Policy approved by HMD CEO and Board of Directors

HMD is committed to international and industrial provisions as well as applicable laws related to conflict minerals. In building this Conflict Mineral Policy we follow the guidance of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas as well as the guidance of Conflict-Free Sourcing Initiative (CFSI). We require our suppliers to trace the origins of all products containing conflict minerals as describe in this Conflict Mineral Policy, to ensure they are sourced from sustainable and socially responsible sources only.

1 Scope In this document, HMD/our/we refer to HMD global Oy (“HMD”) and all its affiliates. The Conflict Mineral Policy which builds on HMD’s Code of Conduct, is global and covers all Company legal entities and applies to all employees’ and external persons working on Company’s behalf. It is the employee’s responsibility to be aware of the content and any subsequent changes and be fully compliant with the Conflict Mineral Policy. Moreover, HMD also expects our suppliers, partners, and other representatives to adhere to the same high standards of ethical behaviour and legal compliance when they are working on our behalf.

2 HMD Conflict Mineral Policy

HMD is committed to international and industrial provisions as well as applicable laws related to conflict minerals. In building this Conflict Mineral Policy we follow the guidance of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas as well as the guidance of Conflict-Free Sourcing Initiative (CFSI). We require our suppliers to trace the origins of all products containing conflict minerals as describe in this Conflict Mineral Policy, to ensure they are sourced from sustainable and socially responsible sources only.

The term “conflict minerals” used here refers to a group of minerals/metals often referred to as 3TGs which are; columbite-tantalite (coltan) (or its derivative tantalum), cassiterite (or its derivative tin), gold and wolframite (or its derivative tungsten) that are sourced from the Democratic Republic of the Congo (DRC) and neighbouring countries. The mining of these metals has the potential of funding military conflicts and human rights violations. In these countries where conflicts are ongoing legitimate trade is very difficult to achieve. Therefore, we need to work collectively to ensure we are operating responsibly. We are monitoring the work of the Responsible Raw Material Initiative (RRMI) and their study into Cobalt on the child labour, human rights and environmental issues and will act in accordance with its recommendations.

The risks involved in sourcing these materials are vast. From the mines through the transportation routes and trading centers to the bigger distributors and on to our manufacturing partners. For this reason, we must operate as a committed member of a wider system. As we have such a distance from these sources we look to ensure a reliable “chain of custody” otherwise known as a document trail that contains details of every person or company that have been in possession of materials throughout the supply chain.

We require our suppliers to report on where the 3TG metals in our products were sourced and that they maintain their due diligence on this data for 5 years. We also require that they commit to sourcing materials that did not directly or indirectly contribute to conflict, human rights violations or environmental degradation. We will make our progress available to our partners with the aim of building awareness, transparency and capacity of conflict-free materials in our supply chain. We also look to review our approach regularly regarding our Conflict Mineral Policy to ensure we continue to operate in a sustainably, ethically and socially responsible manner.

The topics contained in this Conflict Mineral Policy are also enforced in our Supplier Requirements which is a contractually binding document between HMD and our suppliers. We also conduct due diligence as per the recommendations made in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas. For our suppliers to meet our expectations we require that they conduct the same due diligence of their supply chain.

3 Reporting & Guidance

Your understanding of our policies and our Code of Conduct is crucial; as is your right to voice your opinions, seek advice or report non-conformance. There may be aspects of this policy that do not cover each ethically or legally challenging decision you face. If ever you are in doubt about any aspect of this Code of Conduct, please seek advice through any of our channels listed in this document. You are obliged to report any suspected or actual violation of this policy or to seek advice if there is even a potential of violation. HMD fully support acts of “Whistleblowing” as an essential action in assuring our compliance as an ethical and legally conforming business. Any issues can be reported internally and externally through our Speak Up channel portal:

https://secure.ethicspoint.eu/domain/media/en/gui/104743/index.html

3.1 Non-Retaliation

We promote a business culture in which our employees are comfortable in questioning behaviors they feel are not consistent with our policies or our Code of Conduct, without any fear of retaliation. Trust is an essential aspect of our business. Anyone found to retaliate or take adverse action against an employee or other person for raising in good faith a concern covered under our policies or our Code of Conduct shall be subject to discipline up to and including termination of their employment.

3.2 Confidential Reporting Channels

To maintain the trust and confidence of our employees we offer confidential reporting channels. These channels ensure that we never put our employees in a position where they are uncomfortable reporting matters that are of importance to us. We extend this protection on to our supplier’s employees or anyone who reveals breaches of our policies or our Code of Conduct to us. In addition to approaching a member of HMD management, Legal Counsel, Compliance or Human Resources team you can also report through Speak Up channel:

https://secure.ethicspoint.eu/domain/media/en/gui/104743/index.html

3.3 New Requirements Compliance

We continuously keep track of related new regulatory and industrial requirements, and make sure we are compliant with those. For example, we are compliant with the new EU regulation on conflict minerals (The European Union Conflict Minerals Regulation (CMR)) that came into force 1.1.2021. The regulation requires EU companies in the supply chain to ensure they import these minerals and metals from responsible and conflict-free sources only.