We do business the right way
Our Third-Party Code of Conduct, which is applicable to
our suppliers and partners, clearly states our expectations
regarding ethical conduct. We ask our third parties to adhere to
Nokia’s Third-Party Code of Conduct. Third-party commercial
partners, including distributors and indirect resellers, are
required to annually certify compliance with this code, and high
risk third parties are required to complete compliance training.
This code is further supplemented by policies, procedures,
and guidance documents covering a range of topics, including
third-party screening procedures and corporate hospitality.
We also have a separate Code of Ethics that sets out further
expectations for our President and CEO, Chief Financial Officer
and Corporate Controller.
In 2023, we deployed annual mandatory training on ethical
business practices for our employees. Our Ethical Business
Training was completed by 98% of our employees, surpassing
the agreed target of 95%.
We supplement our all-employee mandatory training with
targeted training focusing on particular parts of our operations
and addressing high risk areas, regulatory requirements and
critical and emerging needs. We use a combination of videos,
in-depth training modules, microlearning modules, animations,
and live training sessions to educate employees about high-risk
areas.
In 2023, more than 23 600 attendees received live training
with over 35 compliance topics covered in about 75 sessions.
For select topics, we provide short, animated “just-in-time”
training modules that provide information at the time it is
needed; these are triggered by specific employee actions. For
example, a just-in-time training module on anti-competition
risks is delivered to employees who are attending trade
association meetings, and a module regarding our investigation
process is delivered to employees and external individuals
who raise concerns.
Anti-corruption and bribery
We employ a multi-faceted approach to prevent corruption,
and we have clear and unambiguous policies concerning
improper payments, facilitation payments, gifts and hospitality,
sponsorships and donations and other areas of corruption risk.
Our policies and expectations regarding our strict prohibition
on improper payments and corrupt behavior apply to our
employees, partners and suppliers.
We implement training and regularly communicate with
our employees regarding legal and compliance risks, and
we review these risks and our mitigation measures with the
Company’s senior leadership and Audit Committee of the
Board of Directors.
In 2023, we created a new online anti-corruption training
module and included several topics related to anti-corruption
in our annual “Ethical Business Training,” including: bribery
workplace scenarios, policy information and special
requirements when working with government officials.
We conduct periodic audits and risk assessments to ensure
that we identify and respond to corruption risks across our
operations. Our compliance operations reviews provide an
in-depth assessment of a business or region’s compliance
programs and status, including a review of the strength of
the culture of integrity. In addition, our compliance control
framework assessments provide a deep analysis of compliance
risks and controls associated with a specific business, country,
or region.
These site or business reviews focus on identifying anti-
corruption risks (as well as other risks) and developing,
implementing, and monitoring responsive mitigation controls.
We also carry out risk-based due diligence and monitoring
procedures for all third parties to assess and manage potential
risks related to engaging and working with them. In 2023,
we completed four compliance operation reviews and
13 compliance control framework assessments.
Nokia’s Anti-Corruption Center of Excellence is a dedicated
group within our compliance team that assesses, monitors,
and approves or rejects engagement with high-risk third
parties (including, but not limited to, commercial third parties
and high-risk suppliers), as well as practices such as gifts,
entertainment, hospitality, sponsorships, and donations.
All third parties and suppliers that conduct business with
Nokia are subject to a risk-based screening process.
The activities of the Anti-Corruption Center of Excellence are
digitalized and tool-based, including, for example, monitoring
and training of third parties.
Third parties must adhere to our Third-Party Code of Conduct,
and they are required to sign our anti-corruption certification
annually. In 2023, over 260 of our commercial third parties
certified that they reviewed our Third-Party Code of Conduct
and completed the training video. In addition, as necessary,
live discussions on effective compliance programs are held
with our commercial partners with the goal of exchanging
best practices.
Oversight and grievance mechanisms
Our Board of Directors, its Audit Committee and our Group
Leadership Team all provide oversight of our ethics and
compliance program. Our Chief Compliance Officer provides
periodic reports and updates on our compliance program
(including information relating to investigations, due diligence,
transaction metrics, and evolving external enforcement and risk
trends) to the Board, the Audit Committee, and others, as needed.
Using one of the several resources available to them
employees are expected and encouraged to report concerns
about suspected misconduct or potential violations of the law,
our Code of Conduct, or our company policies. We provide
numerous channels and mechanisms to facilitate such
reporting, including anonymous reporting (unless prohibited
by local law), and we strive to ensure that employees feel
comfortable reporting concerns. Our global Ombuds Program
helps drive our ‘speak-up’ culture and allays concerns
employees may have about potential reprisal for filing a report.
In 2023, the Business Integrity Group, our investigation team
in the Ethics and Compliance organization, received a total
of 1 056 concerns, of which 483 were integrity concerns
investigated by the Business Integrity Group as suspected
violations of our Code of Conduct. The Business Integrity
Group closed 370 investigations into alleged violations of our
Code of Conduct, of which 159 were substantiated with cause
found after investigation. Following investigations conducted
by the Business Integrity Group, we implemented corrective
actions including dismissals, suspension without pay, written
warnings, coaching/counseling, training, and restitution.
Beyond individual discipline, detailed root cause analysis was
conducted for substantiated cases, and unsubstantiated cases,
as appropriate, to identify, implement, and to monitor remedial
measured and improvements.
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Sustainability and corporate responsibility continued
Nokia in 2023
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