Nokia Corporation

Reference: page 90

Nokia describes the composition and role of its Board, committees and Group Leadership Team (GLT) in overseeing sustainability. Of the 10 Board members, 40% are female and 60% are male, representing six nationalities. All members are non-executive and were determined to be independent, with no employee or worker representatives. The GLT, chaired by the President and CEO, had 11 members at year-end (18% female, 82% male). Under the Corporate Governance Guidelines, the Board approves the ESG strategy and evaluates environmental and social activities, related risks and target setting. In 2024 the Board reviewed the sustainability strategy, re-examined targets following the double materiality assessment, and approved climate targets in the long-term incentive plan and health and safety and diversity targets in the short-term plan. Board committees (Personnel, Audit, Corporate Governance and Nomination, Technology and Strategy) provide delegated oversight. The GLT regularly addresses sustainability impacts, risks and opportunities; in 2024 overall ESG responsibility within the GLT moved from the Chief Corporate Affairs Officer to the Chief Legal Officer.

Reference: page 92

Nokia explains how sustainability information reaches its governance bodies. ESG topics are brought to the Board, GLT and committees on a regular basis through several channels, by members of the Sustainability team and subject matter experts and by business group and function representatives who sit on the Sustainability Council. Several councils and committees inform the bodies in their oversight of impacts, risks and opportunities: the Sustainability Council, the Donations and Sponsorships Committee and the Human Rights Due Diligence Council steer, align and ensure implementation of ESG strategies, targets and frameworks. The ESG Financial Reporting Steering Committee informs the Audit Committee of impacts, risks and opportunities identified through the double materiality assessment and of the contents of the Sustainability Statement. Sustainability-related key risks and opportunities are embedded within Nokia's Enterprise Risk Management framework and reviewed at least annually with the GLT and the Board. External expert trainings are organized to help Board members and the GLT evaluate the sustainability strategy and assess materiality. Key experts and executives participated in the double materiality assessment.

Reference: page 94

Nokia operates short-term (STI) and long-term (LTI) incentive plans for all employees, including the GLT and the President and CEO, with performance measures set yearly to align with strategy and including sustainability targets. LTI awards, paid in shares and typically vesting after three years, include a 10% weighting on carbon emission reduction targets across scope 1, 2 and 3 over a three-year period, aligned with Nokia's net-zero roadmap and the 2030 goal of a 50% reduction. The 2024 STI for the President and CEO and GLT members includes a 10% weighting for health and safety (lost time injury frequency rate with a fatality modifier) and a 10% weighting on female percentage in global external hiring. In total, the proportion of variable remuneration subject to sustainability-related targets is 20% for the President and CEO and GLT members in short-term incentives and 10% in long-term incentives. The conditions are prepared and approved by the Personnel Committee, while the Board approves all share-based incentives and the President and CEO's compensation. The Remuneration Policy was last updated in 2024.

Reference: page 95

Nokia describes specific due diligence processes for environment, human rights and responsible sourcing, and provides a table mapping the core elements of due diligence to paragraphs in the Sustainability Statement. Environmental due diligence is integrated into business operations through an Environmental Management System with continuous improvement targets. Human rights due diligence (HRDD) reflects principles in the International Bill of Human Rights, the ILO Declaration, the OECD Guidelines and the UN Guiding Principles. Nokia's HRDD process targets potential misuse of its technology, is applied pre-emptively before any sale, and uses an external country risk rating provider, with triggers built into the sales approval process and oversight by the Head of Human Rights. Responsible sourcing due diligence covers supplier due diligence, climate action, circularity and responsible minerals sourcing, with collaboration through the Responsible Business Alliance (RBA) and the Joint Alliance for CSR (JAC). The mapping table covers embedding due diligence in governance, strategy and business model; engaging with affected stakeholders; identifying and assessing adverse impacts; taking actions to address them; and tracking effectiveness.

Reference: page 96

Nokia describes its internal control procedures over the sustainability reporting process. Management is responsible for establishing and maintaining adequate internal controls over sustainability reporting, aimed at providing reasonable assurance on the reliability of reporting and the fair representation of information in the published Sustainability Statement. The control processes consist of various controls designed around the applicable ESRS and monitored through internal audit. Management conducts a yearly assessment of internal controls in accordance with the COSO Framework (2013). Management has assessed control design, tested operating effectiveness of all key controls, and evaluated noted deficiencies in the interim and at year-end. In 2024, progress and assessments were reported to management and the Audit Committee on a quarterly basis. The internal audit function examines and evaluates the adequacy and effectiveness of the internal controls system, reports to the Audit Committee, and follows a risk-based annual audit plan. In 2024, the sustainability reporting process, controls design, controls performance and audit trail were within the scope of internal audit reviews and testing.

Reference: page 97

Nokia's approach to sustainability is built on its purpose, to create technology that helps the world act together, and is integral to its Technology Vision 2030. Nokia takes a two-pronged approach: maximizing positive impact (handprint) and minimizing negative impact (footprint). The use phase of Nokia's products accounted for 95% of total greenhouse gas emissions in 2024, so emission reduction focuses on product energy efficiency. The sustainability strategy focuses on Environment (climate and circularity), Bridging the digital divide, and Responsible business. Nokia embeds sustainability across its four business groups: Network Infrastructure, Mobile Networks, Cloud and Network Services, and Nokia Technologies, which are the operating and reportable segments. In 2024 Nokia delivered net sales of EUR 19 220 million, invested EUR 4 512 million in R&D, and employed 78 434 employees on average (excluding discontinued operations). Nokia conducted business with around 9 300 suppliers in over 100 countries, with 80% of total supplier spend across around 400 suppliers. The value chain spans upstream (material sourcing, components and service procurement, manufacturing and assembly), own operations, and downstream (product use, support and maintenance, end-of-life management).

Reference: page 100

Nokia adopts a collaborative and consultative approach toward its key stakeholders, reflecting their views and interests in decisions on strategy and the business model. The same approach was followed for the double materiality assessment. Nokia provides a table summarizing its key stakeholder groups, their engagement purpose, communication channels, topics important to them, and the impact on the business model and strategy. Stakeholder groups covered include customers, own workers, investors, suppliers and partners, the industry sector, academia, affected communities and civil society, and regulatory authorities and standard-setting organizations. Engagement channels range from dedicated sales personnel, ESG customer advisory councils and Executive Review Meetings, to the annual ESG investor roadshow, supplier management channels and industry associations such as the RBA, JAC and GSMA. The views and interests expressed through these engagements are brought to the attention of, and taken into account by, the relevant administrative, management and supervisory bodies, with regular reporting to the GLT and the Board and its Committees, enabling Nokia to calibrate its strategy and business model to address significant material impacts on stakeholders.

Reference: page 103

Based on its double materiality assessment, Nokia identified Climate change, Resource use and circular economy, and Social and Governance topics as material. The assessment identified seven material topics encompassing 14 material sub-topics, with material standards E1 (Climate change), E5 (Resource use and circular economy), S1 (Own workforce), S2 (Workers in the value chain), S3 (Affected communities), S4 (Consumers and end-users) and G1 (Business conduct). Nokia provides a table of identified impacts, risks and opportunities by ESRS topic, type, and concentration in the value chain (upstream, own operations, downstream). Material impacts occur across all value chain phases, including positive impacts from energy and resource efficient products and connectivity, and negative impacts from greenhouse gas emissions and electronic waste. These material impacts, risks and opportunities are taken into account in Nokia's ESG strategy and business model, with the strategy reviewed annually within the Enterprise Risk Management framework. Using the phase-in provision for its first year of reporting, Nokia is not yet disclosing the anticipated financial effects of material risks and opportunities. Nokia's strategy resilience is supported by its talent base and consolidated business continuity approach.

Reference: page 109

Nokia describes the process used in its double materiality assessment to identify and assess sustainability-related impacts, risks and opportunities, conducted for both impact materiality and financial materiality following ESRS 1 requirements. The assessment was conducted in four stages: value chain mapping, impact assessment, financial assessment, and material topics determination and validation. Nokia engaged with over 70 internal and external stakeholders, following EFRAG guidelines, and used an external partner to support and guide the process; ten external stakeholders including business partners, investors and NGOs were interviewed. Impacts were scored on severity (scale, scope, irremediability) and likelihood, while risks and opportunities were scored on likelihood and estimated magnitude of financial effect. Materiality thresholds were set at 3.7 for impact materiality and 3.0 for financial materiality, on a 0 to 4 scale. Topics not meeting the thresholds, including pollution (E2), water and marine resources (E3) and biodiversity (E4), were assessed and found not material. The process and results were reviewed and approved by the ESG Financial Reporting and CSRD reporting Steering Committee, and the Audit Committee was informed. Sustainability-related risks and opportunities are embedded within Nokia's Enterprise Risk Management framework.

Reference: page 180

Nokia states that the list of disclosure requirements in ESRS covered in the Sustainability Statement, along with the list of data points that derive from other EU legislation, are included in the Appendix to the Sustainability Statement (content index). This is Nokia's first Sustainability Statement prepared in accordance with the CSRD and ESRS. As this is the first year of reporting, Nokia adopted the phase-in transitional provisions in ESRS 1 and omitted certain disclosures to be reported in subsequent periods, including ESRS 2 SBM-1 paragraphs 40(b) and 40(c) (breakdown of revenue by significant ESRS sectors and the list of additional significant sectors), ESRS 2 SBM-3 paragraph 48(e) (anticipated financial effects of material impacts, risks and opportunities), ESRS E1 E1-9 (anticipated financial effects from physical and transition risks and climate-related opportunities), ESRS E5 E5-6 (anticipated financial effects from resource use and circular economy matters), and ESRS S1 disclosures on social protection (S1-11) and work-life balance metrics (S1-15). The Sustainability Statement does not include digital XBRL tags due to the absence of applicable ESEF or other EU legislation. The statement was subject to external limited assurance in accordance with ISAE 3000 (Revised), with the assurance report on page 289.

Reference: page 113

In 2023 Nokia investigated how to accelerate its net-zero ambition and defined the related transition plan and levers. Following this, in 2024 Nokia announced a commitment to reduce its total greenhouse gas emissions to net zero across the value chain by 2040, accelerating its previous target by ten years and putting it ahead of the Paris Agreement target of net-zero by 2050. The net-zero target was approved by the Science Based Targets initiative in January 2025. Nokia is not excluded from EU Paris-aligned benchmarks. Decarbonization levers fall into three categories: own operations (facilities and fleet, scope 1 and 2), upstream activities (scope 3 categories 1, 2, 4 and 6), and downstream product use phase (scope 3 category 11), with electricity grid decarbonization also significant. The commitment was approved by the Group Leadership team and the Board was informed. Nokia identified no locked-in GHG emissions from its key assets or products.

Reference: page 112

Nokia has adopted policies to manage its material impacts, risks and opportunities related to climate change mitigation and energy. Nokia aims to prevent environmental pollution along its value chain as set out in its Environmental policy and Code of Conduct, and is committed to reducing GHG emissions across the value chain in line with its GHG emission reduction targets. The Environmental policy is based on the principles of the ICC Business Charter for Sustainable Development, while environmental management and performance are governed by a certified ISO 14001 Environmental Management System. In 2024, Environmental Management Systems covered 54% of Nokia's sites and 90% of employees, excluding discontinued operations. The policy is publicly available and each business function is responsible for implementation. Nokia also applies a Design for Environment guideline and product environmental requirements, and requires hardware and final assembly suppliers to maintain an ISO 14001 or equivalent Environmental Management System.

Reference: page 113

Nokia's net-zero pathway sets out decarbonization levers and key actions across own operations, upstream and downstream activities. In own operations, Nokia targets 100% renewable electricity in facilities by 2025 and transition to 100% electric vehicles by 2030. Upstream, it works with suppliers on embodied emissions, circular products and recycled materials. Downstream, with 95% of emissions from products in use, efforts concentrate on product design and energy efficiency. Key 2024 actions included incremental and generational hardware energy efficiency improvements and new software features such as Extreme Deep Sleep mode, MantaRay Anomaly detection and Wavence Sleep modes. In 2024 Nokia invested EUR 4 512 million in research and development, with product energy efficiency integrated into overall product development. In 2024, 408 key suppliers responded to CDP and 257 provided emission reduction targets. Nokia established a Sustainable Finance Framework and completed a EUR 500 million sustainability-linked bond, and signed a EUR 250 million loan with Nordic Investment Bank for 5G and 6G R&D.

Reference: page 118

Nokia has set short-, medium- and long-term climate targets with no geographical exclusions. The SBTi-approved net-zero target (approved January 2025) commits Nokia to net-zero GHG emissions across the value chain by 2040. The near-term target is to reduce absolute scope 1, 2 and 3 GHG emissions 50% by 2030 from a 2019 base year, and the long-term target is to reduce absolute scope 1, 2 and 3 GHG emissions 90% by 2040 from a 2019 base year. Scope 3 covers categories 1, 2, 4, 6 and 11. The earlier SBT 1.5 target (SBTi approved in 2021), a 50% reduction in scope 1, 2 and 3 emissions by 2030 from 2019, is reported for the last time for 2024. Interim 2025 targets include an 80% reduction in scope 1 and 2 market-based emissions and 100% renewable electricity (RE100). In 2024, 87% of electricity was renewable. Total GHG emissions fell 28% versus 2023 and 36% versus the 2019 base year. Progress on the targets is reported as on track.

Reference: page 122

For Nokia continuing operations in 2024, total energy consumption related to own operations was 1 005 206 MWh (2023: 1 034 047 MWh), covering facilities and excluding car fleet, which is expected to be at most 5% of the total. Total energy consumption from renewable sources was 728 242 MWh (2023: 668 540 MWh), with renewable sources representing 72% of total energy consumption in 2024, up from 65% in 2023. Total energy consumption from fossil and nuclear sources was 276 964 MWh, or 28% of the total. Within this, fuel consumption from natural gas was 111 954 MWh and from crude oil and petroleum products 1 012 MWh. Total self-generated energy production was 15 817 MWh, almost entirely non-renewable. Energy consumption of sold products outside Nokia was 53 077 484 MWh in 2024, down from 74 650 000 MWh in 2023. In 2024, 87% of electricity used in Nokia's own facilities was renewable, on track toward the RE100 target.

Reference: page 122

For Nokia continuing operations in 2024, total market-based GHG emissions were 26 011 608 tCO2eq (2023: 36 040 273), a 28% reduction versus 2023 and a 36% reduction versus the 2019 base year, mainly driven by lower emissions from use of sold products. Gross scope 1 emissions were 38 447 tCO2eq (2023: 39 331). Gross market-based scope 2 emissions were 52 051 tCO2eq (2023: 83 924) and location-based scope 2 were 313 865 tCO2eq. Total market-based scope 1 and 2 emissions were 90 498 tCO2eq. Total gross indirect scope 3 emissions were 25 921 110 tCO2eq, with use of sold products (category 11) at 24 736 044 tCO2eq, purchased goods and services 962 134, upstream transportation and distribution 160 178, capital goods 33 207 and business travel 29 547. About 95% of Nokia's total scope 1, 2 and 3 emissions come from products in use in customers' networks. 97% of scope 3 was calculated using primary data.

Reference: page 113

Nokia expects that credible, permanent carbon removals and storage will be required to neutralize residual emissions and reach net-zero, and has been examining credible carbon removal solutions to support its long-term net-zero target. Under the corporate net-zero standard (SBT V1), after achieving its long-term target Nokia may use permanent carbon removal and storage to counterbalance residual emissions up to 10%. Based on net-zero modeling, the maximum GHG emissions (scope 1, 2 and 3) to be compensated in 2040 is 4 million tCO2eq; at the EU Emissions Trading Scheme price of EUR 72 per tCO2eq as of 31 December 2024, this equals EUR 288 million. Potential future investments in carbon removal units would be recorded as intangible assets until utilized, then expensed as operating costs. The net-zero pathway includes entering carbon markets to purchase removals before 2040. Nokia did not report any GHG removals or carbon credits used in the reporting year.

Reference: page 128

Nokia looks at circularity from two perspectives: increasing use of non-virgin materials in new products and packaging, and ensuring maximum waste circularity in its operational value chain. Its strategy to increase operational circularity follows the classic waste hierarchy, with avoidance of waste as the first principle. The Code of Conduct is Nokia's highest-level policy and covers commitment to the environment in own operations, supply chain and business relationships. Environmental policies cover circular economy and resource use matters. Key policies and guidelines include the Design for Environment guideline (addressing regulatory, customer and Nokia requirements for designers), packaging requirements and standards, the Guideline to Reuse of Packaging Material, Electronic Waste Management policies, and facilities waste management guidelines based on ISO 14001. Supplier requirements include the Third-Party Code of Conduct and the Responsible Business Alliance Code of Conduct, covering recycled content, waste management and raw material content data.

Reference: page 129

Nokia runs a Design for Environment program providing developer guidelines on durability, dismantling, reparability, recyclability, product weight, supply risk and energy efficiency. During 2024 the program continued, considering the evolution of product materials (including recycled metals and plastics). Nokia studied how to increase product take-back volumes and solidified its circular solutions portfolio, including four modules: Asset Recovery, Circular Products and Parts, Refurbishment Service and Recycling Service. Supplier engagement programs use on-site audits, Environmental Management System reviews and EcoVadis assessments, with focused improvement programs to increase recycled-origin aluminum, steel, copper and polymerics. With final assembly suppliers Nokia is working to increase waste circularity rate to 95%, diverting waste from landfill or incineration without energy recovery. For packaging, business groups increase recycled content and recyclability and research sustainably sourced materials such as molded pulp and thermoformed plastics.

Reference: page 131

Nokia has three external targets covering resource inflows and outflows. Recycled content in sourced mechanical materials by 2030: 90% for cast aluminum used in mechanical parts, and 50% for wrought aluminum, steel and copper alloys and polycarbonate plastics. These cover materials with the highest use but not all materials. Status: not on track. Waste circularity target by 2030: 95% circularity rate for waste from offices, labs, own manufacturing, installation, product take-back and supply chain final assembly factories (base year 2022, base value 89%); the 2024 annual waste circularity outcome was 81%, reported as on track. In 2024 Nokia also set new packaging targets measured from reporting year 2025 (base year 2024): all packaging recyclable by 2030 (100%), cardboard and plastic packaging materials to contain at least 50% recycled content by 2030, and plastic packaging limited to no more than 10% by weight of total primary packaging by 2030.

Reference: page 133

Nokia's resource inflows include telecommunication products and components and third-party equipment comprising minerals, metals and polymers; secondary hardware such as take-back equipment from customers; and product packaging including wood- and plastic-based materials. For 2024 the overall total weight of products and technical and biological materials used was 60,560 metric tons (not reported for 2023). Recycled content in mechanical part source materials in 2024 was 38% cast aluminum (43% in 2023), 15% wrought aluminum (10%), 5% stainless steel (13%), 2% low alloy steel (7%), 4% copper alloys (3%) and 6% polycarbonate plastics (not reported in 2023). Recycled content in product packaging was 32% in 2024 (not reported in 2023). Nokia uses FSC-certified packaging materials but states the share of sustainably sourced biological materials could not be reliably estimated for 2024, and certain ESRS E5 para 31c metrics on secondary materials were not reported due to lack of value chain data.

Reference: page 133

Nokia's key products are telecommunication network products with mission-critical service availability. Most products have a design life of 10 to 15 years, with some remaining in extended service for more than 20 years. For resource outflows, the rate of recyclable content in products was 80% in 2024 (not reported in 2023) and the rate of recyclable content in product packaging was 96% in 2024 (not reported in 2023). Recyclability rates were calculated based on material composition of key products and packaging, weighted by units delivered and unit weight. Estimated recyclability rates by material included steel, stainless steel, aluminum and alloys, copper and alloys, other metals, paper-based packaging and wood-based packaging all at 100%, polymerics at 70%, plastics-based packaging at 90%, and PWB assemblies at 22%. Circular principles such as reliability, product lifetime and serviceability are inherent in product design, with field-replaceable parts enabling repair.

Reference: page 133

For Nokia continuing operations, total waste from own operations in 2024 was 7,302 metric tons (7,635 in 2023). Total waste diverted from disposal was 6,367 metric tons (6,635 in 2023), comprising 82 for preparation for reuse, 5,588 for recycling and 697 for other recovery operations. Total waste directed to disposal was 935 metric tons (1,000 in 2023), all by landfilling with zero incineration. Total hazardous waste was 2,198 metric tons in 2024 (1,415 in 2023), of which 2,192 was diverted from disposal and 6 directed to disposal. Total non-hazardous waste was 5,104 metric tons in 2024 (6,220 in 2023), of which 4,175 was diverted from disposal and 929 directed to disposal. Non-recycled waste was 935 metric tons (13%) and the waste utilization rate was 87%. Electronic waste from facilities was 2,024 metric tons. Equipment returned from customers totaled 988 metric tons (304 reuse, 682 recycle) and 46,378 items for reuse. Batteries, lamps, solvents, solder and WEEE are classified as hazardous.

Reference: page 147

Nokia's labor conditions are based on its Code of Conduct, People Framework, Human Rights Policy, and local employment laws, policies and practices. Nokia is committed to the principles of the UN Universal Declaration of Human Rights, the UN Global Compact, and the ILO Declaration on Fundamental Principles and Rights at Work, and strives to exceed local labor standards. Policies, Standard Operating Procedures (SOPs) and the Code of Conduct apply to employees and suppliers, covering zero tolerance for child and forced labor, freedom of association and collective bargaining, non-discrimination, humane treatment, working time, disciplinary practices, compensation, and occupational health and safety. The People Framework states no employee or candidate will receive less favorable treatment due to protected characteristics. Nokia strengthened its People Agenda in 2024, centered on talent, leadership and culture, guided by its Essentials of being open, fearless and empowered.

Reference: page 149

Nokia respects the right to collective bargaining and freedom of association. Collective bargaining agreements are local, and in most countries with such agreements, employees who choose not to join a union are also covered by similar terms. Employees can freely join, not join or leave unions and select their representatives based on local and international practices. In countries and regions with works councils, Nokia works collaboratively with them and communicates regularly with employees directly and with their representatives, including at European Works Councils (EWCs). Employee representatives are entitled to participate in training necessary for their duties and to increase knowledge of trade union rights, and may use company infrastructure during the workday. Responsibility for engagement rests with the Chief People Officer through the People Relations Team and the Chief Legal Officer through the Labor and Employment Law Team. Internal career path tools and the Talent Acquisition team support employees through internal vacancies and career applications.

Reference: page 150

The processes and channels available to Nokia's workforce to raise concerns and have them addressed are described in the Business Conduct (ESRS G1) section under Reporting channels and investigations process. Nokia implements its policies to prevent, mitigate, and address discrimination through proactive measures, robust reporting mechanisms, and corrective actions. Prevention is achieved through ongoing awareness campaigns and mandatory training programs designed to educate employees on inclusive behaviors and the importance of diversity. To address potential violations, Nokia has a well-established Ethics Helpline supported by a strong speak-up culture, and employees are encouraged to report any concerns about behaviors that may conflict with company values. Once a report is made, it is handled by a dedicated Ethics team, which assigns an investigator to thoroughly review the concern and determine appropriate outcomes.

Reference: page 147

Nokia invests in measures to develop future-fit talent at company and business group level, focusing on critical skills, stretch assignments and exposure to different parts of the business through internal mobility initiatives. When unavoidable business transformation negatively impacts the workforce, consequences are mitigated through reskilling, redeployment support and severance packages. Social protection measures include offering continued training opportunities, supporting and encouraging redeployment activities to find new roles within the company including retraining, and offering severance packages that are often greater in value than required by local laws. Nokia also offers career counseling and job search support outside the company. On non-discrimination, Nokia implements prevention through awareness campaigns and mandatory training, robust reporting via the Ethics Helpline, and corrective actions. Nokia analyzes gender equality of compensation annually and funds focused salary increases to remediate unexplained gender pay gaps, implementing a second remediation round in December 2024.

Reference: page 150

In 2021, Nokia set two diversity targets to address the under-representation of women. The first target, set against a 2021 base value of 22%, is to increase the share of women to a minimum of 25% of total employees by 2030. The ratio of women in Nokia's own employees was 23% at the beginning of 2024 and remained the same at the end of 2024; this target is reported as On track. The second target, set against a 2023 base value of 28%, was to reach a minimum of 28% female hires in global external recruits in 2024. Nokia achieved this target, with 28% of external recruits being women, reported as Achieved. Nokia achieved this through increased marketing, communication and talent attraction activities to make its employer brand stand out for diversity-friendly employment policies. Targets are tracked with stakeholders across the business, people and talent acquisition teams.

Reference: page 152

For Nokia continuing operations (excluding Submarine Networks), the total number of employees was 78,434 on an average headcount basis across 2024, comprising 17,897 female, 59,402 male, and 1,135 in the other category (non-binary, third gender and/or not disclosed). At the end of 2024, Nokia employed 75,633 people. Of the average total, 75,627 were permanent employees and 2,807 were temporary employees, with no non-guaranteed hours employees. By region, employees were spread across Asia-Pacific (3,521), India (17,784), Europe excluding Finland (26,718), Finland (6,716), LAT (2,749), MEA (2,970), NAM (9,287) and China (8,689). Employee turnover in 2024 was 8,934 employees leaving, a turnover rate of 12%, compared with 6,543 and 8% in 2023. By age group, 13% were under 30, 58% were 30 to 50, 27% were over 50, and 1% unknown.

Reference: page 152

Nokia's own workforce includes both employees and non-employees. Non-employees are short-term external temporary resources sourced from external suppliers and engaged in employment activities under the direction of Nokia. This includes individuals performing the same work as Nokia employees, such as those filling in for absent employees or performing regular work at the same site as Nokia employees. The number of non-employees in Nokia's own workforce was 1,869 in 2024. The non-employee metric is reported in headcount and disclosed as a total average across the reporting period. Submarine Networks is reported separately and is not considered part of Nokia's continuing operations.

Reference: page 151

The ratio of women in Nokia's own employees was 23% at both the beginning and end of 2024. For top management level in continuing operations in 2024, there were 597 female (17%) and 2,816 male (83%), totaling 3,413. Nokia top management includes line managers and individual contributors who are senior directors and executives, corresponding internally to job grade 13 and above. Nokia actively fosters a culture of trust and belonging and aspires to be more representative so its teams reflect the communities it serves. As part of its People Agenda, Nokia has priorities focused on increasing diverse representation and embedding inclusion into its policies and employee experience, and is investing in hiring strategies that attract and source diverse candidate pipelines across roles and locations, including a focus on women in early careers to improve gender balance.

Reference: page 148

Nokia's compensation and benefits programs balance market competitiveness and affordability based on a total compensation approach, and are performance-driven, flexible and fair. The key elements of compensation structures are annual base salary, incentive/bonus programs, recognition programs and equity-based long-term incentives. All Nokia employees are paid an adequate wage, in line with applicable benchmarks. Pay practices are regularly reviewed to align pay with performance, experience, and the skills required for every position. Nokia pays at least the minimum wage, complies with all legal requirements for wages, and at a minimum provides any legally or contractually required benefits. Nokia policy is that part-time or temporary employees have access to employee benefit plans. Nokia does not permit people to work more than is legally allowed and defines regular working hours in accordance with local laws, guaranteeing a minimum of one day off in every seven days in production operations.

Reference: page 152

The average number of all internal learning hours was 19 hours per employee in 2024. By gender, average training hours per employee were 19 overall, 17 for female employees, 19 for male employees, and 16 for the other category (non-binary, third gender and/or not disclosed). The percentage of employees who participated in regular performance and career development reviews was 95% overall, based on 2023 review results due to the timing of the performance review process. By gender, participation was 23% for female and 72% for male employees. By category, participation was 8% for people managers and 87% for individual contributors. In 2024, Nokia delivered 17 Leadership for Impact sessions with 312 participants, 3,545 employees used Harvard ManageMentor and Harvard Spark leadership training solutions, employees completed 16,285 self-paced leadership online trainings, and achieved 4,410 badges. Annual development reviews are available to all employees.

Reference: page 152

The gender pay gap between female and male employees was 0.7% in 2024. Based on the adjusted pay analysis, female employees earn 0.7% less than male employees, accounting for any applied controls. The annual total remuneration ratio was 50.71 in 2024, calculated by dividing the CEO's total pay by the average employee salary. Annual total remuneration encompasses all salary, benefits, equity, and bonuses paid. To ensure gender pay equity, Nokia conducts biannual in-depth pay analyses that investigate statistically significant differences in pay distribution between male and female employees within groups of similar individuals, initially grouped based on geography and/or role type, controlling for neutral, objective factors such as job grade and performance. Since 2019, Nokia has analyzed gender equality of compensation practices and funded focused salary increases to remediate unexplained gender pay gaps, implementing a second remediation round in December 2024.

Reference: page 156

The Nokia Code of Conduct is the highest-level policy and covers Nokia's commitment to human rights in its own operations, supply chain and business relationships. Nokia expects suppliers to adhere to the Nokia Third-Party Code of Conduct and provides Nokia Supplier Requirements, including the Responsible Business Alliance (RBA) Code of Conduct plus Nokia-specific sustainability requirements. Labor-related requirements are based on international standards such as the Universal Declaration of Human Rights, the ILO Core Conventions and the Social Accountability SA8000 Standard. They cover working time, overtime, leaves, compensation and benefits, modern slavery risk and forced labor prevention. The Nokia Health, Safety and Labor Conditions Policy and Nokia's Life-Saving Rules cover all operations performed by everyone working on Nokia's behalf at Nokia's own or customer premises. Nokia conducts business with around 9 300 suppliers in over 100 countries. Supplier due-diligence is one of the four pillars of Nokia's responsible sourcing strategy.

Reference: page 156

Nokia engages with value chain workers through on-site audits and inspections of suppliers. These include management system reviews and interaction, site tours, worker interviews, timesheet and holiday leave checks, remuneration checks, and employment contract and file checks. When sampling for documentation reviews and worker interviews, vulnerable group representatives are included. On-site audits are conducted based on risk, prioritizing supplier sites in high-risk geographies and supplier commodities with high risk of labor rights infringements. Monitoring, assessment and auditing activities also include EcoVadis assessments, which are online assessments of supplier policies and procedures covering working time and leave, remuneration, recruitment and forced labor prevention; these are repeated every two to three years depending on the supplier score. Interaction with supplier employees is also conducted via supplier training such as on-site workshops and webinars. Health and Safety worker consultations include Supplier Health and Safety Maturity Assessments, on-site sustainability audits with worker interviews, and EcoVadis assessments. Operational responsibility sits with the Head of Sustainable Supply Chain and the Head of People Safety and Security.

Reference: page 156

Findings from audits and assessments are addressed through corrective action and improvement plans communicated to the supplier. In the event of a health and safety incident or accident, an investigation process is triggered focusing on root cause determination, after which corrective and preventative actions are mandated. Implementation of action plans, whether triggered by audits or investigations, is monitored by local Health and Safety teams. Nokia has developed a Health and Safety Consequence Management Process to evaluate the causation of incidents transparently and fairly. For incidents related to child and forced labor, Nokia has a Child and Forced Labor Remediation Process. The main channel for value chain workers to raise concerns related to their employer should be their employer grievance channels. Besides those channels, concerns can also be raised through the Nokia Ethics Helpline and via worker interviews conducted as part of supplier audits and site inspections. Reporting channels, investigations and retaliation protections are described under Business conduct (ESRS G1).

Reference: page 157

In 2024, Nokia conducted a total of 606 supplier audits and EcoVadis assessments, including 101 in-depth corporate responsibility audits. There were 16 countries covered by these audits, such as China, India, Japan, Malaysia, Mexico, Singapore, Taiwan, Thailand, the Philippines and Vietnam. As a result of the audits, 420 improvement recommendations were made and addressed through corrective action plans, most aiming to improve working conditions for value chain workers. Nokia aims to close audit findings within six months of audit completion; in 2024, 38% of corporate responsibility audit findings were closed within this time. Beyond in-depth audits, 469 online assessments with EcoVadis were completed, and 84% of Nokia suppliers covered by a valid EcoVadis assessment had a satisfactory score, with below-expectation scores addressed through improvement requests. Findings related to working time, wages, health and safety and forced labor risk were the most frequent in 2024. Example non-compliances addressed included child and juvenile labor (intern policy gaps), forced labor (new employees paying 40 RMB, or 2.1% of base salary, for a health check), health and safety PPE issues, excessive overtime, and remuneration deficits.

Reference: page 158

Nokia's targets reflect due diligence programs addressing forced labor, health and safety, remuneration and working time. The overall supply chain target is 80% of suppliers achieving a satisfactory sustainability score (aggregated weighted share) in supplier performance evaluations based on corporate responsibility on-site audits, EcoVadis, CDP and conflict minerals; in 2024, 78% of suppliers received a satisfactory score, on track. For 3TG traceability and conflict-free status, the 2025 target is 98% traceability to smelter level and conflict-free status of smelters, with extended due diligence for cobalt, mica, aluminum and copper; in 2024 Nokia achieved 87% traceability, not on track. For supplier Health and Safety maturity, the target is 100% H&S Recommended or Preferred supplier status by 2030, with 16% of relevant suppliers meeting this status in 2024, on track. The zero fatal incidents target for own workforce, suppliers and third-parties was not achieved, with 6 work-related fatal incidents (0 own workforce, 5 contractors or subcontractors, 1 third-party). Own workforce LTIFR improved to 0.085 and TRIFR to 0.244.

Reference: page 163

Nokia has specific policies and procedural documents relevant to the key affected communities it may impact. These include Nokia's Code of Conduct, the Human Rights Policy, and the Stakeholder Engagement Mode of Operation. Together they underline Nokia's commitment to providing products and services that expand opportunities to communicate and contribute to fundamental rights such as free expression, privacy, access to information, exchange of ideas and economic development; ensuring freedom of expression and preventing transgression of other human rights through human rights due diligence; and ensuring a systematic approach to how Nokia engages, directly or indirectly, with different stakeholder groups. Indigenous peoples are mentioned in Nokia's Stakeholder Engagement Mode of Operation, and respect for their rights is covered by the general principles in the Nokia Code of Conduct. As part of monitoring compliance with the Human Rights Policy, Nokia's Human Rights Due Diligence (HRDD) process is used to help ensure freedom of expression. The double materiality assessment found freedom of expression to be a material sub-topic, with a positive material impact for affected communities.

Reference: page 163

Nokia is usually one or more steps removed from direct engagement with affected communities but aims to ensure their views and needs are considered in business decisions. It achieves this through legitimate representatives and credible proxies such as Non-Governmental Organizations and multistakeholder groups, for example working with UN Women on gender topics and with UNICEF and local NGOs at grassroots level. Nokia obtains guidance from NGOs for its social impact programs, providing insight into which communities or regions to focus on for digital skills. The Vice President Sustainability and sustainability team in the Legal, Compliance and Sustainability function hold operational responsibility for this engagement. Traditionally, when a customer (telecommunication operator) implements a new network, the operator takes responsibility for related community and stakeholder engagement and identifies areas lacking coverage as part of network planning, also taking into account Indigenous Peoples land use rights where applicable. Where Indigenous Peoples are involved, such as networks for Native Americans, it is common practice to engage with their leaders directly or through an operator. Effectiveness is assessed by tracking and reporting outcomes from social programs, verified through Business for Societal Impact.

Reference: page 172

The processes Nokia has in place and the channels available for affected communities to raise concerns and have them addressed are described in the section Business Conduct (ESRS G1), under Reporting channels and investigations process. Because Nokia delivers digital connectivity solutions and its double materiality assessment identified only a positive material impact for affected communities, with no material risks or opportunities identified, the grievance and remediation mechanisms are handled through Nokia's general reporting channels and investigation processes rather than a community-specific remediation channel. Engagement with affected communities and civil society directly contributes to how Nokia builds and designs its social programs, from initial planning to final follow up and impact outcomes, so that the programs better respond to the most salient challenges, needs and opinions of communities.

Reference: page 163

In 2024, Nokia invested about EUR 6.5 million in communities around the world. Nokia's Social Impact Program works at global, regional and local levels, with experts volunteering time and skills to provide technology training, often with customers and partners during a network rollout. In March 2024, Nokia and UNICEF finalized their 2.5-year social innovation and entrepreneurship program in Morocco, aimed at empowering less advantaged young people aged 15 to 24, particularly girls, toward self-employment. Nokia also closed a pilot program with UNICEF in Senegal, begun in 2023, introducing digital education and coding for students and teachers in public schools. Nokia expanded its collaboration with UN Women across five regions and ran the Nokia University Donations program funding research into 6G, AI, sensing and quantum technologies. Programs focus on digital inclusion and connectivity, particularly targeting the unconnected or underserved, and generally last between 1 and 3 years. Nokia created the Nokia Donations Framework, and the Donations and Sponsorships Committee reviews donations annually.

Reference: page 164

Nokia's target reflects its commitment to provide digital connectivity solutions and expand opportunities to communicate, contributing directly to freedom of expression. One key digital inclusion target, set at the end of 2021, is to harness Nokia's technology, capabilities and funds to improve the lives of 1 500 000 people through social digitalization projects, digital skill building, and connecting the unconnected and underserved by 2025 (base year 2022). During 2024, Nokia reached 112 453 reported direct beneficiaries, 14% less than 2023, driven partly by fewer beneficiaries reported from programs in India and ongoing corporate programs focused on smaller groups. The current cumulative reported direct beneficiaries total 803 987, so the target is not expected to be achieved by 2025 and is reported as not on track. Annual results were 560 702 in 2022, 130 832 in 2023 and 112 453 in 2024. Progress is measured by gathering data annually from NGOs and internal owners, reviewed and verified by an external agency (Business for Societal Impact, B4SI) using a 4-eyes review.

Reference: page 166

Nokia's Code of Conduct and Human Rights Policy show Nokia's commitment to ensuring the technology it delivers supports freedom of expression rather than hindering it. Nokia's robust Human Rights Due Diligence (HRDD) process further aims to minimize the risk of violation of freedom of expression for consumers and end users through the potential misuse of Nokia technology. The HRDD process is a non-commercial, cross-company investigative process that is pre-emptive and rigorous, used before any sale is made while also attempting to ensure compliance with Nokia's Human Rights Policy. The double materiality assessment identified access to quality information and freedom of expression as material sub-topics, both positive impacts. Nokia sells network infrastructure solutions to Communication Service Providers (telecommunication operators), cities and authorities, and vertical industries or enterprises including mining, oil and gas, agriculture, manufacturing, logistics and defense sectors, directly to CSPs and via system integrators or third-party companies. Nokia does not sell its products directly to consumers. The Nokia Stakeholder Engagement Mode of Operation standard operating procedure details roles, responsibilities, key stakeholders and reporting.

Reference: page 167

Nokia's end users are communication service providers and enterprise customers, so regular customer engagement processes apply. Nokia's account teams in business groups are accountable for customer sales and hold operational responsibility for ensuring this engagement happens. Nokia does not have direct engagement with consumers as it rarely operates the networks, but rather enables the communication service provider to offer consumer and end-user services over the network equipment Nokia supplies. When a customer implements a new network, the customer (telecommunication operator) takes responsibility for related community and stakeholder engagement, with rare exceptions in particular in Asia, where Nokia has taken some responsibilities such as site certifications and keeping the local community informed. The operator identifies areas with lack of coverage and uses this in network planning. Nokia customer account teams work through customers who have direct relationships to the communities and consumers. Nokia also collaborates with organizations such as the Global Network Initiative to help ensure the positive impact of technology on consumers, and engages with other NGOs discussed under Affected Communities (ESRS S3).

Reference: page 172

The processes and channels available for consumers and end-users to raise concerns and have them addressed are described in the section G1 Business Conduct, under Reporting channels and investigations process. Because Nokia does not sell directly to consumers and rarely operates the networks, concern-raising for consumers and end-users is handled through Nokia's general reporting channels and investigation processes. Nokia carries out a Human Rights Due Diligence process to help ensure freedom of expression by limiting the potential for misuse of its products. Human rights due diligence actions are applied globally across Nokia and may impact customers, end users, consumers and Indigenous populations, and can lead to potential adjustments to products where needed, supporting the communication service provider in enabling freedom of expression for the end users and consumers who use their services.

Reference: page 167

Nokia carries out a Human Rights due diligence process to help ensure freedom of expression by limiting the potential for misuse of its products, applied globally and potentially impacting customers, end users, consumers and Indigenous populations, which can lead to adjustments to products where needed. For social programs Nokia implements connectivity and digital skill programs through NGOs and other partner organizations across all seven regions where Nokia operates. Examples of connectivity solutions include an optical, IP and fiber broadband network deployed in the Amazon rainforest connecting unconnected communities to multi-gigabit broadband, and Nokia's Rural Connect solution delivering high-speed internet to areas where fiber is difficult to deploy. With Nokia's Fiber-to-the-Home (FTTH) technology, Nokia helps operators connect more people to broadband. In 2024, mobile broadband subscriptions in Nokia radio customers' networks increased by 349 million, and Nokia connected 39 million Fiber-to-the-Home subscribers since the beginning of 2023, beating analyst expectations. Effectiveness is checked annually using GSMA data for the subscriptions target and twice a year for the FTTH target.

Reference: page 167

Nokia has set a target to help its customers connect the next 2 billion, measured by the number of subscriptions in Nokia radio customers' networks by 2030 (base year 2021). The target was set based on the successful achievement of Nokia's previous connectivity target, and Nokia reports on mobile broadband subscriptions as a more measurable number than connected people. Because the target is based on mobile broadband and operator subscriptions reported through the GSMA, there was no direct engagement with consumers in setting it. In 2024, mobile broadband subscriptions in Nokia radio customers' networks increased by 349 million, with cumulative progress of 1 121 million over 2021 to 2024; the target is on track, with an average yearly increase of over 223 million subscriptions. Nokia has a second target related to its Fiber-to-the-Home technology, to connect 140 million new subscribers by 2030 (base year 2023). Nokia connected 39 million Fiber-to-the-Home subscribers since the beginning of 2023 and is on track. This target uses both actual and forecast data from the iDate market analyst report.

Reference: page 171

Nokia's culture of integrity is driven by the Nokia Code of Conduct, available in a web-based format in 20 languages, which sets out 14 key compliance policy statements. Everyone in the company must review and acknowledge the Code annually as part of mandatory compliance training. A separate Code of Ethics applies to the President and CEO, the Chief Financial Officer, and the Corporate Controller. Nokia is consistently recognized as one of the World's Most Ethical Companies by Ethisphere. The corporate culture is supported by the annual mandatory Ethical Business Training course; in 2024, 98% of employees completed it against a 95% target. The 2024 survey showed 83% of employees report to a line manager who discusses ethics and compliance with their team. Compliance is overseen by the Ethics and Regulatory Compliance team of about 50 professionals, led by the Chief Compliance Officer, who has direct access to the Audit Committee. Policies are disseminated through online and live training, an intranet repository, and quarterly communications.

Reference: page 174

Nokia applies sustainability criteria for the qualification and selection of suppliers and requires the fulfillment of sustainability obligations through supplier contracts. Suppliers must adhere to Nokia's Third-Party Code of Conduct and are provided Nokia Supplier Requirements, which include the Responsible Business Alliance Code of Conduct plus Nokia-specific requirements covering the environment, health and safety, security and privacy, risk management, labor and human rights, and ethics and anti-corruption. Nokia requires its Tier 1 suppliers to apply and cascade the same requirements to their own suppliers and to conduct due diligence. In 2024, Nokia conducted business with around 9,300 suppliers, and 80% of total supplier spend was distributed across around 400 suppliers. Supplier monitoring, assessment and auditing activities include an on-site corporate responsibility audit program, EcoVadis sustainability assessments, an in-house Supplier Health and Safety Maturity Assessment, and CDP Supply Chain Climate Change and Water Security assessments. Failing to meet sustainability requirements affects the supplier's future business prospects with Nokia.

Reference: page 170

Nokia operates a robust global Anti-Corruption Program managed by an Anti-Corruption Center of Excellence, which conducts due diligence of commercial third parties, customers, and high-risk suppliers. The Code of Conduct covers anti-corruption and bribery, dealing with government officials, improper payments, and working with third parties. Training specific to anti-corruption and bribery is included in the annual mandatory Ethical Business Training course required of 100% of employees, including administrative, management and supervisory bodies and the Board of Directors, with targeted focused training assigned to high-risk populations such as site acquisition and customer-facing sales teams. Suppliers and commercial third parties must complete a risk-based due diligence vetting process, with a three-year re-screening required. The Third-Party Code of Conduct includes an anti-corruption section. Dedicated investigators sit independently within the Ethics and Regulatory Compliance function and are independent of the chain of management of the subject and the person raising the concern. All suspected breaches of anti-corruption and anti-bribery procedures are investigated, with disciplinary action where violations are found.

Reference: page 178

Nokia discloses confirmed incidents through its ethics and compliance data table. In 2024, the Investigations Group received a total of 923 concerns (1,047 in 2023), of which 384 were integrity concerns investigated as suspected violations of the Code of Conduct. The Ethics and Regulatory Compliance function conducted 384 investigations in 2024 (482 in 2023). Of these, 165 allegations were substantiated with cause found after investigation in 2024 (156 in 2023). Specific to corruption and bribery topics, reported concerns in 2024 included 9 for improper payments (8 in 2023) and 4 for dealing with government officials (1 in 2023). Corrective actions for substantiated cases across all categories included 12 employee dismissals on grounds of violation of the Code of Conduct (22 in 2023) and 30 written warnings (37 in 2023). Detailed root cause analysis is conducted for substantiated cases, and anonymized case examples and annual investigation statistics by category are shared internally and externally.

Reference: page 174

Nokia treats its business partners with respect and endeavors to pay suppliers' valid dues on time per contractual obligations and country regulations. Suppliers must follow defined guidelines for correct and timely invoice submission, and e-invoicing is mandatory or preferred in all countries where legally allowed. Nokia's standard payment terms are 90 days at the minimum, plus days for invoice receipt and the periodic payment cycle per the respective supplier contracts. Terms of 90 days or more cover approximately 62% of annual invoices by value in 2024. For the balance 38% of supplier invoices, including small and medium enterprises, payment terms are based on contractual negotiations and/or country legislation. The number of outstanding legal proceedings for late payments was 0 in both 2024 and 2023. Nokia notes it is in the process of establishing a mechanism to measure the average time it takes to pay an invoice from when the contractual or statutory payment term starts, in line with the ESRS disclosure requirements.