• Version: 2.0
• Effective Date: 27 November 2024

1. Audience and Scope

This Supplier Code of Conduct (the “Code”) covers HMD Global Oy and all its affiliates (collectively referred to as “HMD”). This Code outlines what HMD expects from our suppliers in relation to Human Rights & Labour, Business Ethics, Environmental, Health and Safety and Management practices.

2. Review Mechanism

This Code is reviewed annually and updated as needed.

3. Our approach

This Code complies with international laws and regulations as well as the HMD values. In addition, we have looked into International Standards including the Responsible Business Alliance (RBA) (former Electronic Industry Citizenship Coalition’s) Code of Conduct; United Nations Declaration of Human Rights; United Nations’ Guiding Principles on Business and Human Rights; International Labor Organisation’s (ILO) Core Conventions; Environmental management standard ISO 14001; Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprise; Occupational health and safety management standard ISO45001 and the Social accountability standard SA 8000.

4. Business ethics

HMD is strongly committed to the highest standards of ethical conduct. Our suppliers shall operate by the same ethical standards we set for ourselves and comply with the related policies and procedures, and all applicable national and international laws.

4.1 Improper Payments

HMD believes in fairness and honesty; we obtain and retain our business relationships with these principles firmly in mind. Our suppliers shall adhere to anti-corruption laws and shall not make or allow anyone to make on their behalf any corrupt or inappropriate payment to HMD, our employees or customers, government officials or third parties. These improper payments can occur in many forms and include, among other things, bribes, gifts, entertainment, gratuities, favours, donations or facilitation payments. For the sake of clarity, facilitation payments, as known as “grease” payments, are small payments usually made in cash to a government official to speed up or guarantee a routine action that the official is already obligated to perform.

We extend our understanding of improper payments to include any transfer of value that is not consistent with HMD policies, procedures or applicable laws.

4.2 Fair Competition

Our suppliers shall adhere to marketplace regulations and anti-trust laws. These laws protect the market from unethical agreements and collaborations among competitors which may affect competition. Our suppliers shall uphold these standards of fair business, advertising and competition.

4.3 Privacy and Security

Privacy and security are key considerations in the creation and delivery of HMD’s products and services. Our suppliers shall commit to respect everyone’s privacy and to comply with applicable data protection and privacy laws. Our suppliers shall have in place internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments.

Our suppliers shall take appropriate steps to address online security, physical security, risk of data loss and other such risks; taking into consideration the risk represented by the processing and the nature of the data being protected.

Our suppliers shall not transfer personal data without ensuring it is safe, responsible and legal to do so. When confidential data is no longer needed, it shall be destroyed securely.

4.4 Intellectual Property and Confidential Information

It is essential that intellectual property rights are followed and respected. Whenever our suppliers have a need to transfer technology and know-how, they shall do so in a manner that protects intellectual property rights and any information regarding HMD should be safeguarded. In addition, our suppliers shall have in place an Incident Response Procedure (IRP) to manage breaches of confidential information.

4.5 Controllership

Our suppliers shall ensure that all transactions, assets and liabilities are accurately and fairly reflected in the company’s books and records in reasonable detail and supported by original documentation.

Our supplier shall comply with all applicable laws and regulations wherever they operate and shall not condone the falsification of records or misrepresentation of conditions throughout the supply chain.

4.6 Responsible Sourcing of Minerals

HMD is committed to international and industrial provisions as well as applicable laws related to conflict minerals. As used in this Code, the term “conflict minerals” or “3TG” refers to columbite-tantalite (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 neighbouring countries. The mining of these metals has the potential of funding military conflicts and human rights violations.

Our suppliers shall:

• report where the 3TG metals in our products were sourced from;

• not source 3TG metals that have directly or indirectly contributed to conflict, human rights violations, or environmental degradation; and

• maintain records of the due diligence performed on the source of the conflict minerals and information about the chain of custody for 5 years.

4.7 Confidential Reporting and Non-Retaliation

Our suppliers shall maintain programs that ensure their employees, suppliers, and other stakeholders have access to confidential and anonymous reporting channels, as well as protection in place for acts of whistleblowing. Our suppliers shall have in place a clear, visible and communicated process for anyone to be able to raise concerns without fear of retaliation.

5. Labour and Human Rights

At HMD we believe that everyone deserves respect, fair treatment and equal rights. Our suppliers create jobs all over the world and we expect them to commit to making those jobs have a positive impact on people’ lives. This is true for all types of workers - direct or indirect, permanent or temporary, interns local or migrant, and so on. We refer to all types of workers as simply “employees” or “workers” in this document.

5.1 Modern Slavery

Modern Slavery is an umbrella term that includes slavery, human trafficking, forced or compulsory labour and servitude. Modern slavery as a term refers to a situation where a person is coerced, deceived, taken unwillingly and/or indebted into a position where they feel trapped, held, compelled or forced to work. Work shall always be a voluntary act. Our suppliers shall ensure that anyone working for them or on their behalf is free to choose who they work for, when they work and where they work. Our suppliers shall not trap, compel or force another person to work. In addition, they shall have in place a system by which they can monitor anyone contracted to work on their behalf by these same standards. Our suppliers shall implement and maintain as part of their due diligence a system to uncover any abuses that may occur and to make this data available to HMD. We expect our suppliers and their employees to respect human rights and to report any suspected violation of the UK Modern Slavery Act to us through our legal team to [email protected] or to our Speak Up – channel¹.

5.2 Fair and Freely Chosen Employment

Our suppliers shall ensure that where required by law or industry practice, every employee has a contract that covers the terms and conditions of their employment agreement and is signed by both the employee and the supplier. The terms and conditions should contain all relevant aspects including but not limited to; working hours and guaranteed wage, overtime rates of pay and compensation, payment and frequency of payment and their notice period. In addition, the contract should be written in the native language of the employee, to ensure full understanding of the terms. In the case of migrant workers this contract should be available to them prior to leaving their country of origin.

Our suppliers shall ensure that all employees have all the training, equipment and experience to conduct their work duties safely. Employees shall be free to leave their work at any time and should never have their movement unreasonably restricted either within their workplace or when entering or exiting the facility. Unless otherwise required by law, our suppliers shall not hold, conceal or confiscate the personal documents (such as passport, identity card, immigration document, or work permit) of any worker as a condition for employment or access to supplier’s facilities.

No employee shall be required to make any payment to either the employer or an agent:

(i) in order to secure employment or receive training;

(ii) as a form of punishment; or

(iii) to be released from employment.

Our suppliers shall ensure that if they uncover any such fees being charged, the money shall be returned to the impacted employees promptly and the practice shall be suspended.

Our suppliers shall ensure that adequate policies and procedures are in place to protect workers and potential workers against any form of discrimination, harassment, harsh or inhumane treatment or any other unlawful discrimination or treatment, including disciplinary policies and procedures. No worker should be subjected to sexual abuse or harassment, physical, mental or verbal abuse or harassment, corporal punishment or any threats regarding treatment of this kind.

Our suppliers shall ensure that they employ, retain and promote possible candidates based on their qualifications, skills and competences only; they shall not consider a person’s race, sex, religion, marital status, pregnancy, nationality, ethnicity, disability, sexual orientation, expression and any other characteristic covered by law. Our suppliers shall provide workers with adequate facilities for religious practice. Under no circumstances should employees or potential employees be subjected to medical, physical or pregnancy examination or testing that could be used in a discriminatory way.

5.3 Young Workers Protection

We are committed to the principles of the United Nations Convention on the Rights of the Child and expect the same from our suppliers.

No one under the age of completing compulsory education or under the local legal age of employment or under 15 years of age (whichever is the greatest) shall be employed by, or on behalf of our suppliers. HMD expects its suppliers to verify the age of each candidate from their authorized Identification Card or Passport during recruitment and onboarding process.

Young workers (under the age of 18) need to be protected and our suppliers shall not require them to perform tasks that could risk their health & safety. In addition, young workers shall not work overtime or night shifts. Student workers shall be provided with training and support and our suppliers shall ensure that they maintain student records and conduct thorough due diligence of educational partners protecting the rights of the student in accordance with applicable laws and regulations. Young workers including students, interns and apprentices should be paid at least the same rate of pay as other employees that perform equal or similar tasks.

5.4 Working Hours and Wages

Our suppliers shall ensure that working weeks do not exceed the restrictions placed on them by local law. No worker shall work in excess of 60 hours per week including overtime and they must have at least one day off per six days worked. Workers shall also be entitled to at least two weeks of paid leave per year. In addition, overtime shall be limited to comply with local law or to a maximum of 12 hours per week. Overtime shall always be paid at a premium rate and be taken as a choice by the employee. Overtime should be used in unusual or emergency situations and should not be a regular request of workers. Workers shall be compensated in accordance with local laws in relation to minimum wage rates and legally mandated benefits and living wage. Workers shall be provided with wage statements in a timely manner that clearly indicate the hours worked so that they can verify their wage is correct. The document should be understandable to the worker in their native language if required. Temporary workers of any kind as well as outsourced workers shall be engaged within the restrictions of local law.

5.5 Communication, Collective Bargaining and Freedom of Association

Workers shall be provided with access to information that is relevant to their employment and their work. They shall be made aware of changes to their employment circumstances as they happen in order to conduct their work to the best of their ability. Our suppliers shall have in place the means to measure worker satisfaction and strive to improve this metric where possible. Workers shall be able to discuss openly their opinions, ideas and concerns without the fear of retaliation of any kind.

Our suppliers shall respect the rights of all workers to form and join trade unions of their choosing in conformance with local law and the requirements of this Code. Collective bargaining is an important right of employees, and they should be allowed to engage in peaceful assembly. In addition, workers shall be free to refrain from any such activity. Our suppliers shall refrain from any intimidation, harassment, retaliation and violence against trade union members/representatives.

The rights of whistle-blowers shall be protected, and confidential channels shall be offered for the reporting of unfair conditions of any kind.

5.6 Non-Disclosure Agreements

Our suppliers shall ensure that any workers that are in contact with confidential information regarding HMD have signed a Non-Disclosure Agreement (NDA). It is important that the employee is made fully aware of the meaning of this document and the extent of the agreement being made.

6. Environmental Protection

HMD is committed to environmental protection, and we manage our activities and our supply chain closely to ensure we not only meet the relevant legislation and international standards but wherever we can we strive for higher. We expect our suppliers to be committed to preventing and reducing the environmental impacts of its operations through transparent and ethical management practices. All required environmental permits, approvals, and registrations shall be obtained, maintained, and kept current and all operational and reporting requirements shall be followed.

6.1 Environmental Management Systems (EMS)

We expect our suppliers to be committed to preventing and reducing the impacts of our business through open and ethical management practices. Our suppliers shall have in place an Environmental Management System (EMS) that effectively plans, operates and controls significant environmental aspects of their operations and the electronics industry. They shall ensure at all times these measures at least comply with legal and legislative requirements. Our suppliers shall ensure that they periodically review their environmental legislation, applicable regulations and customer requirements and shall supply evidence of their compliance as requested. Additionally, our suppliers shall conduct and/or cooperate with internal and external environmental risk audits. Our suppliers shall implement improvement targets and programs, necessary employee training and communication, internal audits and management reviews.

We require our manufacturing partners to be certified as compliant with ISO14001 or the Eco-Management and Audit Scheme (EMAS).

6.2 Improving Environmental Performance

Our suppliers shall have in place continuous improvement projects aimed at identifying, measuring, controlling and improving their environmental performance. Environmental performance includes all significant environmental aspects related to their activity such as energy usage, water access, usage and conservation, waste and defect creation, materials reduction per product (which in turn reduces the effects on mining and biodiversity), plastics, hazardous materials and chemicals use reduction, improvement of risk management processes, implementation of the cleanest possible treatment of residues and control of waste generation.

Resource usage and waste creation of all kinds need to be reduced wherever possible either at source or through modifying processes or substituting materials. We expect our suppliers to look towards the “EU Waste Hierarchy” model and where possible they should aim to Reduce, Reuse, Recycle and Reclaim in that order of priority whenever and wherever possible

6.3 Energy Efficiency & Green House Gas (GHG) Emissions

Our suppliers shall commit to reducing their carbon footprint and shall measure and report on their energy consumption and Greenhouse Gas (“GHG”) emissions. This requires them to identify the sources of their emission both internally and externally and define clearly the scope of their reporting.

Our suppliers shall evaluate the data they collect and highlight areas for cost effective improvements to minimise GHG emissions within their control.

6.4 Air Emissions

We require any emissions to the air created by the operations of our suppliers to be characterised, monitored, controlled and treated prior to discharge. These emissions include aerosols and other ozone depleting chemicals, volatile organic chemicals, corrosives, particulates, and combustion by-products. In addition, our suppliers shall continuously improve the performance of their air emission control systems through routine identification and monitoring processes.

6.5 Water Use Reduction

As part of their EMS our suppliers shall identify and measure their water consumption and investigate ways in which they can reduce it.

6.6 Storm Water Management

As part of their EMS, we require our suppliers to take a systematic approach to the way they routinely manage, monitor and report their storm water management. Our suppliers shall minimise the risks of discharges or spills and they shall have robust systems in place to protect against pollutants from entering public drainage and ensure they comply with the law.

6.7 Waste & Wastewater Management

As part of their EMS, we require our suppliers to implement a comprehensive system that characterises, monitors, controls and treats waste and wastewater created by their operations and products. We also expect our suppliers to work towards reducing their waste creation and in turn increase the volume of recycled waste. This process must adhere to legal requirements and environmental best practice approaches before any discharge or disposal.

As part of their EMS, we also require our suppliers to comply fully with wastewater and solid waste management obligations. They must always maintain a systematic approach to wastewater and solid waste management. This includes having all the required permits and approvals in place (for instance, to store hazardous waste).

6.8 Design for Environment

Our suppliers shall have environmental consideration in all areas of product development. This includes adhering to our substance list and minimising or removing negative environmental impacts whenever it is possible to do so, for example by eliminating the use of hazardous constituents. These improvements can increase the efficiency of our products, reduce the use of materials and enable greater recycling capabilities.

6.9 Substance List

Our suppliers shall follow our Substance List and work closely with us and their suppliers to reduce or ban these materials and chemicals as stated in our Substance List.

6.10 Hazardous Substances

Chemicals and other materials that pose the risk of hazards to the environment require special care and attention. At all times their use should be restricted as much as possible and they should be clearly identified and managed. Their use, handling, storage, movement, recycling, reuse or disposal should be done in a controlled way that poses the least risk to the environment.

7. Health & Safety

As part of their management systems, our suppliers shall include aspects related to reducing the risk of work-related injury and illness. This is required to produce working environments that are conducive of productive, safe and healthy work. This requires communication and training as well as processes, rules, regulations and documentation.

7.1 Health & Safety Management System

Our supplier shall have in place an occupational health & safety management system that complies with the ISO45001 or similar internationally recognised standards. The system must cover aspects such as the planning, operation and control of risks and hazards related to health & safety including training and communication/feedback sessions for employees, periodic auditing and assigned improvement programs and targets.

As part of this system our suppliers shall have a standard procedure in place to access and control the risks of accidents and injuries as well as occupational diseases in a proactive and preventative manner. Additionally, an appointed senior manager shall be responsible for periodically ensuring the system is functioning and is suitable.

7.2 Health & Safety Training and Communication

Our suppliers shall ensure that those responsible for ensuring the health and safety of workers are sufficiently trained and knowledgeable as well as given adequate time and resources to perform their tasks. All employees shall be trained on the health and safety aspects that are appropriate for their role in their native language. Health and Safety signage and communications shall be clearly present in and around the facility.

7.3 Occupational Health & Safety

Our suppliers shall have measures in place to safeguard against preventable accidents and emergencies. Nominated employees that are responsible for Occupational Health and Safety shall be trained and workers shall be encouraged to raise safety concerns. Employees shall be protected against exposure to potential hazards such as slip/trip or fall hazards, vehicles hazards, fire or from electrical/energy sources through adequate procedures that identify, minimise and prevent hazards. These procedures include an ongoing safety training program and safety instructions, preventable maintenance and safe work practices, clear signage, machine maintenance and safeguarding, chemical controls, personal protective equipment and clothing, hearing protection and excessive noise reduction. Additional care shall be taken with employees under 18 years of age (young workers). Suppliers shall take responsibility for their employees when they carry out work off premises.

7.4 Emergency Preparations

Emergency procedures shall be in place to identify potential emergency situations and events. Our suppliers shall have emergency plans, evacuation procedures, employee training and drills, appropriate fire detection, sufficient extinguishers, adequate exit facilities and recovery plans in place in case any emergency should arise. Our suppliers shall have a pro-active approach to emergency risk and ensure that wherever possible risks to life, the environment and property are minimised.

7.5 Occupational Injury and Illness

Our Suppliers shall, as part of their Health and Safety Management system, have procedures to mitigate and manage injuries and illnesses sustained by their employees. This requires prevention, management, tracking and reporting on occupational injury and illness. Employees shall be provided with a means to report discomfort, illness and/or injuries sustained. All suspected and actual injuries and illnesses reported by employees shall be classified and recorded and employees shall be provided with treatment or equipment to aid with their recovery and prevent future problems. In addition, investigations shall be made and corrective actions taken to eliminate their causes to ensure that workers can return safely to work.

7.6 Industrial Hygiene

Our suppliers shall have in place engineering and administrative measures to identify, monitor, control and limit workers’ exposure to chemical, biological and physical agents to prevent overexposure. Adequate personal protective equipment shall be supplied to workers at risk.

7.7 Physically Demanding Work

Our suppliers shall have processes to identify, evaluate and control hazards of physically demanding work. Employees shall be protected and trained on aspects such as manual handling, repetitive tasks (i.e. in assembly), heavy lifting and prolonged periods of standing or sitting. When such hazards are found, our suppliers shall monitor, aim to control and minimise their risks.

7.8 Equipment Safeguarding

Our suppliers shall have adequate management systems in place where employees are handling dangerous or hazardous substances or operate dangerous equipment, production machines or other machinery. In all of these cases our suppliers shall ensure that workers are provided with the correct protective equipment and the equipment/machinery should be fitted with properly maintained guards, interlocks and barriers to ensure our employees safety.

7.9 Clean and Safe Buildings and Facilities

Our suppliers shall provide workers with safe and clean buildings and facilities. This includes workers having access to clean drinking water, adequate and clean toilet facilities, sanitary food preparation and storage areas as well as safe and clean eating facilities. In those facilities that require workers to live on site, dormitories shall be provided by the supplier or their labour agent. Dormitories shall be well maintained to ensure safety and reasonable personal space. There shall be access to lockable storage for each worker’s private belongings. The dormitories shall be clean with appropriate emergency exits and signage, access to clean drinking water, hot water for bathing/washing and adequate heating and ventilation. Workers shall have reasonable privileges to enter and leave their accommodation and these facilities shall comply with the applicable legal safety standards and regulations.

8. Management

Our suppliers shall have their own code of conduct, based on internationally recognized standards, to showcase their values and commitment to ethical, environmental, human rights, labour and health and safety topics related to their business operations. Procedures and physical controls shall be adequate for the associated risk and in accordance with this document. The supplier shall promote continuous improvement of its practices and comply with all relevant laws and regulations. A copy of the supplier’s code in the local language of the place where the facility is located shall be made available to employees. In addition, we expect our suppliers to have a process for setting requirements in their code to their suppliers and monitoring compliance. Our suppliers’ management shall ensure that the messages contained in their code are transferred throughout their business and relevant employees are trained on its contents and related procedures, risks and policies. In addition, we expect our suppliers to be able to show supporting documentation and/or evidence that such actions are taking place and training should be recorded as and when it is completed. Training shall be in accordance with applicable laws and regulations.

8.1 Management Systems

Our suppliers shall identify the senior executives and company representatives responsible for ensuring the management systems and associated programs are in place. Additionally, senior management will review the systems periodically with the focus on ensuring they are adequate.

8.2 Environmental and Social Objectives

Our suppliers shall set objectives with realistic timeframes and clear implementation plans to improve their environmental and social performance. Suppliers shall also have clear processes in place for reviewing the implementation progress and amending expectations as appropriate.

8.3 Audits, Assessments and Corrective Actions

Our suppliers shall conduct self-evaluations periodically to ensure that they conform to legal and regulatory requirements and allow for external auditors to conduct similar audits of their facilities to check if they comply with the content of this Supplier Code of Conduct and our contractual requirements. Our suppliers shall ensure that the required corrective actions are implemented at the supplier’s cost in a timely manner and these activities are monitored and reported following the correct procedure, ensuring regulatory compliance whilst protecting privacy.

8.4 Communication and Worker Participation and Feedback

Our suppliers shall make clearly available to their workers their internal policies, procedures, expectations and practices. Workers shall receive adequate training to meet these requirements and be given the right to participate in and give feedback on practices and conditions covered. This shall be an ongoing progress of continuous feedback and improvement measure.

8.5 Documentation and Records

Our suppliers shall create and maintain relevant documentation to ensure their compliance and conformity on all the matters discussed in this Code. This documentation shall be made available to HMD or external auditors working on behalf of ourselves or our customers. Appropriate measures shall be taken to protect privacy rights.

9. Supplier Management & Purchasing

Our suppliers shall have adequate measures in place to set requirements and manage the compliance of their own suppliers. The term supplier used in this section includes any company/person who, from HMD’s perspective, would be considered a sub-supplier such as vendors, subcontractors, service providers, partners, etc. Supplier base management systems must ensure sub-suppliers conform with this Code as well as all applicable laws and regulations. Our suppliers shall take these conformance aspects into consideration when choosing their suppliers and they shall have a structure by which they identify, evaluate and select suppliers.

Purchase and Service agreements shall be used with all suppliers and shall include valid Non-Disclosure Agreements (NDAs). These NDAs shall align and conform to the NDAs in place between HMD and the supplier.

Our suppliers shall set environmental, labour (including health and safety, human rights and ethics) and management requirements for their sub-suppliers. This also includes aspects such as waste handling and recycling. In addition, sub-suppliers who are responsible for waste disposal shall be appropriately authorised and licensed to carry out these tasks and our suppliers shall ensure this compliance.

10. Communication

This policy is made available on HMD public website² and on HMD internal SharePoint (or any other SharePoint site where policies might be stored in the future). HMD arranges regular training and guidance regarding this policy.

11. Disciplinary Measures

HMD will assess its suppliers’ conformance with this Supplier Code of Conduct and any violation will result in remedial actions. Failure of our supplier to comply with this Supplier Code of Conduct or the remedial actions set could result in termination of the business contract.

12. Reporting Channel and Whistleblower protection

To maintain the trust and confidence of our employees and suppliers, 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 Up³, 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.

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

²HMD Supplier Code of Conduct is available at: https://www.hmd.com/ethics/code-of-conduct/hmd-global-supplier-code-of-conduct

³HMD SpeakUp channel available at: https://secure.ethicspoint.eu/domain/media/en/gui/104743/index.html