View:
[NOKIA LOGO] [GRAPHIC OMITTED] 1(2)
January 11, 2006
Securities and Exchange Commission
Office of Global Security Risk
Cecilia D. Blye, Chief
100 F Street, NE
Washington, DC 20005
Nokia Corporation
Form 20-F for the fiscal year ended December 31, 2004
File No. 1-13202
Responseto your letter of December 29, 2005
Dear Ms. Blye
Set forth below is our response to your request for supplemental
information relating to our business activities in Iran, Syria and
Libya. We also provide similar information relating to our business
activities in Sudan.
In 2004, our net sales to customers in Iran, Syria and Sudan
accounted for less than 1% of our total net sales, or approximately
EUR 262 million (approximately USD 314 million). In 2004, we did not
have any sales to Libya.
In 2004, our sales to customers in Iran consisted mainly of mobile
devices and accessories, in addition to which we sold and are
building a mobile telecom network for one customer,
Telecommunications Company of Iran (TCI) /Mobile Communications
Company of Iran (MCI, owned by TCI). Our sales to customers in Syria
and Sudan in 2004 consisted of mobile devices and accessories only.
As to Libya, we did not have any sales there during 2004, but signed
a network sales contract with one customer, Libyan General Post and
Telecommunications Company (GPTC), in late 2004. In 2005, we
continued to sell mobile devices and accessories to customers in
Iran, Syria and Libya, but none to customers in Sudan. We did not
have any sales of network equipment to customers in Libya but we
continued to sell network equipment to customers in Iran in 2005.
None of the products or services built, offered, distributed, or sold
by Nokia to customers in any of Iran, Syria, Libya or Sudan are
intended for military application.
In 2004, we had no employees in any of Iran, Syria, Libya or Sudan.
In 2005, we had approximately 40 employees in Iran, but none in
Libya, Syria or Sudan. Consequently, our employees in these four
countries represent in the aggregate less than 0.1% of our total
number of employees which was 57 477 as of September 30, 2005. We
currently have two sales offices in Iran, we have leased office space
in Libya, but it is not occupied, and we have no offices in Syria or
Sudan.
Our contacts with Iran, Syria, Libya and Sudan are not material to
Nokia. Similarly, from a qualitative perspective, to our knowledge,
these contacts have not had any impact on our business reputation or
share value. We do not believe that our contacts with these four
[NOKIA LOGO] [GRAPHIC OMITTED] 2(2)
countries constitute, individually or in the aggregate, any material
investment risk for our security holders.
Please kindly note that in order to keep our investors adequately
informed in light of the current US position with respect to
activities in these countries, we intend to include in Item 4B,
Business Overview, of our Form 20-F for the fiscal year ended
December 31, 2005 the disclosure attached to this letter in Enclosure
1.
Nokia acknowledges that
- Nokia is responsible for the adequacy and accuracy of
the disclosure in its filings with the SEC;
- The SEC staff comments or changes to Nokia's disclosure
in response to staff comments do not foreclose the SEC
from taking any action with respect to Nokia's filings;
and
- Nokia may not assert the SEC staff comments as a defense
in any proceeding initiated by the SEC or any person
under the federal securities laws of the United States.
In case of additional comments, please contact Kaarina Stahlberg,
Assistant General Counsel, over the e-mail at
kaarina.stahlberq@nokia.com or over the phone at +358 40 728 7843.
NOKIA CORPORATION
/s/ Maija Torkko /s/ Kaarina Stahlberg
----------------------- ---------------------------
Maija Torkko Kaarina Stahlberg
Senior Vice President, Vice President,
Corporate Controller Assistant General Counsel
Cc: Larry Spirgel
Kyle Moffatt
Division of Corporation Finance
Securities and Exchange Commission
Enclosure 1
-----------
Business description
- --------------------
As we are a global company and have sales in most countries of the world, in
2005 we also had sales to customers in Iran, Libya and Syria, which countries
have been designated "state sponsors of terrorism" by the U.S. government
Furthermore, in 2004 we had very minor sales to customers in Sudan, but none in
2005.
In 2005, we sold mobile devices and accessories to customers in Iran, Libya, and
Syria. In addition, we sold network equipment to a customer in Iran. In 2004, we
also signed a network sales contract with a customer in Libya, but that contract
has not resulted in any sales by the end of 2005. In 2005, our aggregate sales
to customers in Iran, Libya and Syria accounted for approximately [ ]% of our
total revenue or EUR [ ] million. Iran and, to a lesser extent, Syria are
subject to U.S. economic sanctions that are primarily designed to implement U.S.
foreign policy.