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Nokia Code of Conduct

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Nokia

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Dear Colleague,

Stephen Elop

President and CEO, Nokia

Nokia products touch the lives of billions of people,from every corner of the earth, from every type ofculture, from every age and background, every day. Infact, we made it our mission to get a mobile phone intothe hands of everyone, because we believe technologyshould be a powerful force for societal advancement. Byconnecting people to mobile products and services, wecan help people improve their lives no matter what theydo, where they live or what their circumstances are.

However, with this impact and inuence, comes agreat amount of responsibility. As a leader in mobiletechnology, Nokia has an obligation to also raise thestandard for ethical business conduct. This means not

just nding ways to avoid negative impact, but actively,constantly looking for ways to make situations better.Thus, we have established a Nokia Code of Conduct tohelp us do the right thing as a company.

The Nokia Code of Conduct was rst published in 1997,and we continue to revise and update the code as theworlds of technology and business evolve. However, thefundamental principles remain consistent. It is notenough that we strictly adhere to laws and regulations,but we must instill the highest degree of ethical conductin every action we take.

As stewards of business, Nokia must foster diversity andequality. We have zero tolerance for corruption. We willbe environmentally aware in all things we do. And, our

products, our technology and our people must positivelycontribute to human rights. As you engage in the com-munities of the world, the Code of Conduct is your trustedresource to help you address ethical issues you might face.

At Nokia, we have the reach, the scale and the values to helppeople around the world see, seize and share opportunities.We believe that when people nd these opportunities, theycan fulll their potential, and the world becomes a betterplace for all of us.

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Nokia Code of Conduct

Setting the highest standardsNokia has always recognized that its own long-terminterests and those of its various stakeholders depend onstrict adherence to applicable regulation, the Rule of Lawand on following the highest standards of ethics. For Nokia,

ethical business conduct does not mean mere minimumlegal compliance. As an industry leader, we aspire to beamong the best in the world in corporate responsibility,actively promoting human rights and environmental pro-tection through our products and solutions. At Nokia thisis everyones responsibility and an integral part of man-aging Nokias business and brand.

Nokia Group Executive Board has approved and issuedthis Code of Conduct, and it is shared and reinforcedthroughout the company. The Board periodically reviews

this Code and follows its implementation closely.

The Nokia Values are embedded in this Code. Every em-ployee is expected to conduct himself or herself, and hisor her business, in line with this Code without exception.Stricter guidelines or more detailed instructions may beappropriate for certain regions, countries or functions,but they must not contradict this Code.

Better communication leads to better lifeNokia will respect human dignity and promote human

rights. Nokia recognizes, with the international community,that certain human rights should be considered fundamen-tal and universal, based on accepted international conven-tions and practices, such as those of the United NationsUniversal Declaration of Human Rights.

Among those rights that Nokia views as fundamental anduniversal are: freedom from discrimination on any grounds;freedom from arbitrary detention, execution or torture;freedom of peaceful assembly and association; freedom ofthought, conscience and religion; and freedom of opinion

and expression.

Nokias products and technologies contribute positively tohuman rights, to the environment and in the development

of many societal areas. Nokia actively seeks business oppor-tunities for innovative solutions that enhance peoples livesand well-being.

High ethics means success

Nokia is strongly committed to the highest standardsof ethical conduct and full compliance with all applicablenational and international laws. This includes, for example,labor conditions, antitrust and promoting fair competition,prevention of bribery and corruption, good corporategovernance, the protection and recognition of copyright,company assets and other forms of intellectual property.

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Nokia

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Nokia places the safety in the intended use of its productsand services and consumer rights at the forefront, andconducts its marketing in a responsible way.

Nokia respects the privacy and integrity of users of itsproducts and services, and other stakeholders. We endeav-or to adhere to strict standards when processing personaldata and customers product and service information. Wecollect personal data relating to our products and services

in an open and transparent fashion and provide fair andreasonable choices on its collection and use. All personaldata collected and held by Nokia will be processed fairly,lawfully and carefully and in a way that protects theprivacy and rights of individuals.

Environmentally aware in all we doNokias environmental targets go beyond merelegal compliance. We achieve these targets throughan environmental strategy based on global standards,processes and practices, relating both to our products

and services and also to our management of facilitiesand production sites.

Nokias environmental activities are based on life cyclethinking. The goal is to reduce the environmental impactof our products, services and operations throughout thewhole product life cycle. Environmental considerations areincorporated into our product development, processesand service design, our own operations and managing oursupplier network. This includes minimizing use of energyand supporting sound take-back and recycling of materialsand used products.Nokia does not use endangered species for any business

purpose, and furthermore insists that its suppliers avoid rawmaterial procurement from an origin where there is animalrights abuse or a potential negative impact on the environ-ment which is not being addressed properly.

Our people build the futureNokia employees must respect and encourage Nokia Valuesat work, promoting teamwork, individual responsibility, andthe strength that comes from diversity. Nokia will strive topay fair compensation and provide a safe and healthy work-

Nokia 3110 Evolve

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place for employees. Nokia is committed to equality ofopportunity in all its employment practices, policies andprocedures. Job requirements fullled, no employee orpotential employee will receive less favorable treatmentdue to any reason whatsoever.

Nokia will not use child or forced labor. Nokia will not tole-rate treatment or working conditions that are in conictwith international conventions and practices.Nokia will continue to invest in the personal and professio-

nal learning and growth of Nokia employees. Nokia will en-courage its employees to lead balanced personal and pro-fessional lives.

No tolerance on corruptionNokia employees must avoid any activity that can leadto a conict of interest. This includes, but is not limited toacceptance and giving of personal gifts or hospitality to orfrom Nokia stakeholders, other than gifts of nominal valueof less than EUR 100 or reasonable hospitality given in theordinary course of business. Local and national laws takeprecedent if stricter.

Nokia and its employees will not pay nor offer to pay bribesor illicit payments to government ofcials or candidates, or

other parties, in order to obtain or retain business. Nokiadoes not provide nancial support to political parties orother political groups.Nokia employees must not prot, nor assist others to pro-t, from opportunities that are discovered through the useof corporate information or position. Nokia employees mustnot use corporate assets for other than legitimate businessor other authorized purposes. Nokia employees must alsonot engage in any activity which competes with the busi-ness of the company.

We and our partnersNokia requires its business partners, subcontractors, orsuppliers to comply with applicable laws and regulations.Nokia encourages its partners, subcontractors, or suppliersto strive beyond legal compliance in areas such as govern-ance, human rights and the environment. Nokia incorpo-rates ethical, social and environmental criteria in its procure-ment agreements and commits to monitoring the perform-ance of its partners and to taking immediate and thoroughremedial steps in cases where the ethical performance of

its business partners comes into question.

ImplementationNokias compliance commitment in this Code extends toall matters, including decisions relating to trade, investment,subcontracting, supplying, business development, and inall other business and employment relationships. Nokiasapproach to implementing this Code of Conduct is active,open and ethically sound. Although difcult questions ofinterpretation may arise, Nokia will do its utmost to resolveany identied ethical, legal, environmental, employment,

and human rights issues consistent with this Code ofConduct.

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It is the responsibility of each Nokia employee to pro-mote this Code of Conduct. The Nokia Ethics Ofce existsto support employees in all questions relating to this Code.Nokia employees are always encouraged, when possibleand feasible, to raise questions and report issues relatingto the Code of Conduct with their superiors. It is the re-sponsibility of all Nokia superiors to support their teamsin matters relating to the Code.

It is the responsibility of each Nokia employee to reporton violations of this Code:

Nokia employees may report violations of the Codeto their superior. It is the responsibility of all Nokiasuperiors to give advice on the proper procedurein case of violations.

Any issue involving a potential violation of theNo tolerance of corruption section in the Code, orany applicable legal rules or regulations, should bereported to the employees Legal or Business Controller,with a copy being sent to the Assistant General Counsel.

The Assistant General Counsel can also be contacteddirectly.

Furthermore, the employee may report an issuedirectly, condentially and anonymously to the NokiaBoard of Directors, its non-executive members or sub-committees through an electronic channel and a physi-cal mailing address, both available on the companyswebsite. In particular, issues related to Nokiasaccounting, internal controls, or auditing matters areto be addressed to the Audit Committee/Nokia Board

of Directors.

Regardless of the reporting channel, all allegations ofpotential violations of this Code made in good faith willreceive a fair and comprehensive investigation conductedwith the relevant internal and/or external assistance.

Acts inconsistent with this Code must be promptly correctedand are subject to disciplinary action, up to and includingtermination of employment. Nokia will ensure that therewill be no adverse work-related consequences for any

employee making complaints of violations of this Code.

When in doubtIf you are faced with difcult decisions, or are simplyconcerned about an issue, consult your superior or theirsuperior.

If more appropriate, you may bring the matters to theattention of the Ethics Ofce, your HR, Legal or Securitysupport.

You may also report your concerns through the electronicchannel established by Nokias Board of Directors:

www.nokia.com CompanyInformation CorporateGovernance ContactUs

ContacttheBoardChannel

The following mailing address is also available:

NokiaBoardofDirectors/Complaint NokiaCorporation P.O.Box226 FIN-00045NokiaGroup,FINLAND

For more information on Nokias Corporate Responsibility, please visit

www.nokia.com/corporate.

Documents

CODE_NOK_2011_en (1)