EX-1.01 2 ex1-01.htm EXHIBIT 1.01 - CONFLICT MINERALS REPORT



NOKIA CONFLICT MINERALS REPORT FOR 2018
May 30, 2019
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 of OECD Due Diligence Guidance.
 
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 is reviewed regularly and is publicly available on our website:
http://company.nokia.com/en/sustainability/downloads
 


1 Columbite-tantalite (coltan) (or its derivative tantalum), cassiterite (or its derivative tin), gold and wolframite (or its derivative tungsten).

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 (Supply Quality Monthly Business Reviews and Dedicated Quality Reviews) and Corporate Responsibility Council (cross-functional committee for sustainability governance composed of group responsibility management and senior leaders from business units).
 
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 Responsible Minerals Initiative (the “RMI”) (formerly known as the Conflict-Free Sourcing Initiative (“CFSI”). As a RMI member company, Nokia is familiar with the rigor and development of the audit protocol that led to the RMI Responsible Minerals Assurance Process 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 RMI Responsible Minerals Assurance Process 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 RMI conflict minerals reporting template and reviews gathered information against that provided by RMI and its Responsible Minerals Assurance Process (“RMAP”).
 
RMI 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. RMI 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 rely for certain statements in this conflict minerals report is obtained through our membership in the RMI.
 
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 which are part of Quality appendix to standard supplier agreements. Nokia reserves the right to assess its suppliers against its supplier requirements.
 
Nokia provides 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 encourages 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.

At the industry level, grievances can also be reported to RMI’s Grievance Channel at: http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/. Nokia receives a periodic overview of the grievance received by RMI and considers this under risk management.
 
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 and therefore, in order to conduct its reasonable country of origin inquiry, Nokia uses 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 survey through a supply chain using the standard industry conflict minerals reporting template (provided by RMI), with the aim of assessing the direct suppliers’ due diligence activities and identifying processing facilities and countries of mineral origin. Nokia assesses 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 conducts several rounds of surveys with suppliers, provides feedback on supplier templates and agrees on corrective actions if necessary. Reminders are sent to non-responsive suppliers and an escalation process is enacted when there is slow progress on supplier side on improvements and meeting Nokia targets.
 
Nokia continues the risk assessment by comparing smelter data provided by suppliers to information provided by the RMAP 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 Supply 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 also conduct an audit program for the suppliers in higher risk countries, such as 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 perform 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 our 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 organizations 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 Supply 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 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 RMAP. The RMAP 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 RMI (former 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 RMAP. 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 RMI (former 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 2018
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 a spend threshold to exclude from the scope the suppliers accounting for relatively insignificant procurement spend.
The number of suppliers in the original scope for Nokia was 1297. Of these, 268 suppliers were above the supplier spend threshold applied by Nokia, in the aggregate representing 98% 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 100%. 13 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:
●
100% of suppliers have adopted a conflict minerals policy (99% in 2017), 89% public and 11% not public.
●
Suppliers tracing all smelters (per mineral): tantalum 93%, tin 95%, tungsten 94%, gold 95%.
Suppliers with conflict-free status (per mineral, including conflict-free status of respective reported smelters): tantalum 93%, tin 88%, tungsten 84%, gold 86%.



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


Suppliers sourcing from the Covered Countries: 251/255=98% (2017: 261 suppliers)

In total, we have identified 313 of the smelters:
●
82% of smelters have been validated by RMAP or mutually recognized programs (out of known smelters) (80% in 20172): gold 70%, tantalum 100%, tin 90%, tungsten 93%.
●
84% of smelters have been validated by RMAP or mutually recognized programs or are active in the validation process (out of known smelters) (83% in 2017): gold 73%, tantalum 100%, tin 91%, tungsten 95%.
●
4% of the smelters who are currently not validated by RMAP or Active towards validation are either Recyclers, or where our due- diligence have shown there is no reason to believe they are sourcing from the Covered Countries and can be reasonably considered as conflict-free.

 
Conformant
Active
No participation
Total
Tantalum
40
0
0
40
100%
0%
0%
Tin
73
1
7
81
90%
1%
9%
Gold
105
4
41
150
70%
3%
27%
Tungsten
39
1
2
42
93%
2%
5%
Total
257
6
50
313
82%
2%
16%
100%

2 The number of identified smelters decreased from 318 in 2017 to 313 in 2018.



Figure 2. Conflict-Free validation status of the 313 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 Responsible Minerals Initiative data as of February 19, 2019.
Responsible Minerals Assurance Process (RMAP) or LBMA Conformant
Processing Facilities
The smelters and refiners identified as part of our reasonable country of origin inquiry and
validated as conformant according to RMAP protocol:

Metal
Smelter ID
Standard Smelter Name
Smelter Country
Gold
CID000015
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
CID000019
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
CID000035
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
CID000041
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
CID000058
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
CID000077
Argor-Heraeus S.A.
SWITZERLAND
Gold
CID000082
Asahi Pretec Corp.
JAPAN
Gold
CID000090
Asaka Riken Co., Ltd.
JAPAN
Gold
CID000113
Aurubis AG
GERMANY
Gold
CID000128
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
CID000157
Boliden AB
SWEDEN
Gold
CID000176
C. Hafner GmbH + Co. KG
GERMANY
Gold
CID000185
CCR Refinery - Glencore Canada Corporation
CANADA



Gold
CID000189
Cendres + Metaux S.A.
SWITZERLAND
Gold
CID000233
Chimet S.p.A.
ITALY
Gold
CID000328
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Gold
CID000359
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
CID000362
DODUCO Contacts and Refining GmbH
GERMANY
Gold
CID000401
Dowa
JAPAN
Gold
CID000425
Eco-System Recycling Co., Ltd.
JAPAN
Gold
CID000493
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
CID000689
HeeSung Metal Ltd.
KOREA, REPUBLIC OF
Gold
CID000694
Heimerle + Meule GmbH
GERMANY
Gold
CID000707
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
CID000711
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
CID000801
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
CID000807
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
CID000814
Istanbul Gold Refinery
TURKEY
Gold
CID000823
Japan Mint
JAPAN
Gold
CID000855
Jiangxi Copper Co., Ltd.
CHINA
Gold
CID000920
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
CID000924
Asahi Refining Canada Ltd.
CANADA
Gold
CID000929
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
CID000937
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
CID000957
Kazzinc
KAZAKHSTAN
Gold
CID000969
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
CID000981
Kojima Chemicals Co., Ltd.
JAPAN
Gold
CID001029
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
CID001078
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
CID001113
Materion
UNITED STATES OF AMERICA
Gold
CID001119
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
CID001147
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
CID001149
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
CID001152
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
CID001153
Metalor Technologies S.A.
SWITZERLAND
Gold
CID001157
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
CID001161
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
CID001188
Mitsubishi Materials Corporation
JAPAN
Gold
CID001193
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
CID001204
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
CID001220
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
CID001259
Nihon Material Co., Ltd.
JAPAN
Gold
CID001325
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
CID001326
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
CID001352
PAMP S.A.
SWITZERLAND
Gold
CID001386
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
CID001397
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
CID001498
PX Precinox S.A.
SWITZERLAND
Gold
CID001512
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
CID001534
Royal Canadian Mint
CANADA
Gold
CID001555
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
CID001585
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
CID001622
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
CID001736
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
CID001756
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
CID001761
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
CID001798
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
CID001875
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
CID001916
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
CID001938
Tokuriki Honten Co., Ltd.
JAPAN
Gold
CID001955
Torecom
KOREA, REPUBLIC OF
Gold
CID001977
Umicore Brasil Ltda.
BRAZIL
Gold
CID001980
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
CID001993
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
CID002003
Valcambi S.A.
SWITZERLAND
Gold
CID002030
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
CID002100
Yamakin Co., Ltd.
JAPAN



Gold
CID002129
Yokohama Metal Co., Ltd.
JAPAN
Gold
CID002224
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
CID002243
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
CID002314
Umicore Precious Metals Thailand
THAILAND
Gold
CID002459
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
CID002509
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
CID002516
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
CID002560
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
CID002561
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
CID002580
T.C.A S.p.A
ITALY
Gold
CID002582
REMONDIS PMR B.V.
NETHERLANDS
Gold
CID002605
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
CID002606
Marsam Metals
BRAZIL
Gold
CID002761
SAAMP
FRANCE
Gold
CID002762
L'Orfebre S.A.
ANDORRA
Gold
CID002763
8853 S.p.A.
ITALY
Gold
CID002765
Italpreziosi
ITALY
Gold
CID002777
SAXONIA Edelmetalle GmbH
GERMANY
Gold
CID002778
WIELAND Edelmetalle GmbH
GERMANY
Gold
CID002779
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
CID002850
AU Traders and Refiners
SOUTH AFRICA
Gold
CID002918
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
CID002919
Planta Recuperadora de Metales SpA
CHILE
Gold
CID002973
Safimet S.p.A
ITALY
Gold
CID003195
DS PRETECH Co., Ltd.
KOREA, REPUBLIC OF
Tantalum
CID000092
Asaka Riken Co., Ltd.
JAPAN
Tantalum
CID000211
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
CID000291
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Tantalum
CID000456
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
CID000460
F&X Electro-Materials Ltd.
CHINA
Tantalum
CID000616
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
CID000914
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
CID000917
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
CID001076
LSM Brasil S.A.
BRAZIL
Tantalum
CID001163
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
CID001175
Mineracao Taboca S.A.
BRAZIL
Tantalum
CID001192
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
CID001200
NPM Silmet AS
ESTONIA
Tantalum
CID001277
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
CID001508
QuantumClean
UNITED STATES OF AMERICA
Tantalum
CID001522
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
CID001769
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
CID001869
Taki Chemical Co., Ltd.
JAPAN
Tantalum
CID001891
Telex Metals
UNITED STATES OF AMERICA
Tantalum
CID001969
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
CID002492
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
CID002504
D Block Metals, LLC
UNITED STATES OF AMERICA
Tantalum
CID002505
FIR Metals & Resource Ltd.
CHINA
Tantalum
CID002506
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
CID002508
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
CID002512
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
CID002539
KEMET Blue Metals
MEXICO
Tantalum
CID002544
H.C. Starck Co., Ltd.
THAILAND
Tantalum
CID002545
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
CID002547
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
CID002548
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
CID002549
H.C. Starck Ltd.
JAPAN
Tantalum
CID002550
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
CID002557
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
CID002558
Global Advanced Metals Aizu
JAPAN
Tantalum
CID002568
KEMET Blue Powder
UNITED STATES OF AMERICA
Tantalum
CID002707
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
CID002842
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
CID002847
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF



Tantalum
CID003191
Jiujiang Janny New Material Co., Ltd.
CHINA
Tin
CID000228
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
CID000292
Alpha
UNITED STATES OF AMERICA
Tin
CID000306
CV Gita Pesona
INDONESIA
Tin
CID000309
PT Aries Kencana Sejahtera
INDONESIA
Tin
CID000313
PT Premium Tin Indonesia
INDONESIA
Tin
CID000315
CV United Smelting
INDONESIA
Tin
CID000402
Dowa
JAPAN
Tin
CID000438
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
CID000468
Fenix Metals
POLAND
Tin
CID000538
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
CID000760
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
CID000942
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
CID001070
China Tin Group Co., Ltd.
CHINA
Tin
CID001105
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
CID001142
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
CID001173
Mineracao Taboca S.A.
BRAZIL
Tin
CID001182
Minsur
PERU
Tin
CID001191
Mitsubishi Materials Corporation
JAPAN
Tin
CID001231
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
CID001314
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
CID001337
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
CID001399
PT Artha Cipta Langgeng
INDONESIA
Tin
CID001402
PT Babel Inti Perkasa
INDONESIA
Tin
CID001406
PT Babel Surya Alam Lestari
INDONESIA
Tin
CID001419
PT Bangka Tin Industry
INDONESIA
Tin
CID001421
PT Belitung Industri Sejahtera
INDONESIA
Tin
CID001428
PT Bukit Timah
INDONESIA
Tin
CID001434
PT DS Jaya Abadi
INDONESIA
Tin
CID001448
PT Karimun Mining
INDONESIA
Tin
CID001453
PT Mitra Stania Prima
INDONESIA
Tin
CID001457
PT Panca Mega Persada
INDONESIA
Tin
CID001458
PT Prima Timah Utama
INDONESIA
Tin
CID001460
PT Refined Bangka Tin
INDONESIA
Tin
CID001463
PT Sariwiguna Binasentosa
INDONESIA
Tin
CID001468
PT Stanindo Inti Perkasa
INDONESIA
Tin
CID001471
PT Sumber Jaya Indah
INDONESIA
Tin
CID001477
PT Timah Tbk Kundur
INDONESIA
Tin
CID001482
PT Timah Tbk Mentok
INDONESIA
Tin
CID001490
PT Tinindo Inter Nusa
INDONESIA
Tin
CID001493
PT Tommy Utama
INDONESIA
Tin
CID001539
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
CID001758
Soft Metais Ltda.
BRAZIL
Tin
CID001898
Thaisarco
THAILAND
Tin
CID001908
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
CID002036
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
CID002158
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
CID002180
Yunnan Tin Company Limited
CHINA
Tin
CID002455
CV Venus Inti Perkasa
INDONESIA
Tin
CID002468
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
CID002478
PT Tirus Putra Mandiri
INDONESIA
Tin
CID002500
Melt Metais e Ligas S.A.
BRAZIL
Tin
CID002503
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
CID002517
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
CID002530
PT Inti Stania Prima
INDONESIA
Tin
CID002570
CV Ayi Jaya
INDONESIA
Tin
CID002592
CV Dua Sekawan
INDONESIA
Tin
CID002593
PT Rajehan Ariq
INDONESIA
Tin
CID002706
Resind Industria e Comercio Ltda.
BRAZIL
Tin
CID002773
Metallo Belgium N.V.
BELGIUM
Tin
CID002774
Metallo Spain S.L.U.
SPAIN
Tin
CID002776
PT Bangka Prima Tin
INDONESIA



Tin
CID002816
PT Sukses Inti Makmur
INDONESIA
Tin
CID002829
PT Kijang Jaya Mandiri
INDONESIA
Tin
CID002835
PT Menara Cipta Mulia
INDONESIA
Tin
CID002844
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
CID002848
Gejiu Fengming Metallurgy Chemical Plant
CHINA
Tin
CID002849
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
Tin
CID002858
Modeltech Sdn Bhd
MALAYSIA
Tin
CID002870
PT Lautan Harmonis Sejahtera
INDONESIA
Tin
CID003116
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
CID003190
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
CID003205
PT Bangka Serumpun
INDONESIA
Tin
CID003325
Tin Technology & Refining
UNITED STATES OF AMERICA
Tungsten
CID000004
A.L.M.T. Corp.
JAPAN
Tungsten
CID000105
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
CID000218
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
CID000258
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
CID000499
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
CID000568
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
CID000766
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
CID000769
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Tungsten
CID000825
Japan New Metals Co., Ltd.
JAPAN
Tungsten
CID000875
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
CID000966
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
CID001889
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
CID002044
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
CID002082
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
CID002095
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
Tungsten
CID002315
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
CID002316
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
CID002317
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
CID002318
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
CID002319
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
CID002320
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
CID002321
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
CID002494
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
CID002513
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
CID002541
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
CID002542
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
CID002543
Masan Tungsten Chemical LLC (MTC)
VIET NAM
Tungsten
CID002551
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
CID002579
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
Tungsten
CID002589
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
CID002645
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Tungsten
CID002649
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
CID002724
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
CID002815
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
Tungsten
CID002827
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
CID002830
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
CID002833
ACL Metais Eireli
BRAZIL
Tungsten
CID002843
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
CID002845
Moliren Ltd.
RUSSIAN FEDERATION

The smelters and refiners identified as part of our reasonable country of origin inquiry and validated as conformant according to LBMA Good Delivery List.

Metal
Smelter ID
Standard Smelter Name
Smelter Country
Gold
CID000343
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
CID001236
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
CID001909
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA


RMAP Participating Processing Facilities

Smelters and refiners identified as part of our reasonable country of origin inquiry and that have agreed to participate in the RMAP audit:
Metal
Smelter ID
Standard Smelter Name
Smelter Country
Gold
CID000264
Chugai Mining
JAPAN
Gold
CID002511
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
CID002863
Bangalore Refinery
INDIA
Gold
CID003189
NH Recytech Company
KOREA, REPUBLIC OF
Tin
CID000555
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tungsten
CID003182
Hunan Litian Tungsten Industry Co., Ltd.
CHINA

Processing facilities with no public participation in validation program
Together with our suppliers and industry cooperation, we will continue requesting participation in RMAP or an equivalent program:
Metal
Smelter ID
Standard Smelter Name
Smelter Country
Gold
CID000103
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
CID000180
Caridad
MEXICO
Gold
CID000197
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
CID000522
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
CID000651
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
CID000671
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
CID000767
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
CID000773
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
CID000778
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Gold
CID000927
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
Gold
CID000956
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
CID001032
L'azurde Company For Jewelry
SAUDI ARABIA
Gold
CID001056
Lingbao Gold Co., Ltd.
CHINA
Gold
CID001058
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
CID001093
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
CID001362
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
CID001546
Sabin Metal Corp.
UNITED STATES OF AMERICA
Gold
CID001562
Samwon Metals Corp.
KOREA, REPUBLIC OF
Gold
CID001619
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
CID001947
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
CID002282
Morris and Watson
NEW ZEALAND
Gold
CID002290
SAFINA A.S.
CZECH REPUBLIC
Gold
CID002312
Guangdong Jinding Gold Limited
CHINA
Gold
CID002515
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
CID002525
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
CID002563
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
CID002567
Sudan Gold Refinery
SUDAN
Gold
CID002587
Tony Goetz NV
BELGIUM
Gold
CID002615
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
CID002708
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Gold
CID002852
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
CID002853
Sai Refinery
INDIA
Gold
CID002854
Universal Precious Metals Refining Zambia
ZAMBIA
Gold
CID002857
Modeltech Sdn Bhd
MALAYSIA
Gold
CID002865
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Gold
CID002866
Morris and Watson Gold Coast
AUSTRALIA
Gold
CID002867
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Gold
CID002872
Pease & Curren
UNITED STATES OF AMERICA



Gold
CID003153
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Gold
CID003185
African Gold Refinery
UGANDA
Gold
CID003324
QG Refining, LLC
UNITED STATES OF AMERICA
Tin
CID000448
Estanho de Rondonia S.A.
BRAZIL
Tin
CID002572
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
CID002573
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
CID002574
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
CID002703
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
CID002756
Super Ligas
BRAZIL
Tin
CID003208
Pongpipat Company Limited
MYANMAR
Tungsten
CID002313
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
CID002647
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA


We have identified an additional 9 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 2019 to perform additional due diligence.
Reasonable Country of Origin Inquiry
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 RMI 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, Armenia, Azerbaijan, Australia, Benin, Bolivia (Plurinational State of), Botswana, Brazil, Burkina Faso, Canada, Chile, China, Colombia, Democratic Republic of the Congo (Kinshasa), Cyprus, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Finland, Georgia, Ghana, Guatemala, Guinea, Guyana, Honduras, Indonesia, Iran, Ivory Coast, Kazakhstan, Kenya, Kyrgyzstan, Laos, Lebanon, Malaysia, Mali, Mauritania, Mauritius, Mexico, Mongolia, Morocco, Namibia, Nicaragua, Niger, Papua New Guinea, Peru, Philippines, Puerto Rico, Russian Federation, Saudi Arabia, Senegal, Slovakia, Solomon Islands, South Africa, Spain, Suriname, Swaziland, Sweden, Zambia, Zimbabwe, Tanzania, Thailand, Togo, Turkey, United States of America, Uruguay, Uzbekistan
The countries of origin for Tantalum may include: Australia, Austria, Bolivia (Plurinational State of), Brazil, Burundi, China, Colombia, Democratic Republic of the Congo (Kinshasa), Ethiopia, Guinea, India, Madagascar, Malaysia, Mozambique, Nigeria, Russian Federation, Rwanda, Sierra Leone, Thailand.
The countries of origin for Tin may include: Australia, Bolivia (Plurinational State of), Brazil, Burundi, China, Colombia, Democratic Republic of the Congo (Kinshasa), Guinea, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Taiwan, Thailand, Uganda, United Kingdom, Venezuela.
The countries of origin for Tungsten may include: Australia, Bolivia, Brazil, Burundi, China, Colombia, Democratic Republic of the Congo (Kinshasa), Guinea, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Russian Federation, Rwanda, Taiwan, Thailand, United Kingdom, United States of America.
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, 251 had reported smelters that process conflict minerals originating in one or more of the Covered Countries.

Altogether 55 smelters in the consolidated smelter list (18% 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 RMAP. 49 smelters were found to be conformant. 30 of these (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. For six of the smelters we cannot rule out that they source from the Covered Countries due to their geographic proximity, and we plan to take further due diligence efforts in 2019 with regard to those smelters.
Progress on Commitments made in 2018 Conflict Minerals Report

Target for 2018
Progress in 2018
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. More suppliers provided information on product level, we reached 96% of traceability smelters and refineries in our supply chain.  Quality and completeness of data was also assessed and verified as part of onsite Conflict Minerals audits that we conducted on our suppliers in China.
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. In addition, two workshops were conducted in China. 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 RMAP compliant smelters;
Engagement was two-fold: on the supplier level directly with smelters and through the respective working group of Responsible Minerals Initiative. As a result 82% of smelters were validated as conflict-free, 2% actively engaged in industry validation process and 4% identified as low risk of sourcing from the Covered Countries.
Requesting suppliers to complete smelter mapping, and source over 90% of tin, tantalum, tungsten and gold from conflict-free smelters; and
In 2018, 100% of the smelters from which our suppliers sourced tantalum were conflict-free, for tungsten 93% of smelters were conflict-free and for tungsten 90%.  For gold the target was not achieved (70%). Smelter mapping by our suppliers was completed at 96% on average.
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 2018 we also conducted 10 third-party audits focused on conflict-free sourcing.

NOKIA COMMITMENTS FOR 2019:
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 2019:
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 RMAP compliant smelters;

requesting suppliers to fully complete smelter mapping, and source tin, tantalum, tungsten and gold 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.