HMD Global Oy (“HMD”) is the home of Nokia phones. A start up founded in Espoo, Finland, we are a collective of passionate and experienced people including some of the most talented and well-recognised leaders in the mobile industry today. We started our operations in December 2016, when we entered into licencing agreement with Nokia Technologies for global exclusive rights for the Nokia brand in mobile phones and tablets for a period of 10 years.

Our aim is to create amazing mobile technology for everyone. We design and deliver trusted and innovative products under the iconic Nokia brand; products that are created to meet the diverse needs of global consumers, that are useful for everyone and that make life more exciting and inspiring for these consumers and our shared communities.

We do this by bringing together the best of the industry to leverage world-class partnerships with manufacturers, operating systems, brands and suppliers.

Consumers today are seeking relationships with brands that they can trust. The Nokia brand has over 150 years of heritage giving it an authentic, differentiating experience which we are proud to introduce to a new generation of mobile fans. We are proud to be writing the next chapter of the Nokia phones story. Nokia phones are always associated with honesty, empathy and high integrity. As a business, we have high integrity on ethical, legal and statutory topics. We care about each other, our customers, our suppliers and the environment.

Policies in relation to slavery and human trafficking. We regularly review, mitigate and maintain a risk map of identified various human rights related risks including modern slavery risks and have established processes and policies to mitigate the risks and to make sure that incidents are actioned in a timely manner.

In 2020 HMD published Human Rights & Labour Policy and Environmental, Health & Safety Policy in addition to HMD’s Code of Conduct and Supplier Code of Conduct Policies. These requirements are explained to the original design manufacturers as part of the onboarding process and regular audits are performed by us and third-party auditors to ensure compliance to the requirements.

Our 657 direct employees (September 2020) employees are based in over 50 countries worldwide. 17% of our direct employees’ agreements (based in Austria, Belgium, France, Finland and Italy) are currently based on the local collective bargaining agreements.

Risk Management. We work closely with our key stakeholders with regards to Human Rights risks. In 2020 we have conducted a comprehensive human rights risk assessment with EY (Ernst & Young) with focus on Telecommunications Equipment and Electronic Sectors specific human rights risks and the human rights risks in countries where we have original design manufacturing partners and sales field force activities. Study included assessment for human rights risks specific to forced labour and modern slavery, child labour, working conditions and wages and discrimination. This risk assessment connects into our regular risk management processes.

Training. In 2020 Code of Conduct live online training was organized for all employees and temporary workforce in close co-operation with our key partner Nokia. During the training employees were able to ask questions and clarify any unclear aspects for example concerning their own role. Training recording is available for all new joiners. Training included various key ethics & compliance aspects including human rights, fair employment and health, safety and labour conditions.

Audits. In 2020, we continued auditing work with our ODM partners. We re-emphasized our CSR requirements towards our ODM partners, which are also explained during all new ODM onboarding process. We used a third-party party auditor company Intertek to assess all (100%) our China and Vietnam based manufacturing partners for CSR using JAC and SA8000 requirements during summer of 2020. We worked closely with our suppliers on root cause analysis, found issues and corrective and preventive actions for those. All ODMs are rated based on their audit performance, and improvements are tracked continuously. As an example, the audit assessment requirements include freedom of association, discrimination, wages and compensation, working hours, disciplinary practises, business ethics, environment, child labour & juvenile workers, forced labour and health and safety. If any violations against the requirements are found, we work with the supplier to remediate the issues immediately the compensate the impacted people.

Sanction Screening. As part of our regular control activities, we conduct risk-based sanction screening to new vendors and customers, and ongoing sanctions screening for all already onboarded third parties. The sanctions screening includes several sanction lists in relation to forced labour and human rights abuse, such as UK Global Human Rights Sanctions (BOE), US Customs and Border Protection Forced Labor (CBPFL), US Department of Commerce Entity List (ERL), US Department of Treasury Specially Designated Nations Lists (SDN) and Brazil Dirty List Eradication of Slave Labor.

Speak Up Channel. Speak Up channel was established in 2018 and it is open for anyone (internal and external) to report concerns. The channel is available in English currently which is the company’s official language, and we are looking into expanding the language options for reporting a concern in Chinese, Spanish and at least Russian. In addition to the Speak Up channel that allows also anonymous reporting, concerns may also be freely escalated directly to Compliance, Legal, HR or any member of the HMD Management.

Each reported concern is timely and carefully reviewed by Compliance & Legal in order to define if formal investigation is required. Investigations are carried out according to HMD’s Investigation Policy.

Statistics of all reported concerns, investigations and their outcome are reported to the HMD Global Compliance Committee, consisting of Executive Leadership Team Members and Chaired by the HMD Global CEO. In 1H 2020, we have received three reported concerns regarding discrimination or harassment. All of these reported concerns have been addressed.

To date, there have been no retaliation claims made against HMD by the reporters of ethical concerns.

We expect our suppliers to maintain programs that ensure their employees and suppliers have access to confidential and anonymous reporting channels, as well as protection in place for acts of whistleblowing. Our supplier shall have in place a clear, visible and communicated process for anyone working at their facility to be able to raise concerns without fear of retaliation.

* Full statement of year 2020 activities will be published after the end of financial year 2020.

During our third operating year, we continued working with activities for preventing modern slavery and ensuring compliance with our HMD Code of Conduct and associated HMD Corporate Social Responsibility policies in our business and supply chains. Our main activities included the following:

Policies in relation to slavery and human trafficking. In addition to our current strict policies relating to environmental, social and human right matters, which are explained in more detail below, we are preparing new policies to improve gender equality and promote diversity and inclusivity. We also regularly review and maintain a risk map for identifying modern slavery risks and have established processes and policies to mitigate the risks and to make sure that incidents are actioned in a timely manner.

Training. We continuously provide Code of Conduct related trainings to employees and monitor that all employees attend such trainings. In addition to providing trainings, we offer different advice channels and fully support acts of whistleblowing as an essential action in the last line of assuring our compliance as an ethical and legally conforming business. We promote ethical and compliant culture.

Audits. In 2019 we made the strategic decision to focus on key geographies and introduced a multi-ODM model. We regularly assess and audit our Original Design Manufacturing suppliers including CSR topics. We are working with our partners and suppliers to prevent and uncover any modern slavery abuses that may occur.

KPIs. In order to meet the standards set out in our policies, our Leadership Team has defined the objectives and KPIs to ensure that our way forward is clear for CSR matters and that the progress can be measured.

In addition to the above actions, we continue to work towards achieving the highest EcoVadis Gold level by the end of 2020.

During our second operating year, we continued working with activities for preventing modern slavery and ensuring compliance with our HMD Code of Conduct and associated HMD Corporate Social Responsibility policies in our business and supply chains. Our main activities included the following:

Policies in relation to slavery and human trafficking. We have a series of rigorous policies and procedures in place to ensure that environmental, social and human rights matters are considered with the utmost importance, such as HMD Code of Conduct, HMD Supplier Code of Conduct, Business Ethics Policy, Human Rights and Labour Policy and Environmental Health and Safety Policy.

Training. HMD provided several Code of Conduct related trainings to employees, including trainings on data privacy for both internal staff and our suppliers, anti-bribery and corruption, anti-harassment and discrimination, controllership and information security and speaking up about any ethical concerns.

Audits. In 2018, we audited both our Original Design Manufacturing suppliers and our own operations to ensure the compliance of our agreed Corporate Social Responsibility policies, including manufacturing process audits, ISO audits and audits within the scope of the global Joint Audit Cooperation (JAC).

Speak Up channel. In April 2018, we implemented the whistleblowing channel called Speak Up for raising ethical concerns. The channel allows also anonymous reporting where legislation permits anonymous reports. All employees were provided training on the process of raising concerns and the company investigation process, and line managers were provided with training on how to support employees to raise concerns. In November 2018 the Speak Up channel link was published on HMD Global web pages to also allow HMD suppliers and partners to report ethical concerns.

KPIs. In April 2018, HMD received the ISO9001 certification. The certification was the result of a successful completion of an external audit that ensured that all of our internal and external processes meet the required quality management system standards. We are also working on achieving the ISO14001 certification for our environmental management system and our target is to get certified in year 2020.

In 2018, we also reached EcoVadis Silver level and we are thus ranking in the top 30% of EcoVadis medal-holders. The EcoVadis Corporate Social Responsibility assessment is an evaluation of how well a company has integrated the principles of CSR into their business and management system. You can learn more from here. We continue to build on our CSR policies and the actions we take to enforce such policies by striving further to achieve the EcoVadis Gold level.

In addition, we executed the European and USA Take Back programs, in order to avoid waste and to ensure that the products we manufacture receive an environmentally friendly treatment. We also launched new web pages to ensure up-to date communication on environmental matters and our actions to reduce the environmental impact of our products. Visit the webpages here.

HMD started its operations in December 2016. With regards to ensuring that slavery and human trafficking is not taking place in any of our supply chains, and in any part of our own business, we have taken the following actions during our first operating year: We have launched our Code of Conduct Policy and provided several mandatory employee trainings on both Nokia Code of Conduct for Nokia’s partners and our own HMD Code of Conduct and associated HMD Corporate Social Responsibility policies, such as: - Business Ethics Policy - Human rights and Labour Policy - Supplier Code of Conduct Policy - Conflict Mineral Policy - Environmental, Health and Safety Policy

We communicate our Supplier Code of Conduct Policy to the suppliers we choose to work with, and in formal agreements we enforce requirement to follow all applicable laws and regulations. Internally, we have established Regional Compliance Committees who oversee the compliance activities in the regions where we operate. Furthermore, we have established Global Compliance Committee who oversees the compliance activities globally.

Our Code of Conduct principles ensuring that slavery and human trafficking is not taking place are as follows:

Human rights. We want to be a company that empowers people; a company that brings enjoyment and solutions to their everyday lives. We stand firmly by The Universal Declaration of Human Rights (UDHR) and their work in protecting people’s rights. We do not tolerate, facilitate or contribute to any activity that could contribute to conflict or an abuse of human rights. Extra vigilance is essential in areas of the world where the laws or enforcement of them is weak to ensure we are still acting in line with our commitment to international standards such as the UDHR. Therefore, it is essential for us to strive for a transparent supply chain in which materials, goods and services are sourced responsibly and anyone associated with this activity is respected.

Modern slavery. We are in full support of the UK Modern Slavery Act and we agree to publish a statement of our action plans, progress and challenges annually. Modern Slavery is an umbrella term that includes; slavery, human trafficking, forced or compulsory labour and servitude. Modern slavery as a term refers to a situation where a person is coerced, deceived, taken unwillingly and/or indebted into a position where they feel trapped, held, compelled or forced to work. These actions are against our principles, illegal and immoral. The greatest challenge facing organisations, in all industries and in all areas of the world, is that these activities are often hidden or hard to spot. We are committed to report on our findings and we endeavour to tackle this issue transparently.

We believe that people should always be free to choose when, where and who they work for. We do not accept anyone who traps, compels or forces another person to work; on our behalf, or in our supply chain. This also applies to anyone who is aware of such behaviour and who does nothing to stop it. Please report any such abuse or suspicion of possible abuse through ethics@hmdglobal.com.

Working with Partners. How we cooperate with our partners (suppliers, distributors, consultants etc.) has a direct impact on how our organisation is viewed. We expect professionalism and honesty from ourselves and our partners. We look to build productive relationships with our suppliers and we must aid them in achieving the high standards that we set ourselves. We expect a third party operating on our behalf to respect ethics and legal practices. We prohibit the creation of side agreements and ensure our contract documents reflect the totality of our agreements and they include all terms and concessions as agreed to by both us and our counterparties.

Labour Practises. We are a culturally rich organisation that operates on a solid foundation of mutual respect in which employment, is always a choice. In building our approach to labour practices, we have followed the guidance of the International Labour Organisation (ILO) an internationally recognised body that “promote rights at work, encourage decent employment opportunities, enhance social protection and strengthen dialogue on work-related issues”. For industry specific guidance, we refer to the Electronic Industry Citizenship Coalition (EICC). We are committed to adhere to employment and labour laws and regulations wherever we operate. These include minimum wage requirements, maximum working hours regulation, minimum rest day requirements, privacy, banning child labour, young worker protection, banning compulsory labour, regulation related to immigration, collective bargaining, freedom of association, anti-discrimination as well as further employment rules and regulations.

Our Human Rights and Labour Policy contains — in greater detail — our approach, guidelines, procedures and standards that aid HMD's employment decision making.

Forced labour and recruitment fees. Employment is a choice and should create value for the employee as well as the employer. Our stance of being an employer of choice means that forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery or human trafficking is forbidden not only in our premises but in those of our suppliers. Our employees conduct their work voluntarily and they are free to leave or terminate their employment. Our workers are never required to surrender any government-issued identification, passports or work permits as a condition of employment nor should any employee be required to pay recruitment fees or related fees either to HMD or to an agent working on our behalf. As part of our hiring process, employees are provided with written employment agreements where applicable containing a clear description of the terms and conditions of their employment.

Child labour avoidance and protection of Young Workers. We provide a supportive environment in which young professionals can learn and develop their skills. No one under the working age, per local regulations, is employed by HMD and we pass this requirement on to our suppliers and other partners. Where local regulations are not in place, we follow the EICC guidance regarding the minimum working age. We believe that helping young workers develop their skills and gain valuable experience is important and such programs should always comply with laws and regulations. Young workers should be protected from dangerous work tasks and must not work night time hours. Wherever we operate we comply with local laws and regulations.

Working hours and wages. We believe that productivity is best created with healthy and meaningful work that is fairly paid. Our employees are compensated for their work in conjunction with all applicable wage laws, including those related to minimum wages, overtime hours and legally mandated benefits. We operate within the ILO guidelines on working hours where laws and regulations are insufficient. We expect our contractors and suppliers to respect and follow local laws and regulations. Where local laws and/or enforcement is weaker than the EICC’s Code of Conduct, we expect our contractors and suppliers to follow the standards set by the EICC.

Freedom of Association and Right to Collective Bargaining. We support our employees right to bargain collectively and ensure their rights are being met. Our employees are free to associate with labour unions as they see fit. They are also free to use collective bargaining as a means for protecting their rights as our employees and we respect their rights to peaceful assembly or protest. Everyone at HMD should feel able to communicate honestly with management regarding their work and working conditions without fear of discrimination, harassment, intimidation, penalty or reprisal. Our suppliers shall follow this same stance and allow their workers to freely associate and give them the right to collective bargaining.