Nokia Oyj

Supporting informed public policies for digitalization and sustainable development\n\nAt Nokia, we collaborate with governments, regulators, international organizations, trade associations, industry peers and academia to inform effective policy making and support the development of the best policy framework for sustainable and inclusive digitalization.\n\nNokia engages with policymakers and regulators transparently and constructively. We offer our expertise on trusted and reliable international connectivity, on the security of digital infrastructures, on a regulatory regime that facilitates network rollout\n\n\nand other digital policy endeavors, on best policy frameworks unlocking innovation, on improving the resilience of economies and their critical\n\ninfrastructure (e.g. energy grids) and on the most\neffective regulations for sustainability (e.g. forced\nlabor regulation or due diligence in supply chains).\nNokia's experts are detailing roadmaps toward 6G in\nseveral parts of the world. We advise on spectrum for\nbroadband, including through our participation in the\nWorld Radiocommunication Conference 2023 in Dubai.\n\nIn 2023, we contributed our experience and expertise\nengaging and leading discussions in organizations\ndeveloping best practices for the industry and advising\npolicymakers across the regions. These included\nthe European Round Table for Industry (ERT) and\nDIGITALEUROPE in Europe, the Samena Council in\nMEA, the Technology Council of Australia, the leading\nbody representing the technology sector in Australia,\nCII (Confederation of Indian Industry) in India. We\ncollaborated with think tanks such as the European\nCouncil on Foreign Relations (ECFR) and the German\nMarshall Fund to promote informed debates on policies\nbeneficial to society.\n\nOur guidelines for dealing with government officials\nalways apply, regardless of the employee's role and\nthe purpose or frequency of interaction. They also\napply to interactions with employees of state-owned\ncompanies and other governmental customers. The\nbasic guidance for interaction with a government\nofficial is laid down in our Code of Conduct. We do not\nparticipate in the political or electoral process through\ndirect donations to political groups.

We have an active global network of people with global positions, and the messages are agreed jointly in regular meetings between all relevant colleagues. Processes-wise we have e.g., training and governance which support the consistency. Environmental management, including climate change topics, as well dealing with government officials are part of Nokia Code of Conduct (CoC) and there is an annual mandatory CoC training called Ethical Business Training for all employees. As part of our certified Environmental management system, based on ISO 14001, we also arrange different environmental trainings and conduct internal audits. Our Environmental management system is globally certified according to ISO 14001 and the external audits done by a third party check consistency with our internal guidelines and ISO 14001 requirements. Nokia's Government Affairs (GA) team and ESG team belong to the same organization and work regularly together. The teams have a standing monthly alignment meeting to assess political and regulatory developments around ESG (including climate) and Nokia's advocacy related to them. Specifically related to industry associations, which are developing joint industry views on various policy issues, GR team is centrally coordinating Nokia representation in the associations. This central coordination ensures consistency in messaging even when different experts across Nokia engage in different work streams of industry associations across continents. Issues are discussed also at the management team level, for example in our Sustainability Council including people who are in charge or both implementing and developing strategy and policy activities, to ensure consistency of messages with the strategy. All our policy engagements are consistent with the company's overall sustainability strategy.

Ethical engagement We do not participate in the political or electoral process through direct donations to political groups. Our guidelines for dealing with government officials always apply, regardless of the employee's role and the purpose or frequency of interaction. They also apply to interactions with employees of state-owned companies and other governmental customers. The basic guidance for interaction with a government official is laid down in our Code of Conduct. [...] Supporting informed public policies for digitalization and sustainable development We believe that if we couple technological innovation with international cooperation and inclusive policies, we can make our planet healthier and our societies fairer. The United Nations SDGs establish a clear framework for us all. The next generation of connectivity technology and its applications are critical tools to enable a sustainable transformation towards digital societies that can enhance productivity, improve quality of life and reduce inequalities on a global scale. At Nokia, we collaborate with governments, regulators, trade associations, international organizations, industry peers, influencers and academia to drive policies that encourage investment in digital and broadband technologies and contribute to a green transition. [...] Across the globe, Nokia engages with policymakers and regulators transparently and constructively to advise on spectrum for broadband, the security of digital infrastructures, a regulatory regime that facilitates network roll out and other digital policy endeavors. In 2022, we contributed to evidence-based discussion by engaging and leading discussions in organizations developing best practices for the industry and advising policymakers. These included the European Round Table for Industry (ERT), the Global System for Mobile Communications Association (GSMA), DIGITALEUROPE and national associations such as BITKOM. We collaborated with think tanks such as the European Council on Foreign Relations (ECFR) and the German Marshall Fund to promote informed debates on policies beneficial for society.

The Board oversees the overall sustainability and climate related strategies, and reviews the materiality matrix which includes climate-related topics. Topics related to the progress and performance of the Group's climate commitments are reviewed regularly as needed. Climate-related topics are also included in the Annual Report and People and Planet Report which are reviewed by the Board. [...] Internal councils and committees, such as the Sustainability council, are used to steer, align and ensure the implementation of these strategies, targets and frameworks and review recommendations to the Group Leadership Team. In 2023, the Sustainability council was managed by the Vice President of Sustainability, who reports to the Chief Corporate Affairs Officer. During the year the council convened 10 times. [...] The corporate ESG function is responsible for Nokia sustainability strategy. Together with the Business Group representatives, the ESG team develops and gains approval for a coordinated Nokia level risk response strategy and related target setting. This central team drives the implementation of the sustainability strategy and actions needed to achieve targets, such as the GHG emissions reduction targets, at the operational level. Subject matter experts contribute fact-based input to the different functions and business groups.

###### Nokia Board of Directors\n\n- Reviews sustainability performance and targets minimum once a year and\napproves select key sustainability targets and corporate donations budget.\n\n- Specific sustainability topics are reviewed by Board Committees based\non their responsibilities, including sustainability reporting, related risk management, ethics, cybersecurity and privacy, culture, human capital management and\nembedding sustainability in our technologies.\n\n###### Managing sustainability\n\n Sustainability issues are reviewed regularly at all levels of the company. We will continue to strengthen our governance structures and the processes we have established to manage ethical business practices and corporate responsibility, reflecting the significant change in our mode of operation implemented in the company during 2021.\n\nOur Code of Conduct provides our requirements\nand guidance for all employees. Our suppliers\nand partners are also expected to adhere to the\nprinciples laid down in the Code. The Code is\napproved by our Board of Directors and supported\nby policies and management systems related to\nresponsibility issues. Our key corporate responsibility\npolicies are regularly updated and can be found\nonline. Our overall sustainability governance\nframework and responsibilities are shown in the chart\non this page and further described in the following\nparagraphs. More information about our corporate\n[governance practices is available in our annual](https://www.nokia.com/about-us/investors/)\n[reports and on our website.](https://www.nokia.com/about-us/investors/)\n\n###### Board of Directors\nThe Board of Directors evaluates Nokia's\nenvironmental and social activities and governance\npractices (ESG), related risks and target setting as\nwell as their implementation and effectiveness in\nthe Company. In 2021, the Board approved select\nkey ESG targets on climate change and diversity\nincluded also in the short-term incentive program\nand reviewed evolving ESG requirements and\nexpectations, investor feedback and the disclosure\napproach. The Board also approved our Corporate\nCommunity Investment and University donations\nbudget for the year 2022.\n\n###### ESG function and Sustainability Forum \n\nThe corporate ESG function\ndrives the implementation of\nthe sustainability strategy and\nactions needed to achieve\ntargets at the operational\nlevel. A Forum of subject\nmatter experts from business\nunits and functions facilitates\ninformation sharing and helps\nimplement processes and\nactivities to achieve targets.\n\n###### Ethics and Compliance Office\n\nProvides training and\nsupports employees in\nmaking decisions that are\nethical, legal, and consistent\nwith our values. Investigates\nconcerns about potential\nbreaches of our Code of\nConduct.\n\n--NEW-PAGE--\n\nIn addition, the Board Committees monitor\nenvironmental and social developments and\nactivities in the Company in their respective areas of\nresponsibilities. During 2021, the Audit Committee's\nresponsibilities included the implementation\nplanning of new climate and other sustainability\nreporting requirements, as well as oversight of the\nethics and compliance program and cybersecurity\nrisks and maturity. The Audit Committee also reviews\nannually sustainability disclosures as well as the use\nof conflict minerals in Nokia's products presented\nin the annual reports and related regulatory filings.\nThe Personnel Committee assists the Board in the\nincorporation of ESG-related metrics in incentive\nstructures and oversees human capital management,\nincluding personnel policies and practices related\nto Nokia culture, employee wellbeing, diversity,\n[recruiting, development and retention. Corporate](https://www.nokia.com/sites/default/files/2022-03/Nokia_Corporate_Governance_2021_EN.pdf)\nGovernance and Nomination Committee assesses\nand advises the Board in environmental, social and\ngovernance (ESG) related activities and practices\naiming to enhance governance structure supporting\nthem. The Technology Committee reviews how\nsustainability is embedded into our technology\nstrategy and roadmaps. Read more in our Corporate\ngovernance statement.\n\n###### Group Leadership Team\nThe Nokia Group Leadership Team (GLT) is chaired\nby the President and CEO. In 2021, the Chief\nCorporate Affairs Officer had overall responsibility\nfor sustainability in the GLT. In line with our new\nmode of operation, the GLT approves sustainability-related strategy, targets and operational frameworks,\nwithin which corporate functions and business\n\n--NEW-PAGE--\n\n###### ESG function\nAt the operational level, sustainability is managed\nby the ESG (Environment, Social and Governance)\nfunction, the Ethics and Compliance Office and\nsubject matter experts in other functions and\nbusiness units. The alignment of the sustainability\nstrategy, priorities and the implementation of\nsustainability activities across Nokia is steered by\nour Sustainability Council. The council consists of\nsenior leaders from units representing product\ndevelopment, sales, real estate, strategy and\ntechnology, human resources and procurement.\nThe council also contributes to the sustainability\n\nstrategy, materiality assessment and reviews of\nsustainability targets and performance. These\nresponsibilities also include assessment and\nmonitoring of climate-related topics. In 2021, the\ncouncil was managed by the Vice President, ESG, who\nreported to the Chief Corporate Affairs Officer. In\n2021, the council convened seven times.\n\n###### Risk and opportunity management\nSustainability risks and opportunities are part\nof our Enterprise Risk Management framework\nwhich includes multi-disciplinary company-wide\nrisk identification, assessment and management\nprocesses. We recognize and aim to mitigate the\npotential risks and negative impacts associated\nwith our business whether related to technology,\nsupply chain, climate or people, while also driving\nthe opportunities within and beyond our business in\norder to contribute to achieving the UN Sustainable\nDevelopment Goals. Our Code of Conduct defines\nour way of working and we have clear policies\nand processes for each identified material\nsustainability risk.\n\nThe main features of our risk management systems\nand the roles of the Board of Directors and the\nGroup Leadership Team within those systems are\ndescribed as part of our corporate governance\n[statement (see Risk management, internal control](https://www.nokia.com/sites/default/files/2022-03/Nokia_Corporate_Governance_2021_EN.pdf)\n[and internal audit functions at Nokia). The most](https://www.nokia.com/sites/default/files/2022-03/Nokia_Corporate_Governance_2021_EN.pdf)\nimportant risk factors and the principal factors and\ntrends affecting our operations are discussed in our\n[Form 20-F filing for the year 2021 here. For more](https://www.nokia.com/system/files/2022-03/nokia-ar21-20f_0.pdf)\ninformation on Nokia Enterprise Risk Management,\n[please go to our website.](https://www.nokia.com/about-us/company/leadership-and-governance/risk-management/)\n\nIn addition, the Board Committees monitor\nenvironmental and social developments and\nactivities in the Company in their respective areas of\nresponsibilities. During 2021, the Audit Committee's\nresponsibilities included the implementation\nplanning of new climate and other sustainability\nreporting requirements, as well as oversight of the\nethics and compliance program and cybersecurity\nrisks and maturity. The Audit Committee also reviews\nannually sustainability disclosures as well as the use\nof conflict minerals in Nokia's products presented\nin the annual reports and related regulatory filings.\nThe Personnel Committee assists the Board in the\nincorporation of ESG-related metrics in incentive\nstructures and oversees human capital management,\nincluding personnel policies and practices related\nto Nokia culture, employee wellbeing, diversity,\n[recruiting, development and retention. Corporate](https://www.nokia.com/sites/default/files/2022-03/Nokia_Corporate_Governance_2021_EN.pdf)\nGovernance and Nomination Committee assesses\nand advises the Board in environmental, social and\ngovernance (ESG) related activities and practices\naiming to enhance governance structure supporting\nthem. The Technology Committee reviews how\nsustainability is embedded into our technology\nstrategy and roadmaps. Read more in our Corporate\ngovernance statement.\n\n###### Group Leadership Team\nThe Nokia Group Leadership Team (GLT) is chaired\nby the President and CEO. In 2021, the Chief\nCorporate Affairs Officer had overall responsibility\nfor sustainability in the GLT. In line with our new\nmode of operation, the GLT approves sustainability-related strategy, targets and operational frameworks,\nwithin which corporate functions and business

Supporting informed public policies for digitalization and sustainable development We believe that if we couple technological innovation with international cooperation and inclusive policies, we can make our planet healthier and our societies fairer. The United Nations SDGs establish a clear framework for us all. The next generation of connectivity technology and its applications are critical tools to enable a sustainable transformation towards digital societies that can enhance productivity, improve quality of life and reduce inequalities on a global scale. At Nokia, we collaborate with governments, regulators, trade associations, international organizations, industry peers, influencers and academia to drive policies that encourage investment in digital and broadband technologies and contribute to a green transition. The rollout of 5G and leading-edge fiber networks is the foundation upon which decarbonization can thrive. Through robust connectivity, society can accelerate the rollout of sensors, Augmented Reality (AR) and Virtual Reality (VR), cloud, and analytics to maximize the sustainable benefits of technology. Policies that encourage broadband adoption and the digital transformation of industry, that maximize available spectrum for connectivity, and that enable rapid deployment of digital infrastructure will help meet climate change goals. We were shocked by Russia's invasion, in 2022, of Ukraine, in contravention of international law. Russia's illegal invasion continues to bring into sharp focus the importance of communications infrastructure as the critical backbone of society. We have worked together with our customers and partners in Ukraine to help those in need and ensure Ukrainians remain connected. We continue to explore ways in which we can be a trusted partner to Ukraine and participate in the country's reconstruction. Our Chief Corporate Affairs Officer, Melissa Schoeb, serves as a member of the Center for Strategic and International Studies' Ukraine Economic Commission. We are also working towards our responsible, swift and compliant exit from Russia as announced on April 12th, 2022. Russia's invasion of Ukraine has also brought increased pressure on the global economy, already weakened by the coronavirus pandemic, and affecting livelihoods especially in developing countries. In other regions, there have been concerns especially around inflation and energy supply. The invasion and its impacts have yet again highlighted that sustainability is increasingly a dimension of societal resilience and that we must accelerate our progress towards a greener world. Technology has a key role to play as a enabler, unlocking economic opportunity and growth, facilitate access to work, education, health and other public services. Governments should further engage with industry to develop the best policy framework for sustainable and inclusive digitalization. Across the globe, Nokia engages with policymakers and regulators transparently and constructively to advise on spectrum for broadband, the security of digital infrastructures, a regulatory regime that facilitates network roll out and other digital policy endeavors. In 2022, we contributed to evidence-based discussion by engaging and leading discussions in organizations developing best practices for the industry and advising policymakers. These included the European Round Table for Industry (ERT), the Global System for Mobile Communications Association (GSMA), DIGITALEUROPE and national associations such as BITKOM. We collaborated with think tanks such as the European Council on Foreign Relations (ECFR) and the German Marshall Fund to promote informed debates on policies beneficial for society. Ethical engagement We do not participate in the political or electoral process through direct donations to political groups. Our guidelines for dealing with government officials always apply, regardless of the employee's role and the purpose or frequency of interaction. They also apply to interactions with employees of state-owned companies and other governmental customers. The basic guidance for interaction with a government official is laid down in our Code of Conduct.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]We have an active global network of people with global positions, and the messages are agreed jointly in regular meetings between all relevant colleagues. Processes-wise we have e.g., training and governance which support the consistency. Environmental management, including climate change topics, as well dealing with government officials are part of Nokia Code of Conduct (CoC) and there is an annual mandatory CoC training called Ethical Business Training for all employees. As part of our certified Environmental management system, based on ISO 14001, we also arrange different environmental trainings and conduct internal audits. Our Environmental management system is globally certified according to ISO 14001 and the external audits done by a third party check consistency with our internal guidelines and ISO 14001 requirements.
Nokia's Government Affairs (GA) team and ESG team belong to the same organization and work regularly together. The teams have a standing monthly alignment meeting to assess political and regulatory developments around ESG (including climate) and Nokia's advocacy related to them. Specifically related to industry associations, which are developing joint industry views on various policy issues, GR team is centrally coordinating Nokia representation in the associations. This central coordination ensures consistency in messaging even when different experts across Nokia engage in different work streams of industry associations across continents. Issues are discussed also at the management team level, for example in our Sustainability Council including people who are in charge or both implementing and developing strategy and policy activities, to ensure consistency of messages with the strategy. All our policy engagements are consistent with the company's overall sustainability strategy.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes