1 Audience

In this document, HMD/our/we refer to HMD Global Oy (“HMD”) and all its affiliates. The Conflict Mineral Policy, which builds on HMD’s Code of Conduct, is global and covers all HMD legal entities and applies to all employees and external persons working on behalf of HMD. It is the employee’s responsibility to be aware of the content and any subsequent changes and be fully compliant with the Conflict Mineral Policy.

Moreover, HMD also expects our suppliers, partners, and other representatives to adhere to the same high standards of ethical behavior and legal compliance when they are working on our behalf.

2 Review Mechanism

This policy is reviewed annually and updated as needed.

3 Content

HMD is committed to international and industrial provisions as well as applicable laws related to conflict minerals. In building this Conflict Mineral Policy we follow the guidance of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas as well as the guidance of Conflict-Free Sourcing Initiative (CFSI). We require our suppliers to trace the origins of all products containing conflict minerals as described in this Conflict Mineral Policy, to ensure they are sourced from sustainable and socially responsible sources only.

The term “conflict minerals” used here refers to a group of minerals/metals often referred to as 3TGs which are: columbite-tantalite (coltan) (or its derivative tantalum), cassiterite (or its derivative tin), gold and wolframite (or its derivative tungsten) that are sourced from the Democratic Republic of the Congo (DRC) and neighboring countries. The mining of these metals has the potential of funding military conflicts and human rights violations. In these countries where conflicts are ongoing legitimate trade is very difficult to achieve. Therefore, we need to work collectively to ensure we are operating responsibly. We are monitoring the work of the Responsible Raw Material Initiative (RRMI) and their study into Cobalt on child labour, human rights and environmental issues and will act in accordance with its recommendations.

The risks involved in sourcing these materials are vast: from the mines through the transportation routes and trading centers to the bigger distributors and on to our manufacturing partners. For this reason, we must operate as a committed member of a wider system. As we have such a distance from these sources, we look to ensure a reliable “chain of custody”, otherwise known as a document trail, that contains details of every person or company that has been in possession of materials throughout the supply chain.

We require our suppliers to report where the 3TG metals in our products were sourced and we require our suppliers to maintain their due diligence on this data for 5 years. We also require that our suppliers commit to sourcing materials that have not directly or indirectly contributed to conflict, human rights violations, or environmental degradation. We will make our progress available to our partners with the aim of building awareness, transparency, and capacity of conflict-free materials in our supply chain. We also look to review our approach regularly regarding our Conflict Mineral Policy to ensure we continue to operate in a sustainably, ethically and socially responsible manner.

The topics contained in this Conflict Mineral Policy are also enforced in our Supplier Requirements which is a contractually binding document between HMD and our suppliers. We also conduct due diligence as per the recommendations made in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. For our suppliers to meet our expectations we require that they conduct the same due diligence in their supply chain.

4 CMRT Reporting

The Conflict Minerals Reporting Template (CMRT) is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that facilitates the transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. The template also facilitates the identification of new smelters and refiners to potentially undergo an audit via the RMI’s Responsible Minerals Assurance Process (RMAP).

We report through the CMRT template results for all our phone and tablet models. The template helps us to transfer information through supply chain regarding mineral country of origin, and smelters and refiners being utilized.

5 Requirements Compliancy

We continuously keep track of related new regulatory and industrial requirements, and make sure we are compliant with those. We are compliant with the EU regulation on conflict minerals (The European Union Conflict Minerals Regulation (CMR)) that came into force 1.1.2021. The regulation requires EU companies in the supply chain to ensure they import these minerals and metals from responsible and conflict-free sources only.

6 Roles and Responsibilities

All employees shall:

• familiarize themselves with this policy;
• comply with the requirements of this policy and other applicable policies.

HMD line managers shall:

• ensure that employees understand and are committed to this policy;
• ensure that all reasonable steps are made to eliminate violations against this policy;
• ensure that all employees are regularly made aware of their obligations in relation to this policy;
• take action and report if they become aware of any violations of this policy.

Human Resources and senior management shall:

• ensure that policies and procedures are regularly reviewed and (if necessary) amended;
• ensure that guidance and training is provided to employees regarding this policy;
• ensure that this policy is made available to all employees internally;
• ensure that managers are aware of their obligations and responsibilities in relation to this policy.

7 Communication

This policy is made available to all employees in the internal Onboarding SharePoint site (or any other SharePoint site where policies might be stored in the future). Human Resources arranges regular training and guidance regarding this policy, and briefs new employees on the content of the policy during the onboarding process.

8 Disciplinary Measures

Employees who violate this policy shall be subject to discipline up to and including termination of employment.

9 Reporting Channel and Whistleblower protection

To maintain the trust and confidence of our employees we offer confidential reporting channels. These channels ensure that we never put our employees in a position where they are uncomfortable reporting matters that are of importance to us. We extend this protection to our supplier’s employees, our tier 2 suppliers’ employees, or anyone who reveals breaches of our policies or our Code of Conduct to us. In addition to approaching a member of HMD management, Legal, Compliance or Human Resources team you can also report anonymously via HMD Ethics channel called Speak Up¹, which is available from HMD Onboarding site and HMD internet pages.

HMD adheres to a strict policy of no retaliation. No reporter shall suffer any adverse consequence for raising a concern regarding potential violations of this policy or for refusing to engage in activities in violation of this policy. No report made in good faith should carry the threat of retaliation against the reporter.

¹ HMD SpeakUp channel available at: https://secure.ethicspoint.eu/domain/media/en/gui/104743/index.html