Code of conduct, robust investigation process, and compliance corner
An ethical approach to business
We look 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.
Nokia has a strong reputation for and commitment to Environmental, Social and Governance (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. Achievements in 2025 include:
Our Annual Ethical Business Training was again mandatory for all employees and was completed by 98% of our employees.
For the ninth time 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 them, optimizing our resources to ensure we focus on early identification and proactive risk mitigation. We maintain our strong culture of integrity by encouraging our leaders and employees to speak up and report any concerns, without fear of retaliation. We expect our employees to follow the law and adhere to policies and processes holding them accountable if they fail to do so.
We have been honored by Ethisphere once again as one of the World’s Most Ethical Companies®. Nokia is one of two companies in the telecommunications sector and the only Finnish company to be recognized in 2025.
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.
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 Investigations team daily. Investigations team 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 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.
Contact us
Web:
https://nokiacms.i-sight.com/portal
Phone:
https://nokiacms.i-sight.com/portal/dialing-instructions
Email:
ethics@nokia.com
Ombuds:
ombuds@nokia.com
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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
To mitigate bribery and corruption risk, Nokia has a robust Anti-Corruption program that includes an Anti-Corruption policy and related standard operating procedures, processes, controls and training. Our Anti-Corruption Center of Excellence implements risk mitigation efforts in this area and, as part of this work, is responsible for reviewing high-risk transactions, third parties, travel and entertainment, and requests to give or receive gifts. This team also conducts monitoring to ensure the efficacy of our processes and controls.
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.
Conflict of interest
Nokia has a Conflict of Interest (COI) policy that 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 compliance questions and concerns and speak up about potential violations of our Code of Conduct, policy, or law. Retaliation of any kind is not permitted, and we take seriously all allegations regarding any form of reprisal and investigate such concerns thoroughly.
Privacy, data and cyber regulatory
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 that connect and interconnect everything and everyone, data privacy, cyber incidents, and security issues are on the rise.
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 2025, we had 215 Ombuds leaders around the world, and 80 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 the review of high-risk third parties, transactions, and geopolitical events that may pose risk to Nokia under various commercial compliance areas, including bribery and corruption, fair competition, human rights, privacy, trade management, and sanctions restrictions.
With respect to bribery and corruption, Nokia’s anti-corruption program includes robust analysis of third parties and transactions in which third parties are involved, including risk-based due diligence processes and the implementation of mitigation action tracking. This compliance program is continually evaluated to ensure that it incorporates emerging risks. It is 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 ensure that they are aware we expect them to adhere to Nokia’s high standards of ethical business and to help ensure responsible sourcing and globally acceptable labor practices.
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.