Environmental, Health and Safety Policy

1 Scope

In this document, HMD/our/we refer to HMD global Oy (“HMD”) and all its affiliates. The Environmental, Health & Safety Policy which builds on HMD’s Code of Conduct, is global and covers all Company legal entities and applies to all employees 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 the Environmental, Health and Safety Policy.

Moreover, HMD also expects our suppliers, partners, and other representatives to adhere to the same high standards of ethical behaviour and legal compliance when they are working on our behalf.

HMD stands committed to environmental protection.

We manage our activities and our supply chain closely to ensure we meet the relevant legislation and international standards. We are committed to preventing and reducing the impacts of our business through open and ethical management practices. In those countries where environmental legislation is limited, not evident or lacking enforcement, we ensure responsible practices meet our own standards.

We monitor the use of our resources closely and with effective operational and technical management look to reduce waste creation and limit our emissions to land, sea and air. We take the environment into account throughout the organisation. Our design for the environment process ensures that our products comply with the latest standards in environmental performance. We monitor and improve our product development, production, transport, use and end of life planning (reduce, reuse, recycle and reclaim).

HMD are committed to meeting the United Nations’ Sustainable Development Goals. In building this policy we have referred where possible to these goals and our ability to have a positive impact on achieving them.

HMD has in place a robust Environmental Management System (EMS) to define and assess the environmental aspects that are of importance to HMD and our stakeholders. We then look to reduce our related impacts targeting those areas in which we can have the most impact. We ensure at all times these measures comply with legal and legislative requirements and where we can we look to go beyond these. We are looking to review our environmental management strategy with the aid of ISO 14001. A detailed breakdown of our policy can be found in our Environmental Policy. As Part of this EMS we will include environmental risk audits, improvement targets and programs, necessary employee training and communication, internal audits and management reviews.

We are committed to ensure our suppliers are sharing our values regarding environmental protection. Our suppliers are required to have an EMS in place that is capable of planning, operating and controlling environmental aspects. The EMS shall align with the requirements of ISO14001 or other internationally recognised standards. Our suppliers shall ensure that they constantly review the environmental legislation, applicable regulations and customer requirements and can supply evidence of their compliance as requested. In our Supplier Code of Conduct we set our requirements to ensure that our relevant manufacturing partners are certified as compliant with ISO14001 or the Eco-Management and Audit Scheme (EMAS).

In order to make the accelerated move towards sustainable business processes we need to periodically review what we can achieve. This is the basis for our approach to our environmental performance. We aim to identify areas in which we can improve, and work towards improving them continuously.

We look to implement programs based on this approach to tackle a whole range of environmental and social issues. These shall include; energy usage, water access, usage and conservation, waste and defect creation, reducing the materials per product which in turn reduces the effects on mining and biodiversity, reducing the use of hazardous materials and chemicals, improving the processes in place that manage risks and ensuring the cleanest possible treatment and control of waste generation. With this process in place we can strive toward reducing our emissions to land, water and air.

We require our suppliers to follow our own stance on improving environmental performance. They shall follow the same process of identifying areas for improvement through measuring their impacts and finding those areas that can offer the greatest improvements. We can’t expect them to reduce their impacts entirely in the first time of trying; so, we expect that they constantly strive for greater improvement. Resource usage and waste creation of all kinds need to be reduced wherever possible either at source or through modifying processes or substituting materials. We always expect our suppliers to look towards the “EU Waste Hierarchy” model and where possible they should aim to Reduce, Reuse, Recycle and Reclaim in that order of priority whenever and wherever possible.

At HMD, we are committed to reducing our carbon footprint and we aim to measure, record and report on our energy consumption and GHG emissions. We are looking to begin an ongoing process of collecting and reporting on our direct emissions (scope 1) and indirect emissions related to our energy purchases (scope 2). In addition, we are looking to include aspects of upstream and downstream value chain emissions (scope 3).

We look to monitor the data we assemble to highlight areas for improvement so that we can look to minimise GHG emissions within our control. In addition, we expect our partners and suppliers to follow similar measures in minimising their impacts and GHG emissions.

As part of our EMS we require our suppliers to implement a comprehensive system that characterises, monitors, controls and treats waste and wastewater created by their operations and products. We also expect our suppliers to be working towards reducing this waste creation and increasing the volume of recycled waste. This process must adhere to legal requirements and environmental best practice approaches before any discharge or disposal.

We require our suppliers to comply fully with wastewater and solid waste management obligations. They must always maintain a systematic approach to wastewater and solid waste management. This includes having all the required permits and approvals in place (for instance, to store hazardous waste).

We are aware of the associated dangers and risks posed by our products, and we are fully committed to do all we can, to reduce and if possible eliminate these dangers/risks.

7.1 Design for Environment

We look to design products that require less materials or introduce the use of new materials that can reduce our impact. Our design for the environment process ensures that our products comply at least with the latest standards in environmental performance. This not only includes the types of materials used, or how much are used, but also how long these products can last for. Our customers want us to create value for money and this is an area in which we can create that in unison with our commitment to the environment.

7.2 Substance List

We use a Substance List to restrict or ban chemicals and materials that are non-environmentally friendly or hazardous. This list adheres to our principles as well as those of our customers and all applicable laws. We require our suppliers to follow this list always and work closely with us and their suppliers to reduce or ban these materials and chemicals as stated in our Substance List.

7.3 Hazardous Substances

Chemicals and other materials that pose the risk of hazards to the environment require special care and attention. At all times their use should be restricted as much as possible and they should be clearly identified and managed. Their use, handling, storage, movement, recycling, reuse or disposal should be done in a controlled way that poses the least risk to the environment.

The environmental impacts of our products don’t end when the products enter the hands of our customers. We aim to aid our customers with the information for them to make environmentally friendly choices with regards to how they use our products. This means giving them clear instructions on how to operate our products, advising them on using our chargers safely and responsibly. It means giving them a means to recycle our products and we must do all we can to support this function.

We constantly look to improve the recyclable content in our products and packaging to minimise the waste generation. We also work closely with our suppliers to ensure they are doing all they can to help us in this goal by in turn sourcing responsibly and using wherever possible practices that can improve not only the length of the use phase of our products, but also our ability to reclaim as much material as possible in end of life.

Providing a safe and healthy working environment for our employees is an essential element of our business. We look to facilitate a positive working environment that is conducive of a productive and meaningful work. We are in the process of building our policy around the recognised management system OHSAS 18001 and ILO guidelines. Wherever we operate we look to ensure we meet both international standards, local laws and customer requirements. The safety of our products is another priority for us. We work with our suppliers and customers to promote responsible use throughout our products’ life cycle.

At HMD, we see Health & Safety as an integrated part of our business. This is an important distinction as it is not simply a list of rules we set to follow but a mindset that is present in all aspects of our operations. In addition, the health and safety of our employees is the responsibility of both management and individual employees. It is therefore crucial that our employees are well trained to deal with any issues that may arise. We expect all our employees to look out for one another and operate in a safe and caring way that ensures the safety and wellbeing of everyone.

9.1 Health & Safety Management System

We are reviewing our management system to be based on the OHSAS 18001 standard. We believe it is essential for us to have in place a comprehensive risk management system that can identify and mitigate risks. As part of this system we will have a standard procedure in place to access and control the risks of accidents and injuries as well as occupational diseases in a proactive and preventative manner. We create a health and safety plan that covers the appropriate measures and appoint a senior manager representative who will be responsible for ensuring a healthy and safe working environment for all our employees.

9.2 Accident and Emergencies

As part of our health and safety management system we will have preventative measures in place to safeguard against accidents and emergencies that could occur. It is essential that we have standard processes in place to ensure we do all we can to minimise the harm and rectify the problems as quickly as possible. This includes follow up activities such as investigations and implementing improvements based on learning points from the accident/emergency.

We have emergency procedures in place in all our buildings. We have emergency plans, evacuation procedures, employee training and drills, appropriate fire detection, sufficient extinguishers, adequate exit facilities and recovery plans in place in case any emergency should arise.

9.3 Training

As part of our health and safety management system we will ensure that all our employees are aware what is expected of them and they are well trained to take on the responsibility that their position requires. This is true for every person on every level of our organisation; from those responsible for writing the procedures and giving the training to those responsible for the day to day actions to ensure our high safety standards are met.

9.4 Occupational Injury and Illness

As part of our health and safety management system we will invest in equipment and facilities that offer our employees preventative measures such as well-designed chairs and work stations. In addition, we use root cause analysis of our procedures and systems to mitigate and manage injuries and illnesses sustained by our employees. We encourage our employees to inform us as soon as they become aware of discomfort or injury due to their work so that we can classify and record any injury or illness and provide the treatment or equipment to aid with their recovery and prevent future problems.

9.5 Hazard Analysis and Critical Control Points

As part of our health and safety management system we will have processes in place to identify hazards and when such hazards are found we monitor, aim to control and minimise their risks.

We expect our manufacturing partners to have adequate management systems in place to cover aspects where employees are operating with dangerous or hazardous substances or with equipment, production machines or other machinery. In any of these cases they shall ensure that workers are provided with the correct protective equipment and the equipment/machinery should be fitted with properly maintained guards, interlocks and barriers to ensure our employees safety.

9.6 Our Buildings

We provide safe and clean working environments that provide our employees with everything they need to ensure their basic needs are met and we comply with legal safety standards and regulations.

We have detailed environmental, health and safety requirements for all our products. This covers all aspects related to customer health & safety as well as product material and substance content and conformance list, product construction and disassembly, labelling and marking, product related laws and regulations and safety instruction and testing standards.