors sustainability in global supply chains. We ask our key suppliers for their EcoVadis scorecard rating and are proud of our own where EcoVadis has again ranked Nokia in the top 1% globally in 2022.
Our materiality analysis and Enterprise Risk Management help identify potential supply chain risks. and we carry out more in-depth analyses to determine all supply chain risks through our dedicated Supplier Sustainability Risk dashboard where we look at various sustainability risks, commodity risks and more on a supplier location level. The outcomes are included in our category strategies. We review category strategies annually with our purchasing category leads. Failing to meet established sustainability requirements will block a supplier from being promoted, for example, from restricted to allowed, or to preferred supplier. We also maintain and regularly update a corporate responsibility risk map of our suppliers. In 2022 we expanded our use of digitalization in our supplier safety management program, carrying out remote safety pre-work checks, and live digital health & safety inspections of customer sites while the suppliers were performing their high-risk activities in Mobile Networks business group.
We carry out assessments and audits with our supplier network regularly to help them meet our ethical standards and improve on their performance where needed. Major manufacturing sites are also part of our monthly monitoring for critical labour related issues. Our in-depth audits are aligned with SA8000 methodology, and we implement a range of audits and assessments including:
- Our general supplier requirement audits
- Corporate responsibility in-depth audits
- Supplier Health & Safety Maturity assessments
- Conflict Minerals Audits
- Assessment tools such as EcoVadis and CDP
Highlights related to audits
- 379 supplier assessments conducted using the EcoVadis sustainability rating scorecards.
- 100 onsite supplier audits despite the pandemic restrictions.
- 481 suppliers disclosed climate data, which covers over 60% of Nokia spend.
Awareness raising and good practice sharing
Every year, we host the Nokia Supplier Climate webinar where we share our expectations, 2030 targets and good practices coming from different stakeholders within Nokia such as R&D, Logistics, Travel and Fleet and Real Estate. This is a great example of how our environmental experts from different business units are engaging, summarizing and sharing their insights and learning. The aim is to cultivate good practice across our supplier networks and find innovative new approaches for our suppliers to work on each year.
Climate data collection and reporting
We send out an annual climate assessment questionnaire via CDP to nearly 600 suppliers, supported by practical guidance and sessions on how to measure CO2 and how to fill out the required information. CDP (formerly known as Carbon Disclosure Project), is a global not-for-profit organization that helps cities and companies like ours disclose their environmental impact, with the aim of making environmental reporting and risk management a business norm for all. Following these assessment rounds, results are communicated with suppliers and tailored advice is shared as part of the suggested next steps, based on their performance. When it comes to our final assembly suppliers, data collection and monitoring take place on a much more stringent monthly basis. Performance and reduction projects track and benchmark impact within our own factories.
Supplier Performance Evaluation
Sustainability is an integral part of our supplier performance evaluation and has a direct impact on that evaluation. The diagram shows the components of our Supplier Performance Evaluation model, and details further the input sources for sustainability evaluation.
Rewarding and recognizing best practices
Recognizing great practice is as important as penalizing the bad so Nokia has embedded sustainability/carbon reduction into our Nokia Procurement Diamond Awards which are hosted by our top leadership team. These awards celebrate excellence amongst our supplier ecosystem and pay particular attention to the strides being made across quality, innovation, and sustainability.
Combatting modern slavery, forced labor and labor migration risks
Modern slavery and forced labor of all kinds remain a challenge for all countries and supply chains. It is believed that the pandemic has also worsened the issue as the vulnerable became even more so and unemployment grew. Therefore in 2022 we also conducted an analysis of labor migration and its impacts on our supply chain. We have robust audit and assessment processes and procedures in place. We continue to raise awareness of modern slavery through workshops and training with suppliers on the topic of good labor practices and inclusion and diversity. Our work includes advocating for greater dialog on non-discrimination of ethnic and other minorities
