Policy Approved by the HMD CEO and Board of Directors

1. Scope

In this document, HMD/our/we/Company refer to HMD global Oy (“HMD”) and all its affiliates. The Anti-bribery and corruption Policy is global and covers all HMD legal entities and applies to all employees, directors and external persons working on HMD’s behalf. It is the employee’s responsibility to be aware of the content and any subsequent changes and be fully compliant with this policy. You should use apply this policy together with HMD Code of Conduct and Business Ethics policies.

Corruption is prohibited by law in every country in which HMD operates. Corruption is the single greatest obstacle to economic and social development around the world. It distorts markets and stifles economic growth. It debases democracy and undermines the rule of law.

HMD has zero tolerance for bribery and corrupt activities.

The purpose of this policy is to raise employees’ awareness of the risk of corrupt payments, to prohibit their payment as bribes as stated in HMD’s Code of Conduct, and to ensure that we conduct our business with integrity, the highest ethical standards, and in compliance with anti-corruption laws, rules and regulations.

All forms of corruption, including but not limited to extortion, cronyism, bribery, facilitation payments, nepotism, fraud and money laundering, are strictly forbidden.

2. No Bribery

HMD has zero tolerance for bribery and corrupt activities.

HMD employees and representatives may not give, promise, offer, or authorize payment of anything of value to any to obtain or keep business or to secure some other improper advantage.

HMD employees and representatives may not request, accept or agree to accept anything of value from anyone in return for providing an improper advantage. An improper (or undue) advantage refers to a benefit of some kind that a company or individual is not legally entitled to and that it has obtained through illegal means.

3. Facilitation Payments

HMD does not allow facilitation payments.

A facilitation payment (also known as “grease” payment) is typically a small payment to a government official to ensure or speed up a routine government action (such as processing papers, issuing permits, or similar official actions). HMD employees, directors and representatives may not make facilitation payments.

If you find yourself in a situation where failure to make a facilitation payment would put your or your family’s safety at risk, you may make such payments to avoid immediate harm. In such circumstances, you must, as soon as reasonably practical:

Report the incident to your line manager and to [email protected]

Ensure that an accurate record of the payment is made including:

• In what context the payment happened
• Rationale for the payment
• Who made the payment
• Recipient of the payment
• Amount and currency paid
• Name of the person(s) witnessing the payment

4. Gifts, Travel and Hospitality

In certain circumstances, the giving of gifts, the payment of travel expenses, and the providing of entertainment and other hospitality, can be considered a bribe if it is done in return for receiving an improper advantage.

To avoid even an appearance of improper behavior, follow the HMD’s Code of Conduct policy, Business Ethics policy and Travel & Expense policy guidance on providing gifts, travel and hospitality to anyone outside HMD, before giving anything of value to anyone outside HMD.

Bear in mind that our partners and suppliers may also have company specific guidelines for gifts, travel and hospitality that we need to respect. If in doubt, ask clarification on such guidelines from your counterparty and consult legal team to ensure you are aware of any contractual terms regarding the supplier or partner, which may include terms regarding acceptable gift, travel and entertainment practices.

Remember the country specific rules: in some countries minor hospitality can be considered as bribe for example when given that to government officials. If you are uncertain of the acceptable level ask before you act. You can contact [email protected] or your Regional Legal Counsel to receive further guidance.

All travel, entertainment or gift to government officials may be given only post Legal Counsel (LICCA - Legal, IP, Compliance and Corporate Affairs) approval which is capped to a certain limit per country. All such travel must be business related and contain business agenda. HMD does not pay any travel to government officials beyond the formal business agenda. Furthermore, all gifts of devices must be given for the entity’s use and shouldn’t benefit government officials. Approvals can be requested via [email protected].

Employees and directors are required to report all interactions (i.e. meetings, events and entertainment) with government officials to Legal Counsels in advance to [email protected], including those that are organized by any third party.

5. Hiring Decisions

Hiring of individuals can be considered a bribe when it creates a benefit for an individual in return for an improper advantage. All potential hires should go through HMD’s normal employee hiring process, and no employment candidate should receive preferential treatment or consideration based on the request of a third-party or internally who is able to provide a benefit to HMD or to colleague. For further information refer to HMD Recruitment and Onboarding Policy.

HMD does not allow nepotism or cronyism in recruitment decisions. Nepotism is a form of favoritism shown to family members without regard to merit. Cronyism is a form of favoritism shown to close friends without regard to the person’s qualifications.

6. Donations and sponsorships

Charitable donations can be considered a bribe when they create a benefit for an individual in return for an improper advantage. If an individual makes a request for a charitable donation that is related to a benefit to HMD (for example, a sale or the granting of a license or permit), the request must be denied and reported to [email protected].

When making charitable contributions, we need to ensure that these do not benefit the government officials or political parties.

For sponsorship spend an agreement detailing terms and conditions is mandatory requirement. All sponsorship agreements must be approved in advance by HMD Global CFO. Business owner is responsible to get the agreement approved by legal team before contract is signed. For further info please refer to HMD Spend Policy.

7. Know Your Third-Party Representatives

Third-parties, acting on HMD’s behalf, can expose HMD to penalties and negatively effect our brand and image if they act or appear to be acting in an unethical manner or in a manner otherwise inconsistent with this policy.

All third-parties acting on HMD’s behalf must adhere to HMD’s Supplier Code of Conduct and business owner engaging with the third-party is responsible for communicating these requirements to them.

HMD employees must follow all applicable third-party due diligence processes, which are designed to ensure that that the party does business in an ethical manner, before doing business with a third-party.

8. Keep Accurate Books and Records

All payments, gifts and other compensation must be accurately recorded in a timely manner and in reasonable detail in the corporate records. No undisclosed or unrecorded accounts may be established for any purpose. False, misleading, incomplete, inaccurate or artificial records are prohibited.

Remember that creation of side agreements is prohibited and our contract documents must reflect the totality of our agreements and must include all terms and concessions as agreed by both HMD and our counterparties. For further info refer to HMD Code of Conduct policy and HMD Business Ethics policy.

9. No Retaliation

HMD adheres to a strict policy of no retaliation. No HMD employee shall suffer any adverse consequence for raising a concern regarding potential violations of this policy or for refusing to engage in activities in violation of this policy.

10. Enforcement

Employees who violate this policy shall be subject to discipline up to and including termination of employment.

11. Guidance

Ask before you act if you are uncertain. You can ask guidance from your Line Manager, from Legal or from Controls & Compliance.