Anti-Discrimination and Anti-Harassment policy

Policy Approved by the HMD CEO and Board of Directors

HMD is committed to the principles of equal employment opportunity and fair treatment of all individuals, and it complies with all applicable laws which prohibit discrimination and harassment in the workplace. It is the policy of HMD not to discriminate against any individual on any basis and not to tolerate harassment on any such basis.

HMD strictly prohibits discrimination in all terms, conditions, or privileges of employment, including recruiting, hiring, assignment, compensation, benefits, promotions, demotions, transfers, discipline and termination, and any form of harassment, based on race, color, religion, national origin, citizenship, gender (including pregnancy, childbirth and related medical conditions), age, disability, sexual orientation, marital status, military/veteran status, genetic information, voluntary association or non-association with trade union/bargaining agreement or any other characteristic protected by applicable law, or collective bargaining agreements where applicable.

No adverse employment action will be taken against any person for exercising his or her rights under applicable law, for making a good faith complaint, or assisting in an investigation under this policy. Retaliation for any such protected activity is strictly prohibited. HMD expects all employees and directors to support the implementation of this policy and to comply with all applicable laws prohibiting discrimination, harassment, and retaliation in employment.

In this document, HMD/our/we refer to HMD Global Oy (“HMD”) and all its affiliates. The Anti-Discrimination and Anti-Harassment Policy (“this policy”) builds on the HMD’s Code of Conduct, describes further our requirements towards a safe and respectful working environment and prohibits any forms of discrimination and harassment.

This policy applies to conduct in the HMD’s offices, on HMD business, and in any location during work time. It also applies to conduct outside of the HMD, such as during social or business occasions and events, which affects the workplace. This policy applies to all employees and directors, as well as to our suppliers, partners, visitors, vendors, contractors, and other third parties working on our behalf whether at HMD premises or outside.

Harassment on the basis of any protected characteristic is strictly prohibited. Harassment is verbal or physical conduct based on a protected characteristic that creates an intimidating, hostile, or offensive working environment or that interferes with an individual’s work performance. Harassment may include, but is not limited to slurs, disparaging remarks or jokes, written or graphic material that denigrates or shows hostility to an individual because of a protected characteristic or otherwise.

Sexual Harassment: In addition to conduct based on hostility as described above, sexual harassment consists of unwelcome sexual advances, requests for sexual acts or favors, or other physical or verbal conduct or visual displays of a sexual nature when 1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment (e.g. hiring, compensation, advancement, promotion or retention); 2) submission to or rejection or such conduct by an individual is used as a basis for making employment decisions concerning the individual (e.g. treating a staff member favorably for engaging in such conduct or unfavorably for refusing to engage in the conduct); or 3) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive environment.

Sexual harassment may include a range of behaviors and may involve individuals of the same or different gender. These behaviors may include, but are not limited to: unwanted sexual advances; subtle or overt pressure for sexual favors; sexual jokes; innuendos; advances or propositions; verbal abuse of a sexual nature; graphic commentary about an individual’s body, sexual prowess or sexual deficiencies; leering; whistling; touching, pinching, assault, coerced sexual acts; display of sexually suggestive objects or pictures; and other physical or verbal conduct of a sexual nature.

It is also essential to understand that consenting romantic and sexual relationships between coworkers may lead to unforeseen complications e.g. when two individuals involved are in a direct reporting relationship, and/or when one individual has the ability to exercise significant influence over any aspect of the other individual’s performance, compensation, and promotional potential. In other situations, to which these definitions do not apply, all employees are expected to exercise the utmost discretion and decorum when entering into a romantic relationship with another employee. HMD reserves the right to reassign individuals involved in romantic relationships, regardless of reporting structure, if there is concern the relationship will impact the performance, career, or comfort level of any staff member, including the couple, or create the potential for conflict of interest.

HMD will take necessary actions up to and including termination of employment against any employee that has been involved in perpetrating or supporting harassment in accordance with applicable laws. Inducing another person to commit any of the prohibited acts under this policy or actively cooperating in committing such acts also amounts to harassment.

Where the alleged harasser is a third party such as a vendor or customer, HMD will take action to investigate the report with the appropriate party’s management or with law enforcement as applicable.

Nothing in this policy shall prevent the reporter or object of harassment from pursuing formal legal remedies or resolution in accordance with applicable laws.

HMD expects all perceived incidents of discrimination, harassment, or retaliation to be reported immediately, regardless of their severity, and regardless of the alleged offender’s identity or position. Individuals who believe they have witnessed or been the victim of any form of discrimination, harassment, or retaliation should discuss their concerns with their manager, Regional HR Lead or with another member of Human Resources. In addition to approaching persons listed above the employee can also send any concerns regarding any manifestations of harassment to the following email address: ethics@hmdglobal.com In addition, HMD encourages individuals who believe they are being subjected to such conduct to advise the offender(s) promptly that his, her, or their behavior is unwelcome and to request that it be discontinued. This is not, however, a requirement prior to making a complaint, and it is not a substitute for the complaint procedure described above.

All complaints will be investigated promptly and fully. Such an investigation will typically include interviews of the person(s) making the complaint, the person(s) accused of discrimination or harassment, and other person(s) who may have relevant knowledge while protecting the identity of the complainant to the extent possible.

If HMD finds that prohibited conduct has occurred, it will take effective and appropriate remedial action. Such action can include discipline up to and including suspension or termination of any employee found to have violated this policy. In addition, any employee who willfully makes a false allegation or false statement under this policy will be subject to appropriate disciplinary action, which may include suspension or termination of employment.

As noted above, no adverse action will be taken against an employee for exercising his or her rights under applicable law or for making a good faith complaint or assisting in an investigation under this policy, and retaliation is strictly prohibited. No one has authority to take any such action against an employee. Any threats or attempts at retaliation must be reported to your Line Manager or any member of HR immediately so that corrective actions can be taken as prescribed in Section 4.

All complaints of discrimination or harassment and any information received during the course of the investigation and the resolution of the investigation will be kept strictly confidential and made available for review only by those with a legitimate need to know, as determined by HMD in its sole discretion, unless required by law to be divulged. All personnel, including the person making the complaint, who are involved in the investigation are expected to use discretion in maintaining the confidentiality of information and documents generated or discussed during the investigation. This provision is not intended, of course, to restrict an individual’s ability to exercise his or her rights under applicable law.

All employees shall:

• understand what is discrimination and harassment and how it can be prevented at the workplace;

• not engage in behavior which may amount to discrimination or harassment;

• not encourage other employees to engage in conduct which could amount to discrimination or harassment;

• report behavior which could amount to discrimination or harassment in accordance with procedures prescribed by this policy;

• comply with the requirements of this policy and other applicable policies.

It is the responsibility of HMD line managers to ensure that:

• employees understand and are committed to their rights to attend work and perform their duties, without fear of being discriminated or harassed in any form;

• employees understand what constitutes an act of discrimination and harassment;

• all reasonable steps are made to eliminate discrimination and harassment;

• all employees are regularly made aware of their obligations in relation to providing a workplace free from discrimination and harassment;

• take action if they become aware of any discrimination or harassment action.

It is the responsibility of the Human Resources and senior management to ensure that:

• policies and procedures are regularly reviewed and (if necessary) amended;

• guidance is provided to employees regarding harassment and inappropriate behaviour in the workplace;

• managers are aware of their obligations and responsibilities in relation to discrimination and harassment, and the rights and entitlements of their employees.