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Anti-discrimination and anti-harassment policy

Effective May 16, 2024

1 Audience

In this document, HMD/our/we refer to HMD Global Oy (“HMD”) and all its affiliates. The Anti-Discrimination and Anti-Harassment Policy (“this policy”) builds on the HMD’s Code of Conduct and describes further our requirements towards a safe and respectful working environment and prohibits any forms of discrimination and harassment.

This policy applies to all HMD employees and directors while at work regardless of location. As such, employees must follow this policy at HMD offices and any other location they visit or pass by for work purposes, such as partner offices, manufacturing centers, warehouses, retail stores, event, conference and team building venues, restaurants where they are having business meals, hotels and airports during work trips etc.).

This policy also applies to suppliers, customers, partners, contractors and any other visitor while at HMD premises.

2 Review Mechanism

This policy is reviewed annually and updated as needed.

3 Purpose

HMD believes that every employee should be treated with dignity and respect. The company is committed to the principles of equal employment opportunity and fair treatment of all individuals and complies with all applicable laws which prohibit discrimination and harassment in the workplace. It is the policy of HMD not to discriminate against any individual on any basis and not to tolerate harassment on any basis, including but not limited to harassment based on any protected characteristic.

HMD strictly prohibits discrimination in all terms, conditions, or privileges of employment, including recruiting, hiring, assignment, compensation, benefits, promotions, demotions, transfers, discipline and termination, and any form of harassment, based on race, color, religion, national origin, citizenship, gender (including pregnancy, childbirth and related medical conditions), age, disability, sexual orientation, marital status, military/veteran status, genetic information, voluntary association or non- association with trade union/bargaining agreement or any other characteristic protected by applicable law, or collective bargaining agreements where applicable.

Retaliation is strictly forbidden. No adverse employment action will be taken against any person for exercising his or her rights under applicable law, for making a good faith complaint, or assisting in an investigation under this policy. Retaliation for any such activity is strictly prohibited. HMD expects all employees and directors to support the implementation of this policy and to comply with all applicable laws prohibiting discrimination, harassment, and retaliation in the workplace.

4 Definitions

Discrimination means unequal, unfair or less favorable treatment of employees or job applicants based on certain characteristics protected by law. Even though the protected characteristics vary from country to country, HMD has chosen the ones listed in Section 3 (Purpose) as the bare minimum and will also take into consideration in each country other characteristics that are legally protected.

Harassment can be verbal or physical conduct that creates an intimidating, hostile, or offensive working environment or interferes with an individual’s work performance.

Harassment may include, but is not limited to slurs, derogatory remarks or jokes, written or graphic material that denigrates or shows hostility to an individual.

Sexual Harassment is a sub-type of harassment and consists of unwelcome sexual advances, requests for sexual acts or favors, or other physical or verbal conduct or visual displays of a sexual nature when: 1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment (e.g. is or appears to be a determining factor for hiring, compensation, advancement, promotion or retention); or 2) submission to or rejection of such conduct by an individual is used as a basis for making employment decisions concerning the individual (i.e. treating a staff member favorably for engaging in such conduct or unfavorably for refusing to engage in the conduct); or 3) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive environment.

Sexual harassment may include a range of behaviors and may involve individuals of the same or different gender. These behaviors may include, but are not limited to: unwanted sexual advances; subtle or open pressure for sexual favors; sexual jokes; insinuations; advances or propositions; verbal abuse of a sexual nature; graphic commentary about an individual’s body, sexual talent or sexual deficiencies; suggestive staring; whistling; touching, pinching, assault, forced sexual acts; display of sexually suggestive objects or pictures; and other physical or verbal conduct of a sexual nature.

5 Consensual Relationships between Employees

Consensual relationships between employees must be reported through the conflict-of- interest declaration form for HMD to verify the existence of any apparent, actual or potential conflict of interest. HMD reserves the right to reassign at its own discretion employees in consensual relationships with other employees to mitigate the apparent, actual or potential conflict of interest, or if there is concern the relationship will impact the performance, career, or comfort level of any staff member, including the couple.

All employees in consensual relationships with other employees are expected to exercise the utmost discretion, professionalism and decency at work.

6 Reporting and Corrective Actions

HMD will take necessary actions up to and including termination of employment against any employee that has been involved in perpetrating or supporting harassment or discrimination. Inducing another person to commit any of the prohibited acts under this policy or actively cooperating in committing such acts also amounts to harassment or discrimination.

Where an employee or representative of third party such as a vendor or customer is involved in the alleged harassment or discrimination, HMD will investigate the case and, if necessary, share information with the third party’s management or with law enforcement.

Nothing in this policy shall prevent the reporter or victim from pursuing legal remedies or other type of resolution in accordance with applicable laws.

HMD expects all perceived incidents of discrimination, harassment, or retaliation to be reported immediately, regardless of their severity, and regardless of the alleged offender’s identity or position. Individuals who believe they have witnessed or been the victim of any form of discrimination, harassment, or retaliation should discuss their concerns with their manager, Regional HR Lead or with another member of Human Resources. In addition to or instead of approaching the persons listed above, the employee can use the Speak Up channel described in Section 10 to share the concerns.

All non-frivolous complaints will be investigated promptly and fully. Such investigation will typically include interviews of the person(s) making the complaint, the person(s) accused of discrimination or harassment, and other person(s) who may have relevant knowledge while protecting the identity of the complainant to the extent possible.

If HMD finds that prohibited conduct has occurred, it will take effective and appropriate remedial action. Such action can include discipline up to and including suspension or termination of any employee found to have violated this policy.

Any employee who willfully makes a false allegation or false statement under this policy will be subject to appropriate disciplinary action, which may include suspension or termination of employment. Any threats or attempts at retaliation must be reported to the Line Manager or any member of HR immediately so that corrective actions can be taken as prescribed in this section.

All complaints of discrimination or harassment and any information received during the course of the investigation and the resolution of the investigation will be kept strictly confidential and made available for review only by those with a legitimate need to know, as determined by HMD in its sole discretion, unless otherwise required by law or in case information needs to be shared with the third party that employs the offender or law enforcement. All personnel, including the person making the complaint, who are involved in the investigation are expected to use discretion and maintain the confidentiality of information and documents generated or discussed during the investigation. This provision is not intended to restrict an individual’s ability to exercise his or her rights under applicable law.

HMD encourages individuals who believe they are being subjected to harassment or discrimination to advise the offender(s) promptly that the behavior is unwelcome and request that it is discontinued. That is not, however, a requirement to make a complaint, and is not a substitute for the complaint procedure described above.

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, employees 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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