Code of conduct and investigation process
An ethical approach to business
We strive to execute all business activities in a responsible, 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.
Our Annual Ethical Business Training was again mandatory for all employees in 2025 and was completed by 98% of our employees
For the 10th time we were named as one of the World's Most Ethical Companies by Ethisphere.
We have been honored by Ethisphere for the 10th time as one of the World’s Most Ethical Companies®. Nokia is the only Finnish company and just one of two companies from our industry to be recognized in 2026.
This award is a testament to our strong ethical business practices in 2025 and our commitment to a culture of integrity, which includes among other things our commitment to human rights, diversity, social and environmental impact, and risk management.
Code of Conduct
Our Code of Conduct is applicable to all our employees, directors and managers and is available in 20 languages. A separate Code of Ethics applicable to the President and CEO, Chief Financial Officer and Corporate Controller exists to highlight additional responsibilities of those functions.
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).
Investigation process and speak-up culture
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 Investigations team promptly, thoroughly, and impartially. The People organization, Ethics and Regulatory Compliance, Security and Privacy, and subject matter experts may be involved as necessary.
Every employee plays a vital part in helping to keep our company safe. It is critical to report knowledge or suspicion of unethical behavior, including violations of our Code of Conduct, the law, or Nokia's policies. We offer multiple channels for employees and external stakeholders to raise concerns.
The Nokia Ethics Helpline tool is administered by an independent software provider, CaseIQ, 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. Reporting in one’s native language is made easy via the Helpline’s call center that offers over 200 languages, and the Helpline’s web-based tool enables people to report concerns in 22 different languages.
In addition to the Nokia Ethics Helpline, concerns may always be raised with managers, HR personnel/People organization, Legal, Compliance & Sustainability members, and Ombuds leaders who offer a neutral and confidential listening channel for compliance questions and concerns.
Nokia has a strict zero-tolerance stance on retaliation against any employee who speaks up, in good faith, or participates in an investigation about potential violations of our Code of Conduct, policy, or law. We do not tolerate retaliation of any kind.
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 compliance questions and concerns. The vast network of local Ombuds leaders serves as a confidential and neutral listening channel 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.
Anti-Corruption Program and Third-Party Program
Nokia has a robust Anti-Corruption program supported by a dedicated policy, standard operating procedures, effective controls, training, and risk-based due diligence processes supported by the implementation of mitigation action tracking.
Anti-Corruption Center of Excellence
As part of this framework, the Anti-Corruption Center of Excellence (CoE) leads risk mitigation efforts by reviewing high-risk third parties and transactions, travel and entertainment, and requests to give or receive gifts along with monitoring the efficacy of related processes and controls.
The CoE also assesses geopolitical events that may create risk for Nokia across a range of commercial compliance areas, including bribery and corruption, fair competition, human rights, privacy, trade management, and sanctions.
The CoE’s comprehensive, multi-faceted, risk-based approach helps to identify and mitigate risks to the company while empowering our business teams to engage in transactions around the globe.