Our business is built on the foundation of trust. Our Code of Conduct expresses our personal commitment to earn this trust every day, in all of our business activities and in every country where we work. It reflects our values through clear and simple direction for all of our employees and business partners and defines the principles of ethical and compliant business practices.
We also have a Code of Ethics applicable to the President and CEO, Chief Financial Officer and Corporate Controller.
Leadership involvement and oversight on ethics and compliance are provided by the Board of Directors via the Audit Committee. Compliance management is further supported by both global and regional compliance committees.
The Fight Against Corruption. Maintaining a culture of integrity requires the continuing commitment of everyone at Nokia: from our leaders, who must lead by example and demonstrate deep engagement in driving compliance, to our employees, who must know and understand the rules and raise their hand when they have concerns. Likewise, Nokia’s Ethics & Compliance organization (E&C) constantly seeks to improve our already robust compliance program and find new and effective ways to lessen risk. Our Ombuds team helps drive our open reporting culture, our Investigations team responds promptly to reports of potential issues, and our Anti-Corruption Center of Excellence reviews hundreds of transactions, third parties, and requests to give or receive gifts, travel and entertainment, to name just some of the work happening every day. Recently, in an effort to further mitigate the risk associated with engaging third parties, E&C began to proactively engage with our third parties to ensure they share our commitment to integrity and have their own robust compliance programs. This engagement is strengthened further by Nokia’s Commercial Third Party Code of Conduct, which was launched in 2018, and Nokia’s decision to become a signatory to the World Economic Forum’s Partnering Against Corruption Initiative (PACI) and commit to an active role in the global fight against corruption.
In the current enforcement environment, the work of E&C is more important than ever. Indeed, the number of anti-corruption and anti-corruption-related enforcement actions continue to climb globally. Recently, we’ve seen the largest-ever settlement in a case brought under US anti-corruption law, as well as fines meted out for a potpourri of wrongdoing, including improper payments to government officials in order to obtain permits and the use of agents to funnel bribes. In sum, anti-corruption prosecution continues at a vigorous pace, and it shows no signs of slowing.
What can we take away from the many cases we have seen of late? While obvious, it bears repeating that the consequences of corruption are profound. Beyond massive fines, disruptive investigations, and loss of business, careers are destroyed, individuals go to jail, companies may never recover their former reputations, and investors and consumers may be harmed.
Nokia is committed to the hard work necessary to maintain a best-in-class ethics and compliance program because having a reputation for integrity has become a true commercial differentiator. We are proud of our deeply embedded culture of integrity, where our leaders and employees care about ethics, want to “win” with integrity, and embrace the “Speak Up” culture. At Nokia, we make it a priority to maintain our values – even in a competitive and difficult market. Put simply, staying out of trouble takes work, and that work is never done as we strive continuously to improve our ethics and compliance program.
THE TRUST EQUATION. We have all seen first-hand the erosion of trust in institutions that have long served as cornerstones of free and open societies – the media, corporations, and freely-elected governments to name a few. From “fake news” to Brexit to yellow vest protests, it can feel as if the fabric that binds us together is stretched to the breaking point. Pessimism abounds. But the latest results from an annual survey on trust1 reveal something surprising: trust has become “localized,” with the majority of respondents now naming “my employer” as their most trusted institution or relationship, far outpacing NGOs, business and media. But it can’t be one way; employees expect something in return. In exchange for their trust, employees expect their companies to act as agents of change, working to improve the lives of employees and for the overall betterment of society. The payoff for employers who can meet these expectations is significant: employers who have earned the trust of their employees reap the benefits of a workforce that is engaged, loyal, and committed.
As one noted management consultant has observed, “the secret to getting people engaged isn’t about showing them why it’s good for them. It’s the exact opposite. It’s about providing people with a purpose that’s bigger than they are.” 2
At Nokia, we understand the importance of trust, engagement, and a greater purpose. As a trusted employer, we know our success is based not only on providing cutting edge technology but equally on a dedicated, happy, productive workforce that trusts the company to do the right thing for them, for the business, and for the communities in which we work. As employees we appreciate an inclusive, stable work environment where our leadership is committed to not only driving growth in an ethical way but also providing employees with fair pay and benefits, multi-dimensional growth opportunities, and the opportunity to make a difference. Our customers, suppliers, shareholders, and partners likewise want to work and invest with us because of our commitment to these ideals.
In the Legal & Compliance organization, the trust equation is central to what we do. We support our business partners in complex commercial negotiations, dispute resolution, protection of our intellectual property and much more. And as guardians of Nokia’s hard-earned and longstanding reputation as a company that leads with integrity and serves as a model of corporate ethics, we strive to raise the bar on transparency and compliance everywhere we do business. We work diligently to ensure that the actions and behaviors of our partners, affiliates, suppliers and others with whom we do business follow the same principles and values we expect of our employees. We also work hard to improve our communities and the lives of others; Nokia has been recognized for its commitment to pro bono work, ranging from improving the delivery of health care services in rural Africa, to education in remote parts of India, to groundbreaking work supporting employment opportunities for asylum-seekers across southeast Asia.
We don’t shy away from doing business in tough places where transparency is lacking and the rule of law is weak. After all, the need for advanced communication technologies is at least as great in such places as in more developed nations. Instead, recognizing the vital nature of our products and services, we go in with clear eyes, recognizing the challenges and partnering with our business leaders to craft effective and creative solutions to address these risks, never compromising on our values and our commitment to integrity. This is how Nokia’s Legal & Compliance team furthers the trust equation: by partnering to achieve business objectives, enabling the provision of communications and technology solutions to millions, setting an example for ethical business practices globally, and never straying from our values and our unyielding commitment to integrity.
12019 Edelman Trust Barometer, an annual survey carried out by Edelman, a global communications firm.
2Lisa Earle McLeod, author of Leading with Noble Purpose (2016) and other leading works.
Nokia is recognized as one of the 2019 World’s Most Ethical Companies. The World's Most Ethical Companies? designation honors companies who recognize their critical role to influence and drive positive change in the business community and societies around the world and who work to maximize their impact wherever possible.
The World’s Most Ethical Company award is given annually by Ethisphere, a leading organization for corporate ethics and compliance. Following a rigorous and comprehensive evaluation of our compliance program, corporate governance, and culture of integrity, Nokia was one of four companies in the telecommunications sector to receive the 2019 award. This is the second consecutive year we have won this award and the third time overall.
Companies are assessed based upon the Ethisphere Institute’s Ethics Quotient? (EQ) framework, which offers a quantitative way to assess a company’s performance in an objective, consistent and standardized manner. Questions included in the Ethics Quotient are periodically reviewed and updated based on changing regulations, expectations, and best practices.
Scores are generated in five key categories: Ethics and compliance program (35 percent); corporate citizenship and responsibility (20 percent); culture of ethics (20 percent); governance (15 percent); and leadership, innovation and reputation (10 percent).
Research has found that, when indexed, listed World’s Most Ethical Companies outperformed the large cap sector over five years by 14.4 percent and over three years by 10.5 percent. Ethisphere refers to this as the Ethics Premium. Our customers and partners can rely on us and our employees not only for innovation and quality but also for our resolute commitment to routinely translate Nokia values into actions. Ethics, integrity, and compliance are embedded deep within our culture. This award represents our continuing commitment to values-based leadership and ethical practices. We are proud to have been honored with this prestigious award and will remain vigilant and proactive when it comes to preserving and enhancing our core values as the foundation of our ethical culture, our strategies, and our actions.
A solid foundation of integrity. The evolution of compliance at Nokia reflects the company’s journey from humble beginnings as a paper and rubber maker to a global leader in telecommunications infrastructure and technology. While integrity has long been a core value, our compliance program has had to adapt as the company has entered new industries and markets.
Compliance at Nokia has remained agile against the backdrop of an ever-shifting risk landscape, as issues such as privacy, information security and trade compliance take on ever-greater importance. If the only constant in today’s world is change, then adaptability and flexibility must be the watchwords of an effective compliance program.
Our compliance program has two aims: enabling business, while also protecting the company. Rather than ignoring the tension between these aims, recognizing it and balancing the competing aims is central to our role. We strike the balance by understanding our business colleagues’ goals and the strategies they use to deliver them and by working closely with them to assess, analyze, and mitigate compliance risks they may encounter along the way.
We have a well-deserved reputation for integrity, and as a team we feel a strong responsibility to preserve and enhance it. We are, therefore, proud to have been named by Ethisphere as one of 2018’s World’s Most Ethical Companies, recognizing us as a global leader in corporate ethics – the second time Nokia has been so honored.
Though our compliance program has several key elements, including effective and engaging compliance training and communications, robust audits and risk assessment processes, and more, it ultimately comes to this: at Nokia, compliance is a shared responsibility. It starts with every employee. They are expected to know and understand the rules, to ask questions when they are uncertain, and to speak up whenever they see something that doesn’t seem right.
Our leaders at every level – managers, supervisors, and executives – “own” compliance, meaning they, rather than lawyers or compliance officers, are responsible for making and being accountable for decisions. We expect them to set the tone and to lead by example. Supporting the entire company are compliance experts, responsible for educating employees and leaders to enable sound and responsible decision-making and for escalating matters, if needed, to ensure that decisions are always consistent with the company’s commitment to integrity.
It is this vision of compliance as a shared responsibility that serves as our foundation for compliance. Nokia is recognized for offering world-class products and services and cutting-edge technology. As we build on our long tradition of integrity, we strive every day to ensure that excellence and innovation also define compliance at Nokia.
Enabling a speak up culture. We are firmly committed to fostering an environment that encourages and welcomes views and inputs from all our employees, as well as others with whom we do business, about any potential violations of our Code of Conduct. Our Code of Conduct sets the tone for how we conduct business globally.
Our commitment to compliance with all relevant laws and regulations and to building and maintaining trust and credibility with our customers, partners, employees, suppliers, shareholders, and other stakeholders is unwavering. An important component of building a culture of trust is ensuring that employees and business partners are empowered to speak up when something is not right. To that end, our Code of Conduct and related compliance policies provide for various mechanisms for reporting compliance concerns, or simply for asking questions or requesting guidance about ethical dilemmas. The various mechanisms for bringing an issue to the attention of the compliance team are listed below. Whichever avenue one selects, the report or concern is handled confidentially by a diverse team of compliance professionals.
The Nokia Business Ethics Helpline is managed by an independent supplier and is available 24 hours a day, 7 days a week. Calls and conversations are entirely confidential, and a reporter may remain anonymous. The Helpline enables persons to report concerns in more than 23 different languages. In addition to the Nokia Business Ethics Helpline, concerns may always be raised with line managers, HR personnel, Legal and Compliance members, and local Ombuds representatives, who provide a local, impartial, and non-judgmental means for employees to raise questions or concerns.
We have zero tolerance for retaliation, and we encourage anybody who has concerns regarding compliance reporting retaliation to immediately contact a member of the compliance team. We are dedicated to ensuring that our employees are aware of the multiple reporting channels available to them and that they have confidence in our non-retaliation policy and feel comfortable in raising matters.
At Nokia, we continuously strive to reinforce our open reporting culture and encourage employees to report potential issues that violate our policies or the laws of any of the countries in which we operate. We stress the importance of operating within the law and staying true to our ethical culture because it is vital for the continued success of our business, our company identity, and our reputation. Our open reporting program and processes support our commitment to doing business the right way.
Encouraging and enabling open reporting – Global Ombuds Program. Fostering a speak-up culture and providing employees with a local and confidential network to safely raise compliance questions and concerns.
Nokia’s Ombuds program is designed to champion a speak-up culture that empowers employees to openly raise and discuss compliance questions and concerns. In addition to the normal channels for reporting, the Ombuds program provides a supplemental channel, comprised of a global network of on-site, local Ombuds Leaders. With more than 130 local Ombuds Leaders, the Ombuds network continues to grow.
We want to ensure that employees feel confident raising issues if they perceive misconduct has taken place and that they understand that Nokia has zero tolerance for retaliation against those employees who do speak up. Ombuds Leaders provide a safe and strictly confidential space to speak up. They remain completely neutral, impartial, and non-judgmental.
In addition to the standard reporting channels of Line Managers, Legal & Compliance, HR and the Ethics Helpline, the global network of Ombuds Leaders is a key pillar of our open reporting culture. Ombuds Leaders provide not only another means for employees to report suspected policy or law violations but also offer a safe place where employees can talk through compliance questions and concerns and receive guidance on compliance issues.
We are dedicated to ensuring that employees are aware of the multiple reporting channels available to them, understand and have confidence in our non-retaliation policy, and feel comfortable raising matters. It is extremely important for employees to speak up and raise concerns, as doing so allows the company to find and remedy problems early before they become more difficult to solve.
The aim of the Ombuds Program is to provide a confidential avenue for employees to raise concerns, to keep Nokia and its employees safe, and to assure that suspected wrongdoing is reported and addressed in a timely manner, as appropriate, without retaliation of any kind.
We rely on the voice of our employees.