EX-1.01 2 ss44635_ex0101.htm CONFLICT MINERALS REPORT

Exhibit 1.01

NOKIA CONFLICT MINERALS REPORT FOR 2016
May 30, 2017
Introduction

 
Based on our reasonable country of origin inquiry, Nokia has reason to believe that certain of the Conflict Minerals1 necessary to the functionality or production of our products may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) and may not have come from recycled or scrap sources. Accordingly, Nokia undertook due diligence measures on the source and chain of custody of these Conflict Minerals. In the design of our due diligence processes we have conformed to the internationally recognized due diligence framework provided by OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (OECD 2016) (the “OECD Due Diligence Guidance”). The details of this alignment of our conflict minerals due diligence process with the OECD Due Diligence Guidance are provided in Table 1 below.

Table 1. OECD Due Diligence Guidance & related Nokia Due Diligence actions

OECD Due Diligence Guidance
Nokia Due Diligence Action
STEP 1. Establish strong company management systems
 
Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. This policy should incorporate the standards against which due diligence is to be conducted, consistent with the standards set forth in the model supply chain policy in Annex II.
 
Nokia has a policy which describes its respective commitment to conflict-free sourcing globally, including responsible and conflict-free sourcing through legitimate trade from conflict-affected and high risk areas and measures taken to reach that goal (referred to herein as the “Nokia Conflict Minerals Policy”). It also sets out a commitment to identify, assess, mitigate, and respond to risks.
 
Nokia Conflict Minerals Policy has been communicated to suppliers when first released and thereafter in conjunction with the annual supply chain conflict minerals inquiry.
 
The Nokia Conflict Minerals Policy was last updated in April 2016 and is publicly available on our website:
http://company.nokia.com/en/sustainability/downloads
Structure internal management systems to support supply chain due diligence.
 
In order to support and oversee the implementation of the Policy Nokia has set up a cross-functional Conflict Minerals Working Group that includes members with necessary competence from sourcing, operations, sustainability, legal, and reporting and government relations teams.
 
The supply chain inquiry is carried out through the internal conflict-free sourcing deployment team in cooperation with a global network of sourcing managers, and the results are periodically reviewed with Sourcing and Quality leadership and Corporate Responsibility Council (cross-functional committee for sustainability governance composed of group responsibility management and senior leaders from business units).
 
 
 

1 Columbite-tantalite (coltan) (or its derivative tantalum), cassiterite (or its derivative tin), gold and wolframite (or its derivative tungsten).
 
Establish a system of controls and transparency over the mineral supply chain. This includes a chain of custody or a traceability system or the identification of upstream actors in the supply chain. This may be implemented through participation in industry-driven programs.
Nokia’s system of controls and transparency is a combination of internal activities, work with direct suppliers and reliance on joint industry programs such as the Conflict-Free Sourcing Initiative (the “CFSI”). As a CFSI member company, Nokia is familiar with the rigor and development of the audit protocol that led to the CFSI Conflict-Free Smelter audit program in accordance with an internationally accepted standard: OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 2nd Edition. Furthermore, the mutual recognition between the CFSI Conflict-Free Smelter Program audit and the Responsible Jewellery Council’s Chain of Custody certification and London Bullion Market Association’s Responsible Gold Programme establish these programs as internationally accepted industry standards.
 
Nokia starts its reasonable country of origin inquiry by a scoping of its suppliers, for which the product data management system and spend data is used to determine which of the suppliers are relevant for the conflict minerals supply chain inquiry.
 
In order to identify the smelters and refiners in our supply chain and country of origin data, Nokia conducts a supply chain survey using the CFSI conflict minerals reporting template and reviews gathered information against that provided by CFSI and its Conflict Free Smelter Program (“CFSP”).
 
CFSI publishes a conflict-free smelter list, which is composed of mineral processing facilities that have been reviewed by an independent third-party audit to assess whether the facility employs policies, practices, and procedures to provide assurance that the material sourced is DRC conflict-free. CFSI also provides country of origin data for members, which has been aggregated due to confidential business information concerns (which conforms to the OECD Guidance specified in Step 5). This is reasonable because the country of the material’s origin is thoroughly examined in the audit process, even if the origin’s more specific location is not published. Therefore, reliance on the aggregated country list constitutes a reasonable inquiry into the material’s country of origin. The data on which we relied for certain statements in this conflict minerals report was obtained through our membership in the CFSI.
Strengthen company engagement with suppliers. A conflict minerals policy should be incorporated into contracts and/or agreements with suppliers. Where possible, assist suppliers in building capacities with a view to improving due diligence performance.
Nokia’s approach is to establish long-term relationships with suppliers, seek sustainable solutions, and work with suppliers to drive improvements. Nokia has incorporated the principles outlined in the Policy into Nokia Supplier Requirements. These requirements are an appendix to standard supplier agreements. Nokia reserves the right to assess its suppliers against its supplier requirements.
 
Nokia has provided support for suppliers in the form of detailed feedback on their conflict minerals reporting template, and corrective action plans were agreed as necessary. Nokia also encouraged suppliers to participate in and support multi stakeholder forums and conflict-free sourcing initiatives. Nokia has also conducted several dedicated information sharing webinar sessions with suppliers to further explain our conflict minerals requirements.
 
Establish a company-level, or industry-wide, grievance mechanism as an early-warning risk-awareness system.
Concerns and violations of the Policy can be reported to Nokia through our official grievance channels:
Email:  ethics@nokia.com
Online: https://nokiaethics.alertline.com
Phone: https://nokiaethics.alertline.com/clientInfo/7782/phone.pdf
 
Suppliers and other external parties are encouraged to contact their regular sourcing channel or Conflict-Free Sourcing team email (conflict_free_sourcing.team@nokia.com) if they wish to seek guidance on the application of the Policy approach, or if they wish to report suspected abuse. They, and other external stakeholders, may also report problems or concerns to the Nokia ethics alert line.
 
 
                 
STEP 2. Identify and assess risk in the supply chain
Identify and assess risks in their supply chain as recommended in the Supplements.
As a downstream company Nokia is many supply chain tiers away from mining activities and has no direct business relationship with mining activities or metal processing facilities. Therefore in order to conduct its reasonable country of origin inquiry, Nokia used a combination of actions both individually with direct suppliers, as well as multilaterally with industry peers and other stakeholders.
 
With direct suppliers, the primary means for conducting the reasonable country of origin inquiry was through a supply chain survey using the standard industry conflict minerals reporting template (provided by CFSI), with the aim of assessing the direct suppliers’ due diligence activities and identifying processing facilities and countries of mineral origin. Nokia assessed risks by reviewing supplier templates to understand their due diligence activities and identified processing facilities and countries of origin, and whether the minerals originated from recycled or scrap sources. In order to improve data quality and completeness Nokia has conducted several rounds of surveys with suppliers, provided feedback on supplier templates and agreed on corrective actions if necessary. Reminders were sent to non-responsive suppliers and an escalation process was enacted when there was slow progress on supplier side on improvements.
 
Nokia continued the risk assessment by comparing smelter data provided by suppliers to information provided by the CFSP and online research in order to verify whether the smelters and refiners have been validated as conflict-free or not and to identify the countries of origin of the minerals.
              
STEP 3. Design and implement a strategy to respond to identified risks
Report findings of the supply chain risk assessment to the designated senior management of the company.
In accordance with the Policy the results of the annual supply chain inquiry and risks identified throughout the year are reported to Nokia’s Head of Global Operations Quality, Product Procurement Leadership and Corporate Responsibility Council.
Devise and adopt a risk management plan
To minimize the risk of tin, tantalum, tungsten or gold present in our products contributing to conflict in the Covered Countries, we seek to conduct a reasonable country of origin inquiry on a regular basis, check and increase the number of validated smelters and refiners in our supply chain, approach smelters directly and consider other publicly available information about smelting operation and country of origin.
 
As part of risk management with our direct suppliers, we provide them feedback on the quality of their conflict minerals due diligence information and ask clarifying questions and demand corrective actions where necessary. We have set up informational calls with selected suppliers to help build their capacity, and we encourage our suppliers to participate in industry activities in order to learn and contribute.
 
          
 
 
 
We have also conducted a pilot audit program for the suppliers in China on their due diligence process.
               
When suppliers have identified in their conflict minerals survey that some of the minerals originate from the Covered Countries, we have performed additional due diligence to find out as much as reasonably possible about the origins of the metals. This involves asking suppliers to identify the smelter or refiner that processed the material and checking whether it has been validated as conflict-free. We also liaise directly with smelters that have not yet been validated as conflict-free in order to request mineral origin information.
             
As part of risk management we aim to increase the portion of validated conflict-free smelters and refiners in our supply chain, with the aim of ultimately sourcing only from validated processing facilities.
                   
Implement the risk management plan, monitor and track performance of risk mitigation efforts and report back to designated senior management. This may be done in cooperation and/or consultation with local and central government authorities, upstream companies, international or civil society organisations and affected third-parties where the risk management plan is implemented and monitored in conflict-affected and high-risk areas.
Risk management plans, monitoring and performance tracking is done in close collaboration with sourcing and followed up by the cross-functional conflict minerals working group that oversees the implementation of the Policy. The results are reported to Sourcing category leaders and also back to Head of Global Operations Quality and Corporate Responsibility Council.
 
 
Where risk incidents involve direct suppliers, we carry out risk management planning, monitoring and performance tracking through the sourcing managers’ network. In cases where risk incidents do not result in corrective actions taken to our satisfaction, it can ultimately result in termination of the business relationship.
 
In cases where our regular annual supply chain inquiry indicates that a given supplier is sourcing materials from the Covered Countries, we undertake additional risk management activities, such as checking the reported mine of origin against industry data and public sources of information, and follow-up of the status periodically.
 
Undertake additional fact and risk assessments for risks requiring mitigation, or after a change of circumstances.
As necessary through the same steps as above.
 
STEP 4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
Companies at identified points (as indicated in the Supplements) in the supply chain should have their due diligence practices audited by independent third parties. Such audits may be verified by an independent institutionalized mechanism.
As the origin of Conflict Minerals cannot be determined after the ores have been smelted or refined, smelters and refiners are in the best position to determine the country of origin. Thus the most important point in the supply chain for a downstream company to have third-party conflict-free validation is the smelter or refiner level. For that purpose we make use of the cross-industry conflict-free smelter listing of the CFSP. The CFSP has agreed on mutual cross-recognition of gold refiner audits with London Bullion Market Association (“LBMA”) and Responsible Jewellery Council (“RJC”), and therefore refineries validated by those organizations are also considered to be conflict-free. Refineries validated by LBMA and RJC are reflected in the CFSI list of validated smelters and refiners. http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/
        
         
          
 
           
We compare the aggregated smelter and refiner list of our supply chain against the validated smelter and refiner lists provided by the CFSP. We also take steps to encourage the non-validated smelters to enter into the program and start the process of validation through our direct outreach to smelters as well as through the respective working group at CFSI.
              
STEP 5. Report on supply chain due diligence 
Companies should publicly report on their supply chain due diligence policies and practices and may do so by expanding the scope of their sustainability, corporate social responsibility or annual reports to cover additional information on mineral supply chain due diligence.
Nokia reports publicly on its due diligence policies and practices in its Form SD and Conflict Minerals Report filed with the US Securities and Exchange Commission, its annual sustainability report (Nokia People and Planet report), and on its company website.
 

As a downstream company, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals. Our due diligence process is based on the necessity of seeking data from our direct suppliers and the direct suppliers seeking data within their supply chain to identify the original sources of the Conflict Minerals. We also rely to a large extent on information provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information.
 

 
RESULTS OF THE NOKIA SUPPLY CHAIN INQUIRY FOR 2016
In order to conduct the reasonable country of origin inquiry, Nokia started by determining the suppliers to be in scope for the supply chain inquiry. The analysis of the material content information gathered for all products led us to conclude that small quantities of the four metals in question are present in practically all parts and components used to manufacture products in our business (such as integrated circuits, connectors, resistors, hardware assembly components, RF MW circuits and capacitors).

The product data management system was used to determine which of Nokia’s suppliers are relevant for the conflict minerals supply chain inquiry. Suppliers being phased-out and products sourced from third parties and subsequently resold by Nokia without influence over the manufacturing or design of such products were not in scope. Further, Nokia applied certain threshold levels of the respective supplier spend to exclude from the scope some of the suppliers accounting for relatively insignificant procurement spend by Nokia.
 
The number of suppliers in the original scope for Nokia was 1756 Of these, 318 suppliers were above the supplier spend threshold applied by Nokia, in the aggregate representing 84% of supplier spend in original scope. Nokia approached these suppliers with the conflict minerals inquiry. The remaining suppliers were under threshold level or were in the phase-out process. The response rate for the suppliers surveyed was 98%. 22 of the suppliers surveyed did not supply materials containing Conflict Minerals.
 
 

 
 
 
 

 

 
Based on our due diligence efforts we found on a supplier level that, of the suppliers in scope:
 
·
98% of suppliers have adopted a conflict minerals policy (96% in 2015), 81% public and 19% not public.
·
Suppliers tracing all smelters (per mineral): tantalum 63%, tin 73%, tungsten 63%, gold 70%.
·
Suppliers with conflict-free status (per mineral, including conflict-free status of respective reported smelters): tantalum 62%, tin 55%, tungsten 46%, gold 56%.
 
 
 
 
 

 

 
Figure 1: Supplier smelter identification completion and Conflict-Free Status
 


Suppliers sourcing from the Covered Countries: 275/291=95% (2015: 180 suppliers)
                 
In total, we have identified 312 of the smelters:
·
79% of smelters have been validated by CFSP or mutually recognized programs (out of known smelters) (70% in 20152): gold 67%, tantalum 100%, tin 80%, tungsten 89%.
·
84% of smelters have been validated by CFSP or mutually recognized programs or are active in the validation process (out of known smelters) (83% in 2015): gold 74%, tantalum 100%, tin 88%, tungsten 89%.

 
 
Compliant
Active
No participation
Total
Tantalum
44
0
0
44
100%
0%
0%
Tin
68
7
10
85
80%
8%
12%
Gold
93
9
36
138
67%
7%
26%
Tungsten
40
0
5
45
89%
0%
11%
Total
245
16
51
312
79%
5%
16%
100%

 

2 The number of identified smelters increased from 306 in 2015 to 312 in 2016.
 
 
      
Figure 2. Conflict-Free validation status of the 312 identified smelters
    
  
In support of supply chain transparency, we disclose in the tables below: the processing facilities we have identified through our due diligence process as having processed conflict minerals contained in the products manufactured by Nokia and in products for which Nokia has contracted with third parties to manufacture. The processing facilities (including smelters and refiners) are listed on an aggregated basis per metal and classified within three categories – “validated”, “active”, and “no public participation in validation program”. Smelter validation status is based on Conflict-Free Sourcing Initiative data as of February 21, 2017.
   
Conflict-Free Smelter Program (CFSP) Compliant Processing Facilities
The smelters and refiners identified as part of our reasonable country of origin inquiry and validated as compliant according to CFSP protocol:
  

Metal
Standard Smelter Name
Smelter ID
Smelter Country
Gold
Advanced Chemical Company
CID000015
UNITED STATES
Gold
Aida Chemical Industries Co., Ltd.
CID000019
JAPAN
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
GERMANY
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
CID000041
UZBEKISTAN
Gold
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
BRAZIL
Gold
Argor-Heraeus S.A.
CID000077
SWITZERLAND
Gold
Asahi Pretec Corp.
CID000082
JAPAN
Gold
Asaka Riken Co., Ltd.
CID000090
JAPAN
Gold
Aurubis AG
CID000113
GERMANY
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
CID000128
PHILIPPINES
Gold
Boliden AB
CID000157
SWEDEN
Gold
C. Hafner GmbH + Co. KG
CID000176
GERMANY
Gold
CCR Refinery - Glencore Canada Corporation
CID000185
CANADA
Gold
Chimet S.p.A.
CID000233
ITALY
         
Gold
Daejin Indus Co., Ltd.
CID000328
KOREA, REPUBLIC OF
Gold
DSC (Do Sung Corporation)
CID000359
KOREA, REPUBLIC OF
Gold
DODUCO GmbH
CID000362
GERMANY
Gold
Dowa
CID000401
JAPAN
Gold
Eco-System Recycling Co., Ltd.
CID000425
JAPAN
Gold
OJSC Novosibirsk Refinery
CID000493
RUSSIAN FEDERATION
Gold
Heimerle + Meule GmbH
CID000694
GERMANY
Gold
Heraeus Metals Hong Kong Ltd.
CID000707
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
CID000711
GERMANY
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CID000801
KOREA, REPUBLIC OF
Gold
Ishifuku Metal Industry Co., Ltd.
CID000807
JAPAN
Gold
Istanbul Gold Refinery
CID000814
TURKEY
Gold
Japan Mint
CID000823
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CID000855
CHINA
Gold
Asahi Refining USA Inc.
CID000920
UNITED STATES
Gold
Asahi Refining Canada Ltd.
CID000924
CANADA
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
RUSSIAN FEDERATION
Gold
JSC Uralelectromed
CID000929
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
CID000937
JAPAN
Gold
Kazzinc
CID000957
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
CID000969
UNITED STATES
Gold
Kojima Chemicals Co., Ltd.
CID000981
JAPAN
Gold
Kyrgyzaltyn JSC
CID001029
KYRGYZSTAN
Gold
LS-NIKKO Copper Inc.
CID001078
KOREA, REPUBLIC OF
Gold
Materion
CID001113
UNITED STATES
Gold
Matsuda Sangyo Co., Ltd.
CID001119
JAPAN
Gold
Metalor Technologies (Suzhou) Ltd.
CID001147
CHINA
Gold
Metalor Technologies (Hong Kong) Ltd.
CID001149
CHINA
Gold
Metalor Technologies (Singapore) Pte., Ltd.
CID001152
SINGAPORE
Gold
Metalor Technologies S.A.
CID001153
SWITZERLAND
Gold
Metalor USA Refining Corporation
CID001157
UNITED STATES
Gold
Metalúrgica Met-Mex Peñoles S.A. De C.V.
CID001161
MEXICO
Gold
Mitsubishi Materials Corporation
CID001188
JAPAN
Gold
Mitsui Mining and Smelting Co., Ltd.
CID001193
JAPAN
Gold
Moscow Special Alloys Processing Plant
CID001204
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.Ş.
CID001220
TURKEY
Gold
Nihon Material Co., Ltd.
CID001259
JAPAN
Gold
Elemetal Refining, LLC
CID001322
UNITED STATES
Gold
Ohura Precious Metal Industry Co., Ltd.
CID001325
JAPAN
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)
CID001326
RUSSIAN FEDERATION
    
Gold
PAMP S.A.
CID001352
SWITZERLAND
Gold
Prioksky Plant of Non-Ferrous Metals
CID001386
RUSSIAN FEDERATION
Gold
PT Aneka Tambang (Persero) Tbk
CID001397
INDONESIA
Gold
PX Précinox S.A.
CID001498
SWITZERLAND
Gold
Rand Refinery (Pty) Ltd.
CID001512
SOUTH AFRICA
Gold
Royal Canadian Mint
CID001534
CANADA
Gold
Samduck Precious Metals
CID001555
KOREA, REPUBLIC OF
Gold
Schone Edelmetaal B.V.
CID001573
NETHERLANDS
Gold
SEMPSA Joyería Platería S.A.
CID001585
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
CHINA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CID001736
CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
CID001756
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
CID001761
TAIWAN
Gold
Sumitomo Metal Mining Co., Ltd.
CID001798
JAPAN
Gold
Tanaka Kikinzoku Kogyo K.K.
CID001875
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
CHINA
Gold
Tokuriki Honten Co., Ltd.
CID001938
JAPAN
Gold
Torecom
CID001955
KOREA, REPUBLIC OF
Gold
Umicore Brasil Ltda.
CID001977
BRAZIL
Gold
Umicore S.A. Business Unit Precious Metals Refining
CID001980
BELGIUM
Gold
United Precious Metal Refining, Inc.
CID001993
UNITED STATES
Gold
Valcambi S.A.
CID002003
SWITZERLAND
Gold
Western Australian Mint trading as The Perth Mint
CID002030
AUSTRALIA
Gold
Yamamoto Precious Metal Co., Ltd.
CID002100
JAPAN
Gold
Yokohama Metal Co., Ltd.
CID002129
JAPAN
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
CHINA
Gold
Zijin Mining Group Co., Ltd. Gold Refinery
CID002243
CHINA
Gold
Umicore Precious Metals Thailand
CID002314
THAILAND
Gold
MMTC-PAMP India Pvt., Ltd.
CID002509
INDIA
Gold
Republic Metals Corporation
CID002510
UNITED STATES
Gold
Singway Technology Co., Ltd.
CID002516
TAIWAN
Gold
Al Etihad Gold LLC
CID002560
UNITED ARAB EMIRATES
Gold
Emirates Gold DMCC
CID002561
UNITED ARAB EMIRATES
Gold
T.C.A S.p.A
CID002580
ITALY
Gold
Korea Zinc Co., Ltd.
CID002605
KOREA, REPUBLIC OF
Gold
SAXONIA Edelmetalle GmbH
CID002777
GERMANY
Gold
WIELAND Edelmetalle GmbH
CID002778
GERMANY
Gold
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH
CID002779
AUSTRIA
Gold
AU Traders and Refiners
CID002850
SOUTH AFRICA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CID000211
CHINA
Tantalum
Conghua Tantalum and Niobium Smeltry
CID000291
CHINA
Tantalum
Duoluoshan
CID000410
CHINA
      
Tantalum
Exotech Inc.
CID000456
UNITED STATES
Tantalum
F&X Electro-Materials Ltd.
CID000460
CHINA
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CID000616
CHINA
Tantalum
Hi-Temp Specialty Metals, Inc.
CID000731
UNITED STATES
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CID000914
CHINA
Tantalum
Jiujiang Nonferrous Metals Smelting Company Limited
CID000917
CHINA
Tantalum
King-Tan Tantalum Industry Ltd.
CID000973
CHINA
Tantalum
LSM Brasil S.A.
CID001076
BRAZIL
Tantalum
Metallurgical Products India Pvt., Ltd.
CID001163
INDIA
Tantalum
Mineração Taboca S.A.
CID001175
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
CID001192
JAPAN
Tantalum
NPM Silmet AS
CID001200
ESTONIA
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
CHINA
Tantalum
QuantumClean
CID001508
UNITED STATES
Tantalum
Yanling Jincheng Tantalum Co., Ltd.
CID001522
CHINA
Tantalum
Solikamsk Magnesium Works OAO
CID001769
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
CID001869
JAPAN
Tantalum
Telex Metals
CID001891
UNITED STATES
Tantalum
Ulba Metallurgical Plant JSC
CID001969
KAZAKHSTAN
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.
CID002232
CHINA
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.
CID002307
CHINA
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CID002492
CHINA
Tantalum
D Block Metals, LLC
CID002504
UNITED STATES
Tantalum
FIR Metals & Resource Ltd.
CID002505
CHINA
Tantalum
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CID002506
CHINA
Tantalum
XinXing HaoRong Electronic Material Co., Ltd.
CID002508
CHINA
Tantalum
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CID002512
CHINA
Tantalum
KEMET Blue Metals
CID002539
MEXICO
Tantalum
H.C. Starck Co., Ltd.
CID002544
THAILAND
Tantalum
H.C. Starck Tantalum and Niobium GmbH
CID002545
GERMANY
Tantalum
H.C. Starck Hermsdorf GmbH
CID002547
GERMANY
Tantalum
H.C. Starck Inc.
CID002548
UNITED STATES
Tantalum
H.C. Starck Ltd.
CID002549
JAPAN
Tantalum
H.C. Starck Smelting GmbH & Co. KG
CID002550
GERMANY
Tantalum
Global Advanced Metals Boyertown
CID002557
UNITED STATES
Tantalum
Global Advanced Metals Aizu
CID002558
JAPAN
Tantalum
KEMET Blue Powder
CID002568
UNITED STATES
Tantalum
Tranzact, Inc.
CID002571
UNITED STATES
Tantalum
Resind Indústria e Comércio Ltda.
CID002707
BRAZIL
Tantalum
Jiangxi Tuohong New Raw Material
CID002842
CHINA
Tantalum
Power Resources Ltd.
CID002847
MACEDONIA
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CID000228
CHINA
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CID000244
CHINA
Tin
Alpha
CID000292
UNITED STATES
Tin
Cooperativa Metalurgica de Rondônia Ltda.
CID000295
BRAZIL
Tin
CV Gita Pesona
CID000306
INDONESIA
           
Tin
PT Aries Kencana Sejahtera
CID000309
INDONESIA
Tin
CV Serumpun Sebalai
CID000313
INDONESIA
Tin
CV United Smelting
CID000315
INDONESIA
Tin
Dowa
CID000402
JAPAN
Tin
EM Vinto
CID000438
BOLIVIA
Tin
Fenix Metals
CID000468
POLAND
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
CHINA
Tin
China Tin Group Co., Ltd.
CID001070
CHINA
Tin
Malaysia Smelting Corporation (MSC)
CID001105
MALAYSIA
Tin
Metallic Resources, Inc.
CID001142
UNITED STATES
Tin
Mineração Taboca S.A.
CID001173
BRAZIL
Tin
Minsur
CID001182
PERU
Tin
Mitsubishi Materials Corporation
CID001191
JAPAN
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
CID001314
THAILAND
Tin
Operaciones Metalurgical S.A.
CID001337
BOLIVIA
Tin
PT Artha Cipta Langgeng
CID001399
INDONESIA
Tin
PT Babel Inti Perkasa
CID001402
INDONESIA
Tin
PT Bangka Tin Industry
CID001419
INDONESIA
Tin
PT Belitung Industri Sejahtera
CID001421
INDONESIA
Tin
PT Bukit Timah
CID001428
INDONESIA
Tin
PT DS Jaya Abadi
CID001434
INDONESIA
Tin
PT Eunindo Usaha Mandiri
CID001438
INDONESIA
Tin
PT Karimun Mining
CID001448
INDONESIA
Tin
PT Mitra Stania Prima
CID001453
INDONESIA
Tin
PT Panca Mega Persada
CID001457
INDONESIA
Tin
PT Prima Timah Utama
CID001458
INDONESIA
Tin
PT Refined Bangka Tin
CID001460
INDONESIA
Tin
PT Sariwiguna Binasentosa
CID001463
INDONESIA
Tin
PT Stanindo Inti Perkasa
CID001468
INDONESIA
Tin
PT Sumber Jaya Indah
CID001471
INDONESIA
Tin
PT Timah (Persero) Tbk Kundur
CID001477
INDONESIA
Tin
PT Timah (Persero) Tbk Mentok
CID001482
INDONESIA
Tin
PT Tinindo Inter Nusa
CID001490
INDONESIA
Tin
PT Tommy Utama
CID001493
INDONESIA
Tin
Rui Da Hung
CID001539
TAIWAN
Tin
Soft Metais Ltda.
CID001758
BRAZIL
Tin
Thaisarco
CID001898
THAILAND
Tin
VQB Mineral and Trading Group JSC
CID002015
VIET NAM
Tin
White Solder Metalurgia e Mineração Ltda.
CID002036
BRAZIL
Tin
Yunnan Tin Company Limited
CID002180
CHINA
Tin
CV Venus Inti Perkasa
CID002455
INDONESIA
Tin
Magnu’s Minerais Metais e Ligas Ltda.
CID002468
BRAZIL
Tin
PT Wahana Perkit Jaya
CID002479
INDONESIA
Tin
Melt Metais e Ligas S.A.
CID002500
BRAZIL
Tin
PT ATD Makmur Mandiri Jaya
CID002503
INDONESIA
Tin
O.M. Manufacturing Philippines, Inc.
CID002517
PHILIPPINES
         
Tin
PT Inti Stania Prima
CID002530
INDONESIA
Tin
CV Ayi Jaya
CID002570
INDONESIA
Tin
CV Dua Sekawan
CID002592
INDONESIA
Tin
CV Tiga Sekawan
CID002593
INDONESIA
Tin
PT Cipta Persada Mulia
CID002696
INDONESIA
Tin
Resind Indústria e Comércio Ltda.
CID002706
BRAZIL
Tin
PT O.M. Indonesia
CID002757
INDONESIA
Tin
Metallo-Chimique N.V.
CID002773
BELGIUM
Tin
Elmet S.L.U.
CID002774
SPAIN
Tin
PT Bangka Prima Tin
CID002776
INDONESIA
Tin
PT Sukses Inti Makmur
CID002816
INDONESIA
Tin
PT Kijang Jaya Mandiri
CID002829
INDONESIA
Tin
PT Menara Cipta Mulia
CID002835
INDONESIA
Tin
HuiChang Hill Tin Industry Co., Ltd.
CID002844
CHINA
Tin
Gejiu Fengming Metallurgy Chemical Plant
CID002848
CHINA
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CID002849
CHINA
Tin
Gejiu Jinye Mineral Company
CID002859
CHINA
Tungsten
A.L.M.T. TUNGSTEN Corp.
CID000004
JAPAN
Tungsten
Kennametal Huntsville
CID000105
UNITED STATES
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CID000258
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CID000499
CHINA
Tungsten
Global Tungsten & Powders Corp.
CID000568
UNITED STATES
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CID000766
CHINA
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CID000769
CHINA
Tungsten
Japan New Metals Co., Ltd.
CID000825
JAPAN
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CID000875
CHINA
Tungsten
Kennametal Fallon
CID000966
UNITED STATES
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
VIET NAM
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
CID002011
VIET NAM
Tungsten
Wolfram Bergbau und Hütten AG
CID002044
AUSTRIA
Tungsten
Xiamen Tungsten Co., Ltd.
CID002082
CHINA
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CID002095
CHINA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CID002315
CHINA
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CID002316
CHINA
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CID002317
CHINA
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CID002318
CHINA
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CID002319
CHINA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
CHINA
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CID002321
CHINA
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
CHINA
Tungsten
Asia Tungsten Products Vietnam Ltd.
CID002502
VIET NAM
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CID002513
CHINA
Tungsten
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd.
CID002535
CHINA
Tungsten
H.C. Starck Tungsten GmbH
CID002541
GERMANY
Tungsten
H.C. Starck Smelting GmbH & Co. KG
CID002542
GERMANY
        
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
CID002543
VIET NAM
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CID002551
CHINA
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CID002579
CHINA
Tungsten
Niagara Refining LLC
CID002589
UNITED STATES
Tungsten
Hydrometallurg, JSC
CID002649
RUSSIAN FEDERATION
Tungsten
Unecha Refractory metals plant
CID002724
RUSSIAN FEDERATION
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CID002815
CHINA
Tungsten
Philippine Chuangxin Industrial Co., Inc.
CID002827
PHILIPPINES
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CID002830
CHINA
Tungsten
Woltech Korea Co., Ltd.
CID002843
KOREA, REPUBLIC OF
Tungsten
Moliren Ltd
CID002845
RUSSIAN FEDERATION

CFSP Participating Processing Facilities

Smelters and refiners identified as part of our reasonable country of origin inquiry and that have agreed to participate in the CFSP audit:

Metal
Standard Smelter Name
Smelter ID
Smelter Country
Gold
Cendres + Métaux S.A.
CID000189
SWITZERLAND
Gold
HeeSung Metal Ltd.
CID000689
KOREA, REPUBLIC OF
Gold
Navoi Mining and Metallurgical Combinat
CID001236
UZBEKISTAN
Gold
Geib Refining Corporation
CID002459
UNITED STATES
Gold
KGHM Polska Miedź Spółka Akcyjna
CID002511
POLAND
Gold
Tony Goetz NV
CID002587
BELGIUM
Gold
Abington Reldan Metals, LLC
CID002708
UNITED STATES OF AMERICA
Gold
Modeltech Sdn Bhd
CID002857
MALAYSIA
Gold
Bangalore Refinery
CID002863
INDIA
Tin
Gejiu Kai Meng Industry and Trade LLC
CID000942
CHINA
Tin
Nankang Nanshan Tin Manufactory Co., Ltd.
CID001231
CHINA
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CID001908
CHINA
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
CHINA
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
CID002572
VIET NAM
Tin
An Vinh Joint Stock Mineral Processing Company
CID002703
VIET NAM
Tin
Modeltech Sdn Bhd
CID002858
MALAYSIA


Processing facilities with no public participation in validation program
Together with our suppliers and industry cooperation, we will continue requesting participation in CFSP or an equivalent program:
Metal
Standard Smelter Name
Smelter ID
Smelter Country
Gold
Chugai Mining
CID000264
JAPAN
Gold
HwaSeong CJ CO., LTD.
CID000778
KOREA, REPUBLIC OF
 
           
Gold
Kazakhmys Smelting LLC
CID000956
KAZAKHSTAN
Gold
Samwon Metals Corp.
CID001562
KOREA, REPUBLIC OF
Gold
SAFINA A.S.
CID002290
CZECH REPUBLIC
Gold
Remondis Argentia B.V.
CID002582
NETHERLANDS
Gold
TOO Tau-Ken-Altyn
CID002615
KAZAKHSTAN
Gold
SAAMP
CID002761
FRANCE
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
CID000103
TURKEY
Gold
Caridad
CID000180
MEXICO
Gold
Yunnan Copper Industry Co., Ltd.
CID000197
CHINA
Gold
Daye Non-Ferrous Metals Mining Ltd.
CID000343
CHINA
Gold
Gansu Seemine Material Hi-Tech Co., Ltd.
CID000522
CHINA
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CID000651
CHINA
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CID000671
CHINA
Gold
Hunan Chenzhou Mining Co., Ltd.
CID000767
CHINA
Gold
L’azurde Company For Jewelry
CID001032
SAUDI ARABIA
Gold
Lingbao Gold Co., Ltd.
CID001056
CHINA
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CID001058
CHINA
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CID001093
CHINA
Gold
Penglai Penggang Gold Industry Co., Ltd.
CID001362
CHINA
Gold
Sabin Metal Corp.
CID001546
UNITED STATES
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CID001619
CHINA
Gold
So Accurate Group, Inc.
CID001754
UNITED STATES
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CID001909
CHINA
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CID001947
CHINA
Gold
Morris and Watson
CID002282
NEW ZEALAND
Gold
Guangdong Jinding Gold Limited
CID002312
CHINA
Gold
Fidelity Printers and Refiners Ltd.
CID002515
ZIMBABWE
Gold
Kaloti Precious Metals
CID002563
UNITED ARAB EMIRATES
Gold
Sudan Gold Refinery
CID002567
SUDAN
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
CID002852
INDIA
Gold
Sai Refinery
CID002853
INDIA
Gold
Universal Precious Metals Refining Zambia
CID002854
ZAMBIA
Gold
Kyshtym Copper-Electrolytic Plant ZAO
CID002865
RUSSIAN FEDERATION
Gold
Degussa Sonne / Mond Goldhandel GmbH
CID002867
GERMANY
Tin
PT Justindo
CID000307
INDONESIA
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CID000555
CHINA
Tin
Phoenix Metal Ltd.
CID002507
RWANDA
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CID000278
CHINA
Tin
Estanho de Rondônia S.A.
CID000448
BRAZIL
Tin
Huichang Jinshunda Tin Co., Ltd.
CID000760
CHINA
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
CID002573
VIET NAM
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
CID002574
VIET NAM
Tin
Super Ligas
CID002756
BRAZIL
Tin
An Thai Minerals Co., Ltd.
CID002825
VIET NAM
      
              
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CID002536
CHINA
Tungsten
Dayu Weiliang Tungsten Co., Ltd.
CID000345
CHINA
Tungsten
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd.
CID002313
CHINA
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CID002647
CHINA
Tungsten
ACL Metais Eireli
CID002833
BRAZIL
  
  
We have identified an additional 57 facilities that were reported as smelters by our suppliers but that we were not able to confirm as smelters or refiners based on industry or public sources of information, and will be reaching out to these facilities in 2017 to perform additional due diligence.
             
In order to identify countries of origin, Nokia made use of Conflict Minerals templates provided by suppliers and aggregated country of origin information of smelters provided by CFSI to its members. Based on these, the countries of origin of the Conflict Minerals in the Nokia supply chain may include:
            
The countries of origin for Gold may include: Argentina; Australia; Azerbaijan; Belgium; Benin; Bolivia; Brazil; Burkina Faso; Canada; Chile; China; Colombia; Dominica; Dominican Republic; Ecuador; Eritrea; Germany; Ghana; Guatemala; Guinea; Guyana; Honduras; Hong Kong; Indonesia; Italy; Japan; Kazakhstan; People’s Democratic Republic of Laos; Liberia; Malaysia; Mali; Mauritania; Mexico; Netherlands; Nicaragua; Panama; Papua New Guinea; Peru; Philippines; Portugal; Russian Federation; Senegal; Singapore; South Africa; Spain; Suriname; Switzerland; Taiwan; United Republic of Tanzania; Thailand; Togo; United States.
              
The countries of origin for Tantalum may include: Australia; Bolivia; Brazil; Burundi; Canada; China; Democratic Republic of the Congo (Kinshasa); Estonia; Ethiopia; France; Germany; Guinea; Guyana; India; Japan; Kazakhstan; Madagascar; Malaysia; Mozambique; Namibia; Nigeria; Russian Federation; Rwanda; Sierra Leone; Thailand; United States; Zimbabwe.
            
The countries of origin for Tin may include: Australia; Austria; Belgium; Bolivia; Brazil; Burundi; Canada; China; Colombia; Democratic Republic of the Congo (Kinshasa); Republic of Congo (Brazzaville); Ethiopia; India; Indonesia; Japan; Kazakhstan; People’s Democratic Republic of Laos; Malaysia; Mongolia; Morocco; Mozambique; Myanmar; Namibia; Nigeria; Peru; Philippines; Poland; Portugal; Russian Federation; Rwanda; Sierra Leone; Thailand; Uganda; United States; Vietnam; Zimbabwe.
              
The countries of origin for Tungsten may include: Australia; Austria; Bolivia; Brazil; Burundi; Cambodia; Canada; China; Colombia; Democratic Republic of the Congo (Kinshasa); Germany; Indonesia; Japan; Mexico; Mongolia; Nigeria; Peru; Portugal; Russian Federation; Rwanda; Spain; Thailand; United States; Uzbekistan; Vietnam.
               
Nokia supports seeking a sustainable solution to the issue of conflict minerals and aims to ensure responsible and conflict-free sourcing, thus supporting legitimate trade and positive development in the DRC and adjoining countries. Of Nokia’s suppliers, 275 had reported smelters that process conflict minerals originating in one or more of the Covered Countries. Altogether 59 smelters in the consolidated smelter list (19% of identified smelters) were confirmed to process Conflict Minerals sourcing from the Covered Countries. As part of our due diligence, we have followed up with all such suppliers to verify whether the smelters that sourced Conflict Minerals from Covered Countries are compliant smelters under the CFSP. All 59 smelters were found to be compliant. 30 of these 59 smelters (10% of identified smelters) were sourcing from the DRC. We believe this is a positive development for the countries whose livelihood depends on these efforts continuing. In addition we have identified 3 smelters for which we cannot rule out that they source from the Covered Countries, due to their geographic proximity, and we plan to take further duediligence efforts in 2017 with regard to those smelters.
         
             
Progress on Commitments made in 2016 Conflict Minerals Report

Target for 2016
Progress in 2016
Further improving the quality and completeness of the conflict minerals due diligence data provided by our suppliers;
 
Further improvement of supplier information quality was observed during data evaluation and follow up. Quality and completeness of data was also assessed as part of onsite audits.
Engaging in further awareness raising and due diligence capability building efforts jointly in collaboration with relevant stakeholder forums and/or independently with our suppliers;
 
A number of webinars were conducted to suppliers with high or medium risk; Direct feedback was provided to all of the suppliers in most of the cases in several rounds. Suppliers were also encouraged to participate in industry forums and collaboration.
Actively engaging with our supply chain to get more smelters validated as conflict-free through the third-party validation mechanisms available, with the aim of increasing the number of smelters on the list of CFSP compliant smelters;
 
Engagement was two-fold: on the supplier level directly with smelters and through the respective working group of Conflict-Free Sourcing Initiative. As a result 79% of smelters were validated as conflict-free against 70% last year.
Requesting suppliers to complete smelter mapping, source conflict-free tantalum only, and source minimum 90% of other metals from conflict-free smelters only;
In 2016 we required all of our suppliers to source conflict-free tantalum only. In 2016, 100% of the smelters from which our suppliers sourced tantalum were conflict-free. On other metals target was not achieved, tungsten (89%), gold (67%), tin (80%). Smelter mapping by our suppliers was completed at 73% on average. This is a continuous challenge, since most of the suppliers are also several tiers away from smelters and achieving full compliance from several tiers remains challenging.
Validating the due diligence efforts of our suppliers as part of overall supplier assessments
Corporate Responsibility audits of our product suppliers included a checklist on conflict-free sourcing. In 2016 we also conducted 6 third-party pilot audits focused on conflict-free sourcing.









 
NOKIA COMMITMENTS FOR 2017:
 
In order to mitigate the risk that the conflict minerals contained in, and necessary to the functionality or production of, Nokia’s products benefit armed groups, and to improve our conflict minerals due diligence efforts further in the coming year, we plan to concentrate on the following activities in 2017:
 
·
further improving the quality and completeness of the conflict minerals due diligence data provided by our suppliers;
 
·
engaging in further awareness raising and due diligence capability building efforts jointly in collaboration with relevant stakeholder forums and/or independently with our suppliers;
 
·
actively engaging with our supply chain to get more smelters validated as conflict-free through the third-party validation mechanisms available, with the aim of increasing the number of smelters on the list of CFSP compliant smelters;

·
requesting suppliers to complete smelter mapping, source conflict-free tantalum only, and source minimum 90% of other metals from conflict-free smelters only; and
 
·
validating the due diligence efforts of our suppliers as part of overall supplier assessments.
 

Statements relating to due diligence process improvement, as well as similar strategy and compliance process statements made in this conflict minerals report are forward-looking in nature and are based on Nokia’s management’s current expectations or beliefs. These forward-looking statements are not a guarantee of performance and are subject to a number of uncertainties and other factors (such as whether industry organizations and initiatives such as CSFI remain effective as a source of external support to us in the conflict minerals compliance process), which may be outside of Nokia’s control and which could cause actual events to differ materially from those expressed or implied by the statements made herein.

Unless otherwise expressly stated herein, any documents, third party materials or references to websites are not incorporated by reference in, or considered to be a part of, this conflict minerals report.