Effective January 30, 2024
Policy approved by HMD CEO and Board of Directors
At HMD Global we are committed to ensuring we meet the highest standards on human rights. We also expect 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. We perform regular risk based sanctions screening of the third parties we conduct business with against various Human Rights related sanctions lists. We are certified for ISO9001:2015 and we perform ISO9001:2015 internal audits to our own operations. To ensure ongoing standards we perform regular Manufacturing Process Audits (MPA) and Corporate Social Responsibility (CSR) audits to safeguard compliance to industry standards and requirements. We participate on the yearly Joint Audit Co-Operation (JAC) CSR audits conducted by 3rd party auditors for our Original Design Manufacturers’ manufacturing facilities. We are also targeting to be ISO14001:2015 certified by the end of 2020.
At HMD Global, we strive to meet the highest standards across all our operating practices. As part of our ongoing monitoring and reviewing of internal processes and compliance, we have engaged with Ernst & Young Oy to conduct a Human Rights Risk Assessment with a focus on supply chain and field force sales promotion activities. The assessment will have an emphasis on risks surrounding child labour, modern slavery, forced labour, working conditions and also other important areas, including discrimination, and will work to identify, evaluate and manage key risks. It is expected to be completed in Q3 2020.
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 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 Human Rights
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 UN’s Guiding Principles on Business and Human Rights; The International Labour Organisation’s (ILO) Declaration of Fundamental Principles and Rights at Work; Electronic Industry Citizenship Coalition (EICC) Code of Conduct and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprise.
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 are suppressed; so too is our ability to improve. We as an organisation support those who report wrongdoing or supposed wrongdoing and we ask our suppliers to follow this vision.
HMD is aware of the challenges to people’s privacy rights. We will work to protect the security of our products and services against these risks.
Infringements on people’s right to freedom of speech and supressing 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. The responsibility for any abuse of human rights rests with those that conducted the act but ignoring the act and those affected is just a much; an abuse.
2.1 Modern Slavery
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.
The greatest challenge facing organisations, in all industries, is that these activities are often hidden or hard to spot. We are against slavery in all its forms. We believe that people should always be free to choose when, where and who they work for. We do not condone anyone who traps, compels or forces another person to work; on our behalf, or in our supply chain. This applies also for anyone who is aware of such behaviour and who does nothing to stop it.
We support the UK Modern Slavery Act and agree to 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 on our findings and we wish to tackle this issue transparently, honestly and completely. Our 8 key rules in relation to Modern Slavery should be followed always, both internally and by our suppliers.
No one working anywhere in our supply chain should be forced or bonded through debt to work. Indentured labor, involuntary prison labor, slavery or human trafficking shall not to be used. No one should be required to pay recruitment fees or any related fees to secure employment. No one should have their freedom of movement restricted unreasonably and they should be free to leave or terminate their work at any time. No one should have their personal documentation taken from them, such as; passports, work permits or government-issued identification as a condition of employment. No one should be forced or made to feel obligated to work. In addition, they should never work “in kind” where their hours are not documented and paid for. All employees should have an employment contract that is signed by both themselves and their employer. The contract should define the terms and conditions of employment covering at least their working hours and guaranteed wage, overtime rates of pay and compensation, payment and frequency of payment and their notice period. No disciplinary actions should ever result in deductions from an employee’s wages. We ask anyone involved in our company directly or indirectly to respect human rights and to report any suspected violation of the UK Modern Slavery Act to us through our Speak Up – Channel. 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.
2.2 Responsible Sourcing of Minerals
As stipulated in 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 sourcing 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 make 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.
3 Labour Practices
Our employees are what make us the business we are. Our collective values create the culture in which we operate and we want that culture to be one of inclusion, creativity, enthusiasm and pride.
Our employees, contractors, job applicants, suppliers, partners and anyone who encounters our company should never subjected to abuse, bullying or discrimination of any kind. No one should be judged or treated differently due to a person’s race, sex, religion, marital status, pregnancy, nationality, ethnicity, disability, sexual orientation, expression and any other characteristic that leaves a person feeling unfairly treated.
No one working for HMD should be expected to work for longer than they are contractually obligated and any overtime is recorded and restricted in relation to local laws and regulations. Our employees are regularly, timely and in full compensated for their work in conjunction with all applicable wage 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 any 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 is 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 important to us and we are committed to the Convention on the Rights of the Child and expect our suppliers to make the same commitments. No one under the 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 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 endeavour.
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