Effective 30 May 2024
In this document, HMD/our/we refer to HMD Global Oy (“HMD”) and all its affiliates. The Human Rights and Labour 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 Human Rights Policy. Moreover, HMD also expects suppliers, partners, and services providers to adhere to the same high standards of ethical behaviour and legal compliance. The Supplier Code of Conduct outlines HMD’s expectations in relation to Human Rights and compliance with said Code is a requirement for all our suppliers.
This policy is reviewed annually and updated as needed.
HMD wants to be a company that empowers people; a company that brings enjoyment and solutions to their everyday lives. We are committed to the Universal Declaration of Human Rights. In building our strategy regarding Human rights and labour practices, we have also followed the guidance of the following documents:
We agree without question that people have a right to free speech and freedom of assembly. When people’s right to challenge things they disagree with is suppressed, so is the ability to improve their lives. We strive to create a work environment where anyone can raise concerns without fear of retaliation, and ask our suppliers to do the same.
Infringements to people’s right to freedom of speech and suppressing people from sharing ideas or denying them access to information is wrong. We all deserve the same chances; we all deserve the same rights, and we all deserve the same respect.
HMD is aware of the challenges technology poses to people’s privacy rights. Privacy protection is a key element in the development of our products and services. We have obtained ISO27001 Information Security Management System certification in 2022 for having implemented robust information security practices. In 2023 we have obtained ISO 27701 Privacy certification, after demonstrating our ability to effectively manage privacy risks, implement privacy controls, and ensure the confidentiality, integrity and availability of personal data.
We engage a third-party auditing company to perform regular CSR audits per SA8000 requirements on our ODM partners’ factories to make sure our suppliers are following the high standards for human rights and labour practices described in the Supplier Code of Conduct. We also conduct internal quality audits.
Modern Slavery is an umbrella term that includes slavery, human trafficking, forced or compulsory labour, and servitude. Modern Slavery as a term refers to a situation where a person is coerced, deceived, taken unwillingly and/or indebted into a position where they feel trapped, held, compelled, or forced to work.
We are against Modern Slavery in all its forms, any action to disguise Modern Slavery, and failure to report it to the authorities. We believe that people should always be free to choose when, where and for whom they work.
We support the UK Modern Slavery Act and publish a statement of our action plans, progress and challenges annually. We are working with our partners and suppliers to uncover any abuses that may occur. We are committed to report our findings and we wish to tackle this issue transparently, honestly and completely. These are the 8 key rules in relation to Modern Slavery that should be followed always, both internally and by our suppliers:
We ask anyone involved in our company directly or indirectly to respect human rights and to report any suspected violation of the Modern Slavery Act to us through our Speak Up - Channel¹. HMD is committed to not impeding access to state-based judicial or non-judicial or other available mechanisms for persons reporting concerns of adverse human rights impact and does not require affected individuals or communities participating in a grievance/mediation process to permanently waive their legal rights to bring in claim through a judicial process as a condition of participating in the grievance/mediation process.
As stipulated in the HMD Code of Conduct Policy, HMD is committed to international and industrial provisions related to minerals. We require our suppliers to trace the origins of all minerals included in our products to ensure they are sourced from sustainable and socially responsible sources only. We have created our Conflict Minerals Policy to underpin our strategy with regards sourcing materials from the Democratic Republic of the Congo (DRC) and neighbouring countries. As mentioned in the United Nations’ Guiding Principles “the risk of gross human rights abuses is heightened in conflict affected areas”. The challenge facing HMD and other electronics manufacturers is that these resources are scarce and, in some cases, limited to these areas.
We follow closely 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 Conflict-Free Sourcing Initiative (CFSI). We are committed to avoiding the use of materials that directly or indirectly contribute to conflict, violation of human rights or environmental degradation. For us to take this stance we require our suppliers to commit to the same values and help us wherever possible to avoid the use of such materials in our products.
We have also adopted the CMRT Conflict Mineral Reporting Template for all our phone and tablet models.
The Conflict Minerals Reporting Template (CMRT) is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) that facilitates the transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. The template also facilitates the identification of new smelters and refiners to potentially undergo an audit via the RMI’s Responsible Minerals Assurance Process (RMAP).
HMD is not just a company; we are a community united by the power of diversity, equity, and inclusion. Every team member’s contribution is valued and everybody can expect to be treated with respect and openness.
Our employees, contractors, job applicants, suppliers, partners and other stakeholders should never subjected to abuse, bullying or discrimination of any kind. No one should be judged or treated differently due race, color, religion, marital status, gender (including pregnancy, childbirth and related medical conditions), national origin, citizenship, age, disability, sexual orientation, military/ veteran status, genetic information, voluntary association or non-association with trade union/ bargaining agreement or any other characteristic protected by the applicable law or collective bargaining agreement, where applicable.
No one working for HMD should be expected to work for longer than they are contractually obligated. Overtime is duly recorded and does not exceed the limits established by the applicable local laws and regulations. Our employees are regularly, timely and fully compensated for their work in conjunction with all applicable laws, including those related to minimum wages, overtime hours and legally mandated benefits. Our employees are regularly and timely provided with a salary statement that clearly indicates legitimate deductions. Our employment contracts (including minimum wage, maximum working hours and overtime pay/restrictions) adhere to local laws and regulations wherever we operate. Wherever local laws are lacking or not well enforced we operate within the ILO guidelines on working hours and our employees are never contracted to work more than 48 hours per week. We do not expect our employees to work for longer than they are contractually obligated, and overtime must be pre-approved by line manager and is restricted to a maximum of 12 hours per week. Overtime is also always paid at a premium rate.
We expect our contractors and suppliers to respect and follow local laws and regulations. Where local laws and/or enforcement are weaker than the Electronic Industry Citizenship Coalition (EICC) in their Code of Conduct, we expect our contractors and suppliers to follow the standards set by the EICC’s Code.
The banning of child labour and the protection of young workers are very important to us. We are committed to the Convention on the Rights of the Child and expect our suppliers to make the same commitment. No one under working age, per local regulations, is employed by HMD and we pass this requirement on to our suppliers. Where local regulations are not in place, the minimum working age is 15 or after compulsory education (whichever is greater). We believe that helping young workers develop their skills and gain valuable experience is important, but such programs should always comply with the applicable laws and regulations. Young workers should be protected from dangerous work tasks and must not work night-time hours.
Our employees are free to associate with labor unions as they see fit. They are also free to use collective bargaining as a means for protecting their rights as our employees and we respect their rights to peaceful assembly or protest. Everyone at HMD should feel able to communicate honestly with management regarding their work and working conditions without fear of discrimination, harassment, intimidation, penalty or reprisal. Any form of intimidation, harassment, retaliation or violence against workers seeking to exercise their freedom of association and collective bargaining rights is strictly forbidden. Our suppliers shall follow this same stance and allow their workers to freely associate and give them the right to collective bargaining.
We are aware that many of the labour issues related to our business will not necessarily occur within our operations where we have complete control but may occur elsewhere in our supply chain. We aim to build long and trusting relationships with our suppliers and as part of this relationship we set requirements for them to meet the same level of standards that we set ourselves, and we are committed to doing all we can to support them in this endeavor.
To further emphasize our strong commitment to Occupational Health and Safety topics, we pursued and obtained ISO45001 Occupational Health and Safety Certification for HMD Global during spring 2023.
All employees shall:
HMD line managers shall:
Human Resources and senior management shall:
This policy is made available to all employees in the internal Onboarding SharePoint site (or any other SharePoint site where policies might be stored in the future). Human Resources arranges regular training and guidance regarding this policy, and briefs new employees on the content of the policy during the onboarding process.
Employees who violate this policy shall be subject to discipline up to and including termination of employment.
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 to our supplier’s employees, our tier 2 suppliers’ 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, Compliance or Human Resources team you can also report anonymously via HMD Ethics channel called Speak Up², which is available from HMD Onboarding site and HMD internet pages.
HMD adheres to a strict policy of no retaliation. No reporter shall suffer any adverse consequence for raising a concern regarding potential violations of this policy or for refusing to engage in activities in violation of this policy. No report made in good faith should carry the threat of retaliation against the reporter.
¹ HMD SpeakUp channel available at: https://secure.ethicspoint.eu/domain/media/en/gui/104743/index.html
² HMD SpeakUp channel available at: https://secure.ethicspoint.eu/domain/media/en/gui/104743/index.html
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