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 2023 include:
We completed our second external Human Rights Assessment for the Global Network Initiative, with the assessors highlighting Nokia’s strong human rights culture.
Our Annual Ethical Business Training was again mandatory for all employees and was completed by 98% of our employees.
For the eighth 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 three companies in the telecommunications sector and the only Finnish company to be recognized in 2024.
This award is a testament to our strong ethical business practices in 2023 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 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.
Anonymized illustrative examples of 2023 reported concerns and actions taken after investigation by our Investigations team
Issue raised |
Our guidance |
Actions taken |
|---|---|---|
A resigning employee raised a concern about a manager’s misuse of GPS telemetry to track field service maintenance team members. The investigation established that the manager had a very problematic attitude toward health and safety and used the GPS technology not for its intended use but rather in an intrusive manner to monitor the team’s movements. This is contrary to the company’s privacy rules on the use of data as well as the intended purpose of the technology, i.e., safety of our employees |
At Nokia, safety and well-being are paramount. Nothing is more important than our people going home safely at the end of the day. Nokia also takes its privacy obligations seriously. The cost of privacy violations can be substantial and may expose both the company and the employees to civil and criminal penalties in certain cases. |
The manager in question was terminated, and the concern raiser subsequently withdrew their resignation. |
A manager instructed engineers to create dummy customer project service cases for purposes of meeting internal, output-related KPIs. The investigation confirmed that the team did not provide actual services for the fake cases that were created. Achieving the KPIs and headcount reduction concerns, if KPIs were not met, were the main drivers for the misconduct. Line managers reporting to said manager did not review the new entries adequately. |
We expect everyone to do business the right way, regardless of commercial or other pressures. Nokia’s leaders, including all line managers, are compliance stewards for their organizations and are responsible not only for achieving business results but also for driving a culture of integrity throughout their organizations. |
Disciplinary action was taken against the manager and the others implicated in the case. Controls were introduced to mitigate the risk of a recurrence in the future. |
Multiple concerns were raised to the Ethics Helpline about an employee who was allegedly directing Nokia subcontractors to use a certain supplier. An investigation identified evidence that supported the allegation and revealed that the employee had a personal interest in the supplier in question. In an interview, the employee lied, even when confronted with email evidence, about their involvement with the supplier. The employee’s conduct was a clear breach of Nokia’s Conflict of Interest Policy and an abuse of the employee’s position. |
Any potential or actual conflict of interest must be disclosed promptly. Undisclosed conflicts are impermissible and can lead to serious consequences for the responsible parties. |
On conclusion of the investigation, the employee resigned. |
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 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. 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 line managers, HR personnel/People organization, 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
24
hours
7
days a week
22
languages
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 a 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 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 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 2023, 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 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 high standards of ethical business across all interactions 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.