Effective 27 May 2024
HMD Global Oy (“HMD”) is the largest European mobile phone manufacturer. Founded in Espoo, Finland, we are a collective of passionate and experienced people including some of the most talented and well-recognised leaders in the mobile industry today. We started our operations in December 2016, when we entered into licencing agreement with Nokia Technologies for global rights for the Nokia brand in mobile phones and tablets for a period of 10 years.
Our aim is to create amazing mobile technology for everyone. We have been designing and delivering trusted and innovative products under the iconic Nokia brand; products that are created to meet the diverse needs of global consumers, that are useful for everyone and that make life more exciting and inspiring for these consumers and our shared communities. In 2023, we introduced our new multi-brand strategy which means that we will launch new HMD branded and white label devices in 2024.
As a business, we have high integrity on ethical, legal and statutory topics. We are passionate about creating value for people, partners and the planet.
This statement is made pursuant to the UK Modern Slavery Act 2015 and the California Transparency in Supply Chains Act 2010. This statement sets out the steps HMD is taking to ensure that slavery and human trafficking is not taking place in its supply chains or any parts of its business.
We regularly review, mitigate and maintain a risk map of identified various human rights related risks including modern slavery risks and have established processes and policies to mitigate the risks and to make sure that incidents are actioned in a timely manner. During 2023, we updated our Human Rights and Labour Policy and separated our Environmental Policy from our Health and Safety Policy as we identified that the combined policy did no longer serve its purpose. We also updated both our Code of Conduct and Supplier Code of Conduct during 2023. After updating the Supplier Code of Conduct, we trained our internal sourcing and quality managers on the policy and extended this training to our original design manufacturer (ODM) partners, which also concluded the training.
All relevant requirements are explained to the ODM partners as part of the onboarding process, and regular audits are performed by us and third-party auditors to ensure compliance with the requirements.
In the end of 2023, we had 550 employees in 35 countries worldwide. The number of employees has slightly reduced from 2022 due to streamlining and developing the company structure. Our employees always have the right and freedom of association, peaceful assembly, protest and the right to collective bargaining. Everyone should feel empowered to communicate honestly with management regarding working conditions without fear of discrimination, harassment, intimidation, penalty or reprisal as a consequence. Our suppliers follow the same principles and allow their workers to freely associate with the right to collective bargaining.
In 2023, HMD launched a new Diversity, Equality, and Inclusion Council (“DEI Council”). The DEI Council is a task force made up of diverse employees from across the business who help drive organizational change and provide focus on DEI strategic initiatives. We will leverage their diverse perspectives to improve organisational performance and create a more diverse and inclusive work environment.
The DEI Council also launched a mandatory company-wide “Unconscious Bias” training in the end of 2023. The overall aim of the course was to help individuals at HMD to begin to get an understanding of unconscious bias and a wider awareness of unconscious bias in daily behavior.
In 2023, we organized multiple trainings for our employees and partners. These included the above-mentioned Supplier Code of Conduct training for our internal sourcing and quality managers and our ODM partners, and Unconscious Bias training for our employees, organized by our DEI Council. On top of this, we trained our internal employees on various topics, including Sustainability, Conflict of Interest and our Code of Conduct. Trust and integrity are key pillars of HMD business, and our Code of Conduct training included several different themes, including ethics, forced labour and whistleblowing.
We work closely with our key stakeholders with regards to Human Rights risks. This risk assessment connects into our regular risk management processes. We have a dedicated risk management tool that we use for all risk management.
We have been auditing our ODM partners in China, Vietnam and India since 2020 and in Bangladesh since 2022. The Bangladesh manufacturing partner only manufactures devices for the Bangladesh market. In 2023, we continued to audit new ODM factories that manufacture HMD devices to ensure our high standards are supported. We audited three additional factories in China and based on the audits we could confirm that all factories’ certifications for ISO45001 and OHSAS 18001 were valid. We use a 3rd party auditor to audit our global device ODM factories as per the JAC/SA8000 requirements. In total, we concluded six 3rd party JAC audits in 2023 and 14 HMD organized quality audits.
All ODM partners are rated based on their audit performance, and improvements are tracked continuously. We have a 3-year audit plan, and the audit schedule is created based on the previous audit rating. The audit assessment requirements include freedom of association, discrimination, wages and compensation, working hours, disciplinary practises, business ethics, environment, child labour & juvenile workers, forced labour and health and safety. In 2023, we were pleased to report that we had no child or forced labour incidents found from our audits with our manufacturing partners.
HMD started manufacturing smartphones in Europe in 2023. This decision is aligned with our commitment to invest in security, technology and manufacturing processes that make our devices more secure and longer lasting, keeping sustainability in mind.
We received our initial ISO14001 Environmental Management system certification in 2020 and we have been able to maintain it through 2023. We also continued maintaining our ISO9001 certification that we have had since 2018. We are also happy to report that we were able to maintain our ISO27001 certification in 2023 that we first received in 2022. In 2023, we started working towards ISO 45001 certification for sustainable procurement, which further demonstrates our commitment to sustainability, and ISO 27701, which is the privacy extension to the Information Security Management System certification.
In 2023, we maintained our Platinum level scoring for Ecovadis. The overall score is based on our company’s commitment to Labour & Human Rights, Sustainable Procurement, Ethics and the Environment. This means our company is in the top 1% of businesses audited for their commitment to sustainable practices in the manufacturing of communications equipment.
We have continued to publish Ecoprofiles for all our device models on our webpages.
Our journey of measuring GHG emissions began in 2018 when we initiated the measurement of our Scope 3 emissions from the transportation of our products to our customers. We joined the CDP (Carbon Disclosure Project) in 2020. Since then, we have intensified our efforts to measure our emissions in order to clearly define a robust sustainability strategy that is fit for the future. In 2022, we partnered with an accredited third-party to validate our measurement processes based on science-based targets. The results of this emissions study for 2020 and 2021 were published in 2022. We have since committed to conducting this assessment on an annual basis.
In 2023, we joined SBTi and committed to setting near-term company-wide emission reduction targets in line with climate science through the SBTi. In the same year, we made our first disclosure of emissions via CDP.
HMD commits to reducing absolute Scope 1, 2, and Scope 3 GHG emissions from purchased goods and services by 42% by 2030, from a 2022 base year.
We are committed to disclosing our GHG reduction progress with CDP in the future.
In 2023 we published our third UNGC report.
As part of our regular control activities, we conduct risk-based sanction screening to new vendors and customers, and ongoing sanctions screening for all already onboarded third parties. The sanctions screening includes several sanction lists in relation to forced labour and human rights abuse, including but not limited to the UK Sanctions List, U.S. Consolidated Screening List, WMD Trade Control Designations (OFAC), United Nations Consolidated List and the EU Consolidated List.
Our Ethics & Compliance whistleblowing channel is available for anyone to report any concerns within the company. The channel is currently available in English. However, if someone would issue a report in any other language, we would obtain translation support to handle the matter in the employee’s native language. The channel allows anonymous reporting. Concerns may also be freely escalated directly to our Legal team, HR or any member of the HMD Management.
To date, there have been no retaliation claims made against HMD by the reporters of ethical concerns.
We expect our suppliers to maintain programs that ensure their employees and suppliers have access to confidential and anonymous reporting channels, as well as protection in place for acts of whistleblowing. Our suppliers shall have in place a clear, visible and communicated process for anyone working at their facility to be able to raise concerns without fear of retaliation.
During our 6th operating year, we continued working with activities for preventing modern slavery and ensuring compliance with our HMD Code of Conduct and associated policies.
We introduced a new training platform for our employees, and we introduced several new trainings.
In 2022, we continued auditing work with our ODM partners. We re-emphasized our CSR requirements towards our ODM partners, which are also explained during all new ODM onboarding process. In 2022 we were pleased to report that we had no child or forced labour incidents found from our audits with our manufacturing partners.
We received our initial ISO14001 Environmental Management system certification in 2020 and we have been able to maintain it through 2022 as well as continued maintaining our ISO9001 certification that we have had since 2018. We are also happy to report that in 2022 we received ISO27001 certification.
In 2022, we received first time Platinum level scoring for Ecovadis. The overall score is based on our company’s commitment to Labour & Human Rights, Sustainable Procurement, Ethics and the Environment. This means our company is in the top 1% of businesses and 98 percentile of companies audited for their commitment to sustainable practices in the manufacturing of communications equipment. This was a significant achievement and really highlighted the steps we have been taking as a company, demonstrating our commitment to people and to the planet.
We continued to follow the Human Rights & Labour Policy from 2020 and Environmental, Health & Safety Policy in addition to HMD’s Code of Conduct and Supplier Code of Conduct Policies. They were still considered to be up to date. These requirements are explained to the original design manufacturers as part of the onboarding process and regular audits are performed by us and third-party auditors to ensure compliance to the requirements.
In 2021, we continued auditing work with our ODM partners, located mainly in China. We conduct regular CSR audits to ensure that no child labour cases occur in the region. We have zero tolerance for such activity. All ODMs are rated based on their audit performance, and improvements are tracked continuously. As an example, the audit assessment requirements include freedom of association, discrimination, wages and compensation, working hours, disciplinary practises, business ethics, environment, child labour & juvenile workers, forced labour and health and safety.
We received our initial ISO14001 Environmental Management system certification in 2H 2020, and continued maintaining our ISO9001 certification that we have had since 2018. In 2021 we were working towards ISO27001 certification for 2022.
In May 2021, we received for the first time Gold level Ecovadis scoring. The overall score is based on our company’s commitment to Labour & Human Rights, Sustainable Procurement, Ethics and the Environment. HMD Global is in the top 6% of companies rated by Ecovadis in the communication equipment manufacturing industry.
We joined global Ecorating initiative. Since 2021 Ecoratings or environmental profiles for all of our devices can be found on our website. This enables operators and their customers to evaluate the sustainability of mobile devices and work towards a more sustainable future.
We joined UN Global Compact during 2020. We published our first UNGC report during 2021.
During our fourth operating year, we continued working with activities for preventing modern slavery and ensuring compliance with our HMD Code of Conduct and associated HMD Corporate Social Responsibility policies in our business and supply chains. Our main activities included the following:
In 2020 HMD published Human Rights & Labour Policy and Environmental, Health & Safety Policy in addition to HMD’s Code of Conduct and Supplier Code of Conduct Policies. These requirements are explained to the original design manufacturers as part of the onboarding process and regular audits are performed by us and third-party auditors to ensure compliance to the requirements.
We worked closely with our key stakeholders with regards to Human Rights risks. In 2020 we have conducted a comprehensive human rights risk assessment with EY (Ernst & Young) with focus on Telecommunications Equipment and Electronic Sectors specific human rights risks and the human rights risks in countries where we have original design manufacturing partners and sales field force activities. Study included assessment for human rights risks specific to forced labour and modern slavery, child labour, working conditions and wages and discrimination. This risk assessment connects into our regular risk management processes.
In 2020 Code of Conduct live online training was organized for all employees and temporary workforce in close co-operation with our key partner Nokia. During the training employees were able to ask questions and clarify any unclear aspects for example concerning their own role. Training recording is available for all new joiners. Training included various key ethics & compliance aspects including human rights, fair employment and health, safety and labour conditions.
In order to meet the standards set out in our policies, our Leadership Team has defined the objectives and KPIs to ensure that our way forward is clear for CSR matters and that the progress can be measured.
In addition to the above actions, we continue to work towards achieving the highest EcoVadis Gold level by the end of 2020.
During our third operating year, we continued working with activities for preventing modern slavery and ensuring compliance with our HMD Code of Conduct and associated HMD Corporate Social Responsibility policies in our business and supply chains. Our main activities included the following:
In addition to our current strict policies relating to environmental, social and human right matters, which are explained in more detail below, we are preparing new policies to improve gender equality and promote diversity and inclusivity. We also regularly review and maintain a risk map for identifying modern slavery risks and have established processes and policies to mitigate the risks and to make sure that incidents are actioned in a timely manner.
We continuously provide Code of Conduct related trainings to employees and monitor that all employees attend such trainings. In addition to providing trainings, we offer different advice channels and fully support acts of whistleblowing as an essential action in the last line of assuring our compliance as an ethical and legally conforming business. We promote ethical and compliant culture.
In 2019 we made the strategic decision to focus on key geographies and introduced a multi-ODM model. We regularly assess and audit our Original Design Manufacturing suppliers including CSR topics. We are working with our partners and suppliers to prevent and uncover any modern slavery abuses that may occur. KPIs.
In order to meet the standards set out in our policies, our Leadership Team has defined the objectives and KPIs to ensure that our way forward is clear for CSR matters and that the progress can be measured.
In addition to the above actions, we continue to work towards achieving the highest EcoVadis Gold level by the end of 2020.
During our second operating year, we continued working with activities for preventing modern slavery and ensuring compliance with our HMD Code of Conduct and associated HMD Corporate Social Responsibility policies in our business and supply chains. Our main activities included the following:
Policies in relation to slavery and human trafficking. We have a series of rigorous policies and procedures in place to ensure that environmental, social and human rights matters are considered with the utmost importance, such as HMD Code of Conduct, HMD Supplier Code of Conduct, Business Ethics Policy, Human Rights and Labour Policy and Environmental Health and Safety Policy.
HMD provided several Code of Conduct related trainings to employees, including trainings on data privacy for both internal staff and our suppliers, anti-bribery and corruption, anti-harassment and discrimination, controllership and information security and speaking up about any ethical concerns.
In 2018, we audited both our Original Design Manufacturing suppliers and our own operations to ensure the compliance of our agreed Corporate Social Responsibility policies, including manufacturing process audits, ISO audits and audits within the scope of the global Joint Audit Cooperation (JAC).
In April 2018, we implemented the whistleblowing channel called Speak Up for raising ethical concerns. The channel allows also anonymous reporting where legislation permits anonymous reports. All employees were provided training on the process of raising concerns and the company investigation process, and line managers were provided with training on how to support employees to raise concerns. In November 2018 the Speak Up channel link was published on HMD Global web pages to also allow HMD suppliers and partners to report ethical concerns.
In April 2018, HMD received the ISO9001 certification. The certification was the result of a successful completion of an external audit that ensured that all of our internal and external processes meet the required quality management system standards. We are also working on achieving the ISO14001 certification for our environmental management system and our target is to get certified in year 2020.
In 2018, we also reached EcoVadis Silver level and we are thus ranking in the top 30% of EcoVadis medal-holders. The EcoVadis Corporate Social Responsibility assessment is an evaluation of how well a company has integrated the principles of CSR into their business and management system. You can learn more from here. We continue to build on our CSR policies and the actions we take to enforce such policies by striving further to achieve the EcoVadis Gold level.
In addition, we executed the European and USA Take Back programs, in order to avoid waste and to ensure that the products we manufacture receive an environmentally friendly treatment. We also launched new web pages to ensure up-to date communication on environmental matters and our actions to reduce the environmental impact of our products. Visit the webpages here.
HMD started its operations in December 2016. With regards to ensuring that slavery and human trafficking is not taking place in any of our supply chains, and in any part of our own business, we have taken the following actions during our first operating year: We have launched our Code of Conduct Policy and provided several mandatory employee trainings on both Nokia Code of Conduct for Nokia’s partners and our own HMD Code of Conduct and associated HMD Corporate Social Responsibility policies, such as: - Business Ethics Policy - Human rights and Labour Policy - Supplier Code of Conduct Policy - Conflict Mineral Policy - Environmental, Health and Safety Policy.
We communicate our Supplier Code of Conduct Policy to the suppliers we choose to work with, and in formal agreements we enforce requirement to follow all applicable laws and regulations. Internally, we have established Regional Compliance Committees who oversee the compliance activities in the regions where we operate. Furthermore, we have established Global Compliance Committee who oversees the compliance activities globally.
Our Code of Conduct principles ensuring that slavery and human trafficking is not taking place are as follows:
We want to be a company that empowers people; a company that brings enjoyment and solutions to their everyday lives. We stand firmly by The Universal Declaration of Human Rights (UDHR) and their work in protecting people’s rights. We do not tolerate, facilitate or contribute to any activity that could contribute to conflict or an abuse of human rights. Extra vigilance is essential in areas of the world where the laws or enforcement of them is weak to ensure we are still acting in line with our commitment to international standards such as the UDHR. Therefore, it is essential for us to strive for a transparent supply chain in which materials, goods and services are sourced responsibly and anyone associated with this activity is respected.
We are in full support of the UK Modern Slavery Act and we agree to publish a statement of our action plans, progress and challenges annually. 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. These actions are against our principles, illegal and immoral. The greatest challenge facing organisations, in all industries and in all areas of the world, is that these activities are often hidden or hard to spot. We are committed to report on our findings and we endeavour to tackle this issue transparently.
We believe that people should always be free to choose when, where and who they work for. We do not accept anyone who traps, compels or forces another person to work; on our behalf, or in our supply chain. This also applies to anyone who is aware of such behaviour and who does nothing to stop it. Please report any such abuse or suspicion of possible abuse through [email protected].
How we cooperate with our partners (suppliers, distributors, consultants etc.) has a direct impact on how our organisation is viewed. We expect professionalism and honesty from ourselves and our partners. We look to build productive relationships with our suppliers and we must aid them in achieving the high standards that we set ourselves. We expect a third party operating on our behalf to respect ethics and legal practices. We prohibit the creation of side agreements and ensure our contract documents reflect the totality of our agreements and they include all terms and concessions as agreed to by both us and our counterparties.
We are a culturally rich organisation that operates on a solid foundation of mutual respect in which employment, is always a choice. In building our approach to labour practices, we have followed the guidance of the International Labour Organisation (ILO) an internationally recognised body that “promote rights at work, encourage decent employment opportunities, enhance social protection and strengthen dialogue on work-related issues”. For industry specific guidance, we refer to the Electronic Industry Citizenship Coalition (EICC). We are committed to adhere to employment and labour laws and regulations wherever we operate. These include minimum wage requirements, maximum working hours regulation, minimum rest day requirements, privacy, banning child labour, young worker protection, banning compulsory labour, regulation related to immigration, collective bargaining, freedom of association, anti-discrimination as well as further employment rules and regulations.
Our Human Rights and Labour Policy contains — in greater detail — our approach, guidelines, procedures and standards that aid HMD's employment decision making.
Employment is a choice and should create value for the employee as well as the employer. Our stance of being an employer of choice means that forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery or human trafficking is forbidden not only in our premises but in those of our suppliers. Our employees conduct their work voluntarily and they are free to leave or terminate their employment. Our workers are never required to surrender any government-issued identification, passports or work permits as a condition of employment nor should any employee be required to pay recruitment fees or related fees either to HMD or to an agent working on our behalf. As part of our hiring process, employees are provided with written employment agreements where applicable containing a clear description of the terms and conditions of their employment.
We provide a supportive environment in which young professionals can learn and develop their skills. No one under the working age, per local regulations, is employed by HMD and we pass this requirement on to our suppliers and other partners. Where local regulations are not in place, we follow the EICC guidance regarding the minimum working age. We believe that helping young workers develop their skills and gain valuable experience is important and such programs should always comply with laws and regulations. Young workers should be protected from dangerous work tasks and must not work night time hours. Wherever we operate we comply with local laws and regulations.
We believe that productivity is best created with healthy and meaningful work that is fairly paid. Our employees are compensated for their work in conjunction with all applicable wage laws, including those related to minimum wages, overtime hours and legally mandated benefits. We operate within the ILO guidelines on working hours where laws and regulations are insufficient. We expect our contractors and suppliers to respect and follow local laws and regulations. Where local laws and/or enforcement is weaker than the EICC’s Code of Conduct, we expect our contractors and suppliers to follow the standards set by the EICC.
We support our employees right to bargain collectively and ensure their rights are being met. Our employees are free to associate with labour 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. Our suppliers shall follow this same stance and allow their workers to freely associate and give them the right to collective bargaining.
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