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NOKIA CONFLICT MINERALS REPORT FOR 2022

25 May 2023

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

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

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 2022

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, inductive components, RF MW circuits, discrete semiconductors, 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 934. Of these, 320 suppliers were above the supplier spend threshold applied by Nokia, in the aggregate representing 99% 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 99%. 43 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:

Suppliers sourcing from the Covered Countries: 88% (2021: 98%)

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

In total, we have identified 337 smelters (337 in 2021) of the smelters:

Figure 2. Conflict-Free validation status of the 337 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 January 27, 2023.

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:

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

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:

Processing facilities with no public participation in validation program whom we have requested to be removed from Nokia supply chain

Together with our suppliers and industry cooperation, we will continue requesting participation in RMAP or an equivalent program or remove from the supply chain:

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, Australia, Azerbaijan, Benin, Bolivia (Plurinational State of), Botswana, Brazil, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Democratic Republic of the Congo, Cote d'Ivoire, Djibouti, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, Hungary, India, Indonesia, Italy, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Liechtenstein, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Oman, Panama, Papua New Guinea, Peru, Philippines, Portugal, Russian Federation, Saudi Arabia, Senegal, Serbia, Sierra Leone, Slovakia, South Africa, South Korea, Spain, Sudan, Suriname, Swaziland, Sweden, Tanzania, Thailand, Turkey, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zambia, Zimbabwe.

The countries of origin for Tantalum may include: Australia, Brazil, Burundi, China, Democratic Republic of the Congo, Ethiopia, Mozambique, Nigeria, Rwanda, Sierra Leone, Spain, Thailand, Zimbabwe.

The countries of origin for Tin may include: Australia, Bolivia (Plurinational State of), Brazil, Burundi, China, Colombia, Democratic Republic of the Congo, France, Indonesia, Laos, Malaysia, Myanmar, Namibia, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Spain, Tanzania, Taiwan, Thailand, United Kingdom of Great Britain and Northern Ireland, Venezuela, Vietnam.

The countries of origin for Tungsten may include: Australia, Austria, Bolivia, Brazil, Burundi, China, Democratic Republic of the Congo, Kazakhstan, Kyrgyzstan, Malaysia, Mexico, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Spain, Thailand, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Vietnam, Zimbabwe.

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, 242 (268 in 2021) had reported smelters that process conflict minerals originating in one or more of the Covered Countries and 243 (245 in 2021) from other Conflict-Affected Countries and High-Risk Areas. Altogether 82 smelters in the consolidated smelter list (24% 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. 67 smelters were found to be conformant and 2 active in the RMAP validation process. 31 of these (9% of all 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 five of the smelters we cannot rule out that they source from the Covered Countries due to their geographic proximity, and we will continue to take further due diligence efforts in 2023 with regard to those smelters.

Extending Due Diligence to Cobalt and Mica

In 2022, we also undertook a mapping of cobalt and mica in our components based on extended minerals material declarations for product parts. We addressed 79 relevant suppliers about our requirements regarding cobalt and requested them to exercise due diligence over the cobalt supply

chain and 19 suppliers with mica. 68% of suppliers for cobalt and 21% for mica have completed mapping their cobalt and mica supply chains and as a result, we have been able to identify 71 cobalt and 17 mica smelters in our cobalt supply chain, out of which 59% (cobalt) and 18% (mica) have gone through the Responsible Minerals Assurance Program and have either Conformant or Active status. In 2022, we undertook an assessment of our entire list of materials against ESG risks and beyond 3TGs, cobalt and mica and started to map the mechanics supply chains related to copper, steel, nickel and aluminum.

For upstream engagement we have continued our work with the Public-Private Alliance, contributing to the development of in-region programs. In 2022, we helped to fund one of the local programs dealing with expanding children's educational access and socio-economic opportunities for their families and vulnerable women (including survivors of sexual violence); and work on women's leadership and reintegration into communities following sexual violence strongly related to the minerals mining and supply chain.

Progress on Commitments made in 2022 Conflict Minerals Report

NOKIA COMMITMENTS FOR 2023:

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 2023:

engaging in further awareness raising and due diligence capability building efforts jointly in collaboration with relevant stakeholder forums and/or independently with our suppliers;

requesting non-conformant suppliers to improve quality of the reporting and to finalize the phase out of the non-conformant smelters;

actively engaging with our supply chain to get more smelters validated as conflict-free through the third-party validation mechanisms, with the aim of sourcing only from the list of RMAP compliant smelters;

validating the due diligence efforts of our suppliers as part of overall supplier assessment;

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 RMI 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.