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Anti-bribery and Corruption Policy

Effective May 29, 2024

1 Audience

In this document, HMD/our/we/Company refer to HMD Global Oy (“HMD”) and all its affiliates. The Anti-bribery and Corruption policy is global and covers all HMD legal entities and applies to all employees, directors and external persons working on HMD’s behalf. It is the employee’s responsibility to be aware of the content and any subsequent changes and be fully compliant with this policy.

2 Objective

Corruption is the single greatest obstacle to economic and social development around the world. It distorts markets and stifles economic growth. It debases democracy and undermines the rule of law. HMD has zero tolerance for bribery and other corrupt activities. This policy aims to prohibit any corrupt activity and establish guidelines and procedures to prevent and detect corruption within our organization and among our business partners.

We conduct our business with integrity, following the HMD Code of Conduct and the highest ethical standards, and in compliance with anti-corruption laws, rules, and regulations. All forms of corruption, including but not limited to extortion, cronyism, bribery, facilitation payments, nepotism, and fraud, are strictly forbidden.

3 Review Mechanism

This policy is reviewed annually and updated as needed.

4 Conduct-specificguidance

4.1 Bribery

Bribery means offering, giving, soliciting, or receiving anything of value in order to gain any improper and/or unfair advantage (e.g. to obtain or retain business, to influence the actions of a third party).

The concept of “anything of value” is not limited to payments. It also covers gifts, entertainment, donations, scholarships, jobs and anything else that brings a benefit to the receiver (which might be the person who is able to provide the improper advantage or someone close to them).

HMD’s zero-tolerance approach in relation to bribery covers all types of bribery, including when no government employee is involved (commercial bribery).

HMD employees and representatives may not give, promise, offer, or authorize the provision of anything of value to anyone to obtain or keep business or to secure any improper advantage.

HMD employees and representatives may not request, accept, or agree to accept anything of value from anyone in return for providing business or any improper advantage.

4.2 Facilitation payments

A facilitation payment (also known as “grease” payment) is typically a small payment to a government official to ensure or speed up a routine government action (such as processing papers, issuing permits, granting visas or similar official actions).

HMD does not allow its employees, directors and representatives, or anyone acting on HMD’s behalf, to make facilitation payments. HMD recommends anyone who is asked directly or indirectly to make a facilitation payment to immediately end the conversation and contact the Ethics & Compliance team ([email protected]) for guidance. However, if the employee, director, representative or person acting on behalf of HMD is in a situation where failure to make a facilitation payment would put them or their family’s safety at risk, the payment should be made to avoid immediate harm and, as soon as reasonably practical, the incident should be reported to the line manager and to [email protected] with accurate information about:

  • The context in which the payment took place o Rationale for the payment
  • Who made the payment
  • Recipient of the payment
  • Amount and currency paid
  • Name of the person(s) witnessing the payment

4.3 Gifts, travel and hospitality

Gifts, travel expenses, entertainment and hospitality may be considered a bribe if done to obtain an improper advantage.

To avoid even an appearance of improper behavior:

  • follow the HMD Code of Conduct, the Gifts and Hospitality Policy and the Travel & Expense Policy;
  • bear in mind that our partners and suppliers may also have company specific guidelines for gifts, travel, and hospitality that we need to respect. If in doubt, ask clarification on such guidelines from your counterparty and consult the Legal team ([email protected]) to ensure you are aware of any contractual terms regarding the supplier or partner, which may include terms regarding acceptable gift, travel and entertainment practices; and
  • remember that most countries have strict rules applicable to gifts and hospitality to government officials. More details of HMD’s guidance on that can be found in the Gifts and Hospitality Policy.

4.4 Hiring and employment decisions

Nepotism is the act of using power or influence to get jobs or other benefits for members of one’s family.

Cronyism is the act of using power or influence to get jobs or other benefits for friends and trusted allies.

HMD does not allow nepotism or cronyism in recruitment and employment decisions (such as promotions and salary increase).

All candidates will be asked to report any potential conflict of interest. All potential hires should go through HMD’s normal employee hiring process, and no candidate should receive preferential treatment or consideration based on a request of a third-party or employee. For further information refer to HMD Recruitment and Onboarding Policy.

4.5 Donations and sponsorship

Charitable donations and sponsorships may be considered a bribe if made to obtain an improper advantage or favor. There is also the risk that HMD employees involved in the sponsorship or donation receive a kickback or a personal benefit.

All charitable donations and sponsorships are subject to pre-approval as described in the Gifts and Hospitality Policy. In the case of donations, HMD will conduct a due diligence to ensure that the donations are used for their intended purpose.

HMD shall continuously review its charitable donations and sponsorships to ensure that they align with the HMD Code of Conduct and do not create conflicts of interest or the appearance of impropriety.

All sponsorships must be documented through an agreement duly approved by Legal. For further info please refer to HMD Spend Policy. All donations must be properly documented and accounted for.

4.6 Fraud and Extortion

Fraud is the use of deceptive practices to obtain anything of value or gain unfair advantage or benefit. Extortion is the use of threats, intimidation, or coercion to obtain anything of value from another person or entity. HMD will not engage or allow any third party acting on its behalf to engage in any kind of fraud or extortion.

5 Third Parties

Corrupt practices by third parties such as suppliers, sales representatives, customs brokers and consultants acting on HMD’s behalf or having access to funds provided by HMD can expose HMD to investigations, legal action, penalties and reputational damage.

All third parties providing services or goods to HMD must adhere to HMD’s Supplier Code of Conduct and the business owner engaging with the third-party is responsible for communicating those requirements to them.

HMD employees must follow all applicable third-party due diligence processes, which are designed to ensure that that the party does business in an ethical manner, before doing business with a third party.

6 Books and records

All payments, gifts, reimbursements, donations and sponsorships must be accurately recorded in a timely manner and in reasonable detail in the corporate records. No undisclosed or unrecorded accounts may be established for any purpose. False, misleading, incomplete, inaccurate, or artificial records are prohibited.

The creation of side agreements is prohibited, and the contracts signed by HMD must reflect the totality of our agreements and must include all terms and conditions as agreed by both HMD and our counterparties.

7 Roles and Responsibilities

All employees shall:

  • familiarize themselves with this policy;
  • comply with the requirements of this policy and other applicable policies.

HMD line managers shall:

  • ensure that employees understand and are committed to this policy;
  • ensure that all reasonable steps are made to eliminate violations against this policy;
  • ensure that all employees are regularly made aware of their obligations in relation to this policy;
  • take action and report if they become aware of any violations of this policy.

Human Resources and senior management shall:

  • ensure that policies and procedures are regularly reviewed and (if necessary) amended;
  • ensure that guidance and training is provided to employees regarding this policy;
  • ensure that this policy is made available to all employees internally;
  • ensure that managers are aware of their obligations and responsibilities in relation to this policy.

8 Communication

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.

9 Disciplinary Measures

Employees who violate this policy shall be subject to discipline up to and including termination of employment.

10 Reporting Channel and Whistleblower protection

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 Up¹, 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:

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