Nokia Oyj – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Nokia discloses a structured process that seeks to keep both its direct and indirect policy engagement aligned with its climate goals. The company states that “Nokia’s Government Affairs (GA) team and ESG team belong to the same organization and work regularly together” and that they hold “a standing monthly alignment meeting to assess political and regulatory developments around ESG (including climate) and Nokia's advocacy related to them,” providing a clear, recurring mechanism for managing its own lobbying positions. For trade-association activity, the company reports that the “GR team is centrally coordinating Nokia representation in the associations. This central coordination ensures consistency in messaging,” showing that indirect lobbying is subject to the same alignment checks. Oversight responsibility is assigned at senior levels: “Internal councils and committees, such as the Sustainability council, are used to steer, align and ensure the implementation of these strategies… In 2023, the Sustainability council was managed by the Vice President of Sustainability, who reports to the Chief Corporate Affairs Officer,” while “The Board oversees the overall sustainability and climate related strategies, and reviews the materiality matrix which includes climate-related topics.” Governance is reinforced through mandatory annual “Ethical Business Training for all employees” built around the Code of Conduct, and the company asserts that “all our policy engagements are consistent with the company's overall sustainability strategy.” These disclosures indicate strong governance covering both direct and indirect lobbying and naming accountable bodies, yet the company does not disclose a dedicated climate-lobbying alignment report or specific examples of reviewing, correcting, or exiting associations whose positions conflict with its climate policy, limiting transparency on the effectiveness of the process. View Sources	B

Overall Assessment

Analysis

Score

Strong

Nokia discloses a structured process that seeks to keep both its direct and indirect policy engagement aligned with its climate goals. The company states that “Nokia’s Government Affairs (GA) team and ESG team belong to the same organization and work regularly together” and that they hold “a standing monthly alignment meeting to assess political and regulatory developments around ESG (including climate) and Nokia's advocacy related to them,” providing a clear, recurring mechanism for managing its own lobbying positions. For trade-association activity, the company reports that the “GR team is centrally coordinating Nokia representation in the associations. This central coordination ensures consistency in messaging,” showing that indirect lobbying is subject to the same alignment checks. Oversight responsibility is assigned at senior levels: “Internal councils and committees, such as the Sustainability council, are used to steer, align and ensure the implementation of these strategies… In 2023, the Sustainability council was managed by the Vice President of Sustainability, who reports to the Chief Corporate Affairs Officer,” while “The Board oversees the overall sustainability and climate related strategies, and reviews the materiality matrix which includes climate-related topics.” Governance is reinforced through mandatory annual “Ethical Business Training for all employees” built around the Code of Conduct, and the company asserts that “all our policy engagements are consistent with the company's overall sustainability strategy.” These disclosures indicate strong governance covering both direct and indirect lobbying and naming accountable bodies, yet the company does not disclose a dedicated climate-lobbying alignment report or specific examples of reviewing, correcting, or exiting associations whose positions conflict with its climate policy, limiting transparency on the effectiveness of the process.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Nokia provides only limited transparency around its climate-related lobbying. It does name one concrete policy – the EU Taxonomy – and acknowledges that it has “support with minor exceptions” while seeking “better inclusion of digital tools and technologies in the Taxonomy,” but it does not identify any other specific climate laws or regulations it has tried to influence. The company describes its methods in broad terms, saying it engages directly with policymakers and indirectly through trade associations such as DIGITALEUROPE and the European Roundtable of Industrialists, yet it does not spell out what form those interactions take (for example, meetings, consultation submissions or letters) or which government bodies or officials were approached. Likewise, aside from the request to expand the EU Taxonomy, the disclosures speak only of general aims like promoting digitalisation to enable the green transition and do not set out further concrete legislative changes or measurable targets it is advocating. Together, this leaves a partial picture of its lobbying activities, with one named policy and broad descriptions of engagement, but few specifics on mechanisms used or the full range of policy outcomes sought.	D