UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD
SPECIALIZED DISCLOSURE REPORT


Nokia Corporation
(Exact name of the registrant as specified in its charter)


Republic of Finland
 
1-13202
 
N/A
(Jurisdiction of incorporation)
 
(Commission File Number)
 
(IRS Employer Identification No.)


Karakaari 7, P.O. Box 226
   
02610 Espoo, Finland
 
N/A
(Address of principal executive offices)
 
(Zip code)


Esa Niinimäki, Deputy Chief Legal Officer, Corporate
Telephone: +358 (0)10 448 8000, Facsimile: +358 (0)10 448 1003
(Name and telephone number, including area code, of the
person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

X
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

__
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ________.




Section 1 – Conflict Minerals Disclosure

Item 1.01
Conflict Minerals Disclosure and Report

Nokia Corporation (the “Company” or “Nokia”) invests in technologies important in a world where billions of devices are connected.
At the end of 2021 we had four business groups: Mobile Networks, Network Infrastructure, Cloud and Network Services and Nokia Technologies.

Products manufactured by Nokia, or for which Nokia contracted with third parties to manufacture, during the year ended December 31, 2021 contained columbite-tantalite (coltan) (or its derivative tantalum), cassiterite (or its derivative tin), gold or wolframite (or its derivative tungsten) (collectively, “Conflict Minerals”) necessary to the production or functionality of such products (such products containing Conflict Minerals, the “Products”).
Nokia has a policy which describes Nokia’s commitment to responsible minerals sourcing and measures taken to reach that goal. Nokia’s long-term commitment to sustainability and responsible sourcing has seen us take action individually and collectively to move this agenda forward in search of solutions. We have been members in joint industry efforts such as the Responsible Minerals Initiative (“RMI”), participants in the development and implementation of the OECD Due Diligence Guidance for Responsible Supply Chains together with other stakeholders, and we support various initiatives that seek to support the development of traceable, responsible trade in the Covered Countries (defined below) such as Public-Private Alliance for Responsible Minerals Trade.
Nokia has performed a reasonable country of origin inquiry that was designed to reasonably determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (the “Covered Countries”) or are from fully recycled or scrap sources. In the design of our reasonable country of origin inquiry and due diligence activities, we have aligned with the internationally recognized due diligence framework provided by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (OECD 2016). All businesses subject to the Rule are covered. 
As a downstream company, Nokia is many supply chain tiers away from mining activities and has no direct business relationship with mines or metal processing facilities. Nokia does not buy directly any mineral ores or even refined metals. Therefore, in order to conduct the reasonable country of origin inquiry, Nokia used a combination of actions. With direct suppliers the primary means for conducting the reasonable country of origin inquiry was through a supply chain survey using the RMI conflict minerals reporting template. In addition to engaging with direct suppliers, Nokia relies in its due diligence process on the information provided through multi-industry initiatives, such as RMI’s Responsible Minerals Assurance Process (“RMAP”) that aim to validate the mineral processing facilities as conflict-free.



The smelters and refiners process mineral ores into refined metals and deliver them further down the supply chain for inclusion in the components and parts used in final products. After this consolidation point in the chain it is very difficult to trace the origins of the minerals. Also, as there are a limited number of mineral processing facilities operating in the world compared to the high number of mineral origins globally, we believe it is the best level in the chain to concentrate validation efforts. Therefore, the progress made in the validation efforts of smelters and refiners as conflict-free are of great importance for all downstream companies having the same metals in their products.
Direct suppliers from all the affected sourcing categories that delivered parts for products manufactured or contracted to be manufactured during 2021 were in scope for the reasonable country of origin inquiry. Suppliers under phase-out were excluded from the scope. Products sourced from third parties and subsequently resold without influence by Nokia over the manufacturing or design of such products were not in the scope. Furthermore, Nokia applied certain threshold level of the respective supplier spend to exclude some of the low purchase suppliers from the scope.
Based on Nokia’s reasonable country of origin inquiry, we determined that a portion of the Conflict Minerals did originate from scrap or recycled sources.
Nokia also determined, based on the reasonable country of origin inquiry described above, that certain of the Conflict Minerals contained in products manufactured by Nokia or which Nokia contracted to be manufactured during the year ended December 31, 2021 originated in the Covered Countries.
For 2021, we determined that the Conflict Minerals used in Nokia’s products originated from the following countries:

Argentina, Armenia, Australia, Austria, Azerbaijan, Belgium, Benin, Bolivia, Botswana, Brazil, Bulgaria, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Costa Rica, Cote d'Ivoire, Cuba, Cyprus, Democratic Republic of the Congo, Djibouti, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, Hungary, India, Indonesia, Italy, Ivory Coast, Japan, Kazakhstan , Kenya, Kyrgyzstan, Laos, Liberia, Liechtenstein, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Montenegro, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Oman, Papua New Guinea, Peru, Philippines, Portugal, Russia, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Solomon Islands, South Africa, South Korea, Spain, Sudan, Suriname, Swaziland, Sweden, Taiwan, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Venezuela, Vietnam, Zambia, Zimbabwe.

Accordingly, Nokia is filing a Conflict Minerals Report, attached as Exhibit 1.01 hereto and which can also be found on its website:
https://www.nokia.com/about-us/sustainability/. This website is provided for convenience only, none of the information contained on the website constitutes a part of this filing and such information is not incorporated by reference herein.



A more detailed description of the due diligence undertaken by Nokia is provided in the Conflict Minerals Report attached as Exhibit 1.01.
Item 1.02
Exhibit

Nokia files, as Exhibit 1.01 to this Specialized Disclosure Report on Form SD, a Conflict Minerals Report for 2021.
Section 2 – Resource Extraction Issuer Disclosure
Not applicable.
Section 3 – Exhibits
Item 3.01
Exhibits

List below the following exhibit filed as part of this report.
Exhibit 1.01
Conflict Minerals Report as required by Items 1.01 and 1.02 of Form SD.




SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 
NOKIA CORPORATION
     
 
By:  
 /S/ STEPHAN PROSI
   
Stephan Prosi, Vice President, Corporate Controlling
     
     
 
By:
/S/ ESA NIINIMÄKI
   
Esa Niinimäki, Deputy Chief Legal Officer, Corporate
Dated: 24 May 2022
   







NOKIA CONFLICT MINERALS REPORT FOR 2021
24 May 2022
Introduction

Based on our reasonable country of origin inquiry, Nokia has reason to believe that certain of the Conflict Minerals1 necessary to the functionality or production of our products may have originated in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”) and may not have come from recycled or scrap sources. Accordingly, Nokia undertook due diligence measures on the source and chain of custody of these Conflict Minerals. In the design of our due diligence processes we have conformed to the internationally recognized due diligence framework provided by OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD 2016) (the “OECD Due Diligence Guidance”). The details of this alignment of our conflict minerals due diligence process with the OECD Due Diligence Guidance are provided in Table 1 below.

Table 1. OECD Due Diligence Guidance & related Nokia Due Diligence actions


OECD Due Diligence Guidance
Nokia Due Diligence Action
STEP 1. Establish strong company management systems
Adopt, and clearly communicate to suppliers and the public, a company policy for the supply chain of minerals originating from conflict-affected and high-risk areas. This policy should incorporate the standards against which due diligence is to be conducted, consistent with the standards set forth in the model supply chain policy in Annex II of OECD Due Diligence Guidance.
Nokia has a policy which describes its respective commitment to conflict-free sourcing globally, including responsible and conflict-free sourcing through legitimate trade from conflict-affected and high-risk areas and measures taken to reach that goal (referred to herein as the “Nokia Responsible Minerals Policy” or the “Policy”). It also sets out a commitment to identify, assess, mitigate, and respond to risks.
 
Nokia Responsible Minerals Policy (formerly Nokia Conflict Minerals Policy) has been communicated to suppliers when first released and thereafter in conjunction with the annual supply chain responsible minerals sourcing inquiry and related webinars.
 
The Nokia Responsible Minerals Policy is reviewed regularly and is publicly available on our website:
 
https://www.nokia.com/about-us/investors/corporate-governance/policies/
Structure internal management systems to support supply chain due diligence.
In order to support and oversee the implementation of the Policy, Nokia has set up a cross-functional Responsible Minerals Working Group that includes members with necessary competence from sourcing, operations, sustainability, legal, and reporting and government relations teams.
________________________
1 Columbite-tantalite (coltan) (or its derivative tantalum), cassiterite (or its derivative tin), gold and wolframite (or its derivative tungsten).




 
The supply chain inquiry is carried out through the internal responsible minerals sourcing deployment team in cooperation with a global network of sourcing managers, and the results are periodically reviewed with Sourcing and Quality leadership (Supply Quality Monthly Business Reviews and Supply Chain and Sourcing Sustainability Governance Team) and Sustainability Council (cross-functional committee for sustainability governance composed of group ESG management and senior leaders from business units).
 
Establish a system of controls and transparency over the mineral supply chain. This includes a chain of custody or a traceability system or the identification of upstream actors in the supply chain. This may be implemented through participation in industry-driven programs.
Nokia’s system of controls and transparency is a combination of internal activities, work with direct suppliers and reliance on joint industry programs such as the Responsible Minerals Initiative (the “RMI”). As an RMI member company, Nokia is familiar with the rigor and development of the audit protocol that led to the RMI Responsible Minerals Assurance Process in accordance with an internationally accepted standard: OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 2nd Edition. Furthermore, the mutual recognition between the RMI Responsible Minerals Assurance Process audit and the Responsible Jewellery Council’s Chain of Custody certification and London Bullion Market Association’s Responsible Gold Programme establish these programs as internationally accepted industry standards.
 
Nokia starts its reasonable country of origin inquiry by a scoping of its suppliers, for which the product data management system and spend data is used to determine which of the suppliers are relevant for the responsible minerals supply chain inquiry.
 
In order to identify the smelters and refiners in our supply chain and country of origin data, Nokia conducts a supply chain survey using the RMI conflict minerals reporting template and reviews gathered information against that provided by RMI and its Responsible Minerals Assurance Process (“RMAP”).
 
RMI publishes the Conformant Smelter and Refiner lists which represent the smelters and refiners that have successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment. The assessment evaluates the auditee’s due diligence systems and processes to conform with the RMAP standards. This assessment is done by an independent third-party audit. RMI also provides country of origin data for members, which has been aggregated due to confidential business information concerns (which conforms to the OECD Guidance specified in Step 5). This is reasonable because the country of the material’s origin is thoroughly examined in the audit process, even if the origin’s more specific location is not published. Therefore, reliance on the aggregated country list constitutes a reasonable inquiry into the material’s country of origin. The data on which we rely for certain statements in this conflict minerals report is obtained through our membership in the RMI.
In addition to RMI sources Nokia also conducts independent research into country of origin information for the smelters that are not yet part of RMI RMAP audit process.
 
To help to address risks beyond those associated with conflict, such as social, environmental and human rights risks, smelters are also requested to participate and update Risk Readiness Assessment of the RMI.




Strengthen company engagement with suppliers. A conflict minerals policy should be incorporated into contracts and/or agreements with suppliers. Where possible, assist suppliers in building capacities with a view to improving due diligence performance.
Nokia’s approach is to establish long-term relationships with suppliers, seek sustainable solutions, and work with suppliers to drive improvements. Nokia has incorporated the principles outlined in the Policy into Nokia Supplier Requirements which are part of Quality appendix to standard supplier agreements. Nokia reserves the right to assess its suppliers against its supplier requirements.
 
Nokia provides support for suppliers in the form of detailed feedback on their conflict minerals reporting template, and corrective action plans are agreed as necessary. Nokia also encourages suppliers to participate in and support multi stakeholder forums and conflict-free sourcing initiatives. Nokia has also conducted several dedicated information-sharing live webinar sessions and one-to-one sessions with suppliers to further explain our responsible minerals requirements and risk mitigation.
Establish a company-level, or industry-wide, grievance mechanism as an early-warning risk-awareness system.
Concerns and violations of the Policy can be reported to Nokia through our official grievance channels:
Email:  ethics@nokia.com
Online: https://nokiaethics.alertline.com
Phone: https://nokiaethics.alertline.com/clientInfo/7782/phone.pdf
 
Suppliers and other external parties are encouraged to contact their regular sourcing channel or Conflict-Free Sourcing team email (conflict_free_sourcing.team@nokia.com) if they wish to seek guidance on the application of the Policy approach, or if they wish to report suspected abuse. They, and other external stakeholders, may also report problems or concerns to the Nokia ethics alert line. At the industry level, grievances can also be reported to RMI’s Grievance Channel at: http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/. Nokia receives a periodic overview of the grievance received by RMI and considers this under risk management. In 2021 there were 17 grievances reported via RMI Grievance Channel which were all follow up grievances from issues reported in previous years and one grievance (follow up from 2020 incident) directly to Nokia. RMI grievances are reviewed in line with RMI Grievance handling process and direct grievance was addressed directly with the smelter who was requested to conduct additional due-diligence activities. Corrective actions requested from the smelter were followed up.
STEP 2. Identify and assess risk in the supply chain
Identify and assess risks in their supply chain as recommended in the Supplements.
As a downstream company Nokia is many supply chain tiers away from mining activities and has no direct business relationship with mining activities or metal processing facilities and therefore, in order to conduct its reasonable country of origin inquiry, Nokia uses a combination of actions both individually with direct suppliers, as well as multilaterally with industry peers and other stakeholders.
 
With direct suppliers, the primary means for conducting the reasonable country of origin inquiry survey through a supply chain using the standard industry conflict minerals reporting template (provided by RMI), with the aim of assessing the direct suppliers’ due diligence activities and identifying processing facilities and countries of mineral origin. Nokia assesses risks by reviewing supplier templates to understand their due diligence activities and identified processing facilities and countries of origin, and whether the minerals originated from recycled or scrap sources. In order to




 
improve data quality and completeness Nokia conducts several rounds of surveys with suppliers, provides feedback on supplier templates and agrees on corrective actions if necessary. Reminders are sent to non-responsive suppliers and an escalation process is enacted when there is slow progress on supplier side on improvements and meeting Nokia targets. Responsible minerals conformance status is also integrated into Supplier Performance Evaluation.
 
Nokia continues the risk assessment by comparing smelter data provided by suppliers to information provided by the RMAP and online research in order to verify whether the smelters and refiners have been validated as conflict-free or not and to identify the countries of origin of the minerals. In addition, broader social, environmental and human rights risks related to upstream sourcing are addressed via RMI’s Risk Readiness Assessment.
STEP 3. Design and implement a strategy to respond to identified risks
Report findings of the supply chain risk assessment to the designated senior management of the company.
In accordance with the Policy, the results of the annual supply chain inquiry and risks identified are reported to Sourcing and Supply Chain Leadership, Sustainability Council and Global Leadership Team.
Devise and adopt a risk management plan
To minimize the risk of tin, tantalum, tungsten or gold present in our products contributing to conflict in the Covered Countries and other Conflict-Affected and High-Risk Areas, we seek to conduct a reasonable country of origin inquiry on a regular basis, check and increase the number of validated smelters and refiners in our supply chain, approach smelters directly and consider other publicly available information about smelting operation and country of origin.
 
As part of risk management with our direct suppliers, we provide them feedback on the quality of their conflict minerals due diligence information and ask clarifying questions and demand corrective actions where necessary. We have set up informational calls with selected suppliers to help build their capacity, and we encourage our suppliers to participate in industry activities in order to learn and contribute.
 
We also conduct an audit program for the suppliers in higher risk countries, such as China on their due diligence process.
 
When suppliers have identified in their conflict minerals survey that some of the minerals originate from the Covered Countries and other Conflict-Affected and High-Risk Areas, we perform additional due diligence to find out as much as reasonably possible about the origins of the metals. This involves asking suppliers to identify the smelter or refiner that processed the material and checking whether it has been validated as conflict-free. We also liaise directly with smelters that have not yet been validated as conflict-free in order to request mineral origin information.
 
As part of our risk management we aim to source only from validated conflict-free smelters and refiners and are phasing out non-conformant smelters from our supply chain.
Implement the risk management plan, monitor and track performance of risk mitigation efforts and report back to designated senior management. This may be done in
Risk management plans, monitoring and performance tracking is done in close collaboration with Business Groups Sourcing organizations and followed up by the cross-functional responsible minerals working group that oversees the implementation of the




cooperation and/or consultation with local and central government authorities, upstream companies, international or civil society organizations and affected third-parties where the risk management plan is implemented and monitored in conflict-affected and high-risk areas.
Policy. The results are reported to Sourcing category leaders and also back to Sustainability Council.
 
Where risk incidents involve direct suppliers, we carry out risk management planning, monitoring and performance tracking through the sourcing managers’ network. In cases where risk incidents do not result in corrective actions taken to our satisfaction, it can ultimately result in termination of the business relationship. In 2021 we asked suppliers to remove 74 smelters that were not conformant to RMAP and LBMA programmes.
 
In cases where our regular supply chain inquiry indicates that a reported smelter is sourcing materials from the Covered Countries or other Conflict-Affected and High-Risk Areas, we undertake additional risk management activities, such as checking the reported mine of origin against industry data and public sources of information, and follow-up of the status periodically.
 
For smelter level and upstream related grievances, we use RMI Grievance process and Nokia channels. In 2021 there were 17 grievances reported via RMI Grievance Channel and 1 grievance directly to Nokia. RMI grievances were reviewed and addressed in line with RMI Grievance handling process and direct grievance was addressed directly with the smelter who was requested to conduct additional due-diligence activities which were implemented by the concerned smelter.
Undertake additional fact and risk assessments for risks requiring mitigation, or after a change of circumstances.
In 2021 Nokia also joined an industry online delegation to the DRC that included facilitated discussions with governmental leaders, NGOs and local business (as a follow up for the Public Private Alliance delegation visit to the DRC in 2019). We also helped to fund a local program dealing with expanding children's educational access and socioeconomic opportunities for their families and vulnerable women (including survivors of sexual violence); and work on women's leadership and reintegration into communities following sexual violence strongly related to the minerals mining and supply chain.
STEP 4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain
Companies at identified points (as indicated in the Supplements) in the supply chain should have their due diligence practices audited by independent third parties. Such audits may be verified by an independent institutionalized mechanism.
As the origin of Conflict Minerals cannot be determined after the ores have been smelted or refined, smelters and refiners are in the best position to determine the country of origin. Thus, the most important point in the supply chain for a downstream company to have third-party conflict-free validation is the smelter or refiner level. For that purpose, we make use of the cross-industry conflict-free smelter listing of the RMAP. The RMAP has agreed on mutual cross-recognition of gold refiner audits with London Bullion Market Association (“LBMA”) and Responsible Jewellery Council (“RJC”), and therefore refineries validated by those organizations are also considered to be conflict-free. Refineries validated by LBMA and
RJC are reflected in the RMI list of validated smelters and refiners. http://www.responsiblemineralsinitiative.org/smelters-refiners-lists/
 
We compare the aggregated smelter and refiner list of our supply chain against the validated smelter and refiner lists provided by the RMAP and LBMA. We encourage the non-validated smelters to enter into the program and start the process of validation through




 
our direct outreach to smelters as well as through the respective working group at RMI). Smelters that refuse to participate in the industry programme are asked to be phased out by our suppliers.
 
We also audit our suppliers on their conflict minerals related management system and due-diligence process. Such audits are conducted by an independent third-party audit company.
STEP 5. Report on supply chain due diligence
Companies should publicly report on their supply chain due diligence policies and practices and may do so by expanding the scope of their sustainability, corporate social responsibility or annual reports to cover additional information on mineral supply chain due diligence.
Nokia reports publicly on its due diligence policies and practices in its Form SD and Conflict Minerals Report filed with the US Securities and Exchange Commission, its annual sustainability report (Nokia People and Planet report), Modern Slavery Report and on its company website.


As a downstream company, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals. Our due diligence process is based on the necessity of seeking data from our direct suppliers and the direct suppliers seeking data within their supply chain to identify the original sources of the Conflict Minerals. We also rely to a large extent on information provided by independent third-party audit programs. Such sources of information may yield inaccurate or incomplete information.

RESULTS OF THE NOKIA SUPPLY CHAIN INQUIRY FOR 2021
In order to conduct the reasonable country of origin inquiry, Nokia started by determining the suppliers to be in scope for the supply chain inquiry. The analysis of the material content information gathered for all products led us to conclude that small quantities of the four metals in question are present in practically all parts and components used to manufacture products in our business (such as integrated circuits, connectors, resistors, hardware assembly components, inductive components, RF MW circuits, discrete semiconductors, and capacitors).

The product data management system was used to determine which of Nokia’s suppliers are relevant for the conflict minerals supply chain inquiry. Suppliers being phased-out and products sourced from third parties and subsequently resold by Nokia without influence over the manufacturing or design of such products were not in scope. Further, Nokia applied a spend threshold to exclude from the scope the suppliers accounting for relatively insignificant procurement spend.
The number of suppliers in the original scope for Nokia was 1320. Of these, 331 suppliers were above the supplier spend threshold applied by Nokia, in the aggregate representing 98% of supplier spend in original scope. Nokia approached these suppliers with the conflict minerals inquiry. The remaining suppliers were under threshold level or were in the phase-out process. The response rate for the suppliers surveyed was 99%. 54 of the suppliers surveyed did not supply materials containing Conflict Minerals.


Based on our due diligence efforts we found on a supplier level that, of the suppliers in scope:

99% of suppliers have adopted a Responsible/Conflict Minerals Policy (100% in 2020), 81% public and 19% not public.

Suppliers tracing all smelters (per mineral): tantalum 96%, tin 97%, tungsten 96%, gold 97%.

Suppliers with conflict-free status (per mineral, including conflict-free status of respective reported smelters): tantalum 96%, tin 96%, tungsten 94%, gold 94%.

Figure 1: Supplier smelter identification completion and Conflict-Free Status


Suppliers sourcing from the Covered Countries: 98% (2020: 99%)

In total, we have identified 337 smelters (308 in 2020) of the smelters:

71% of smelters have been validated by RMAP or mutually recognized programs (out of known smelters) (77% in 20202): gold 63%, tantalum 100%, tin 68%, tungsten 84%.

78% of smelters have been validated by RMAP or mutually recognized programs or are active in the validation process (out of known smelters) (80% in 2020): gold 67%, tantalum 100%, tin 83%, tungsten 94%. Several smelters that were validated as conformant previous year, have lost their conformance status due to updated compliance protocols and are working on required improvements. Although progress on smelter compliance level is hardly visible, number of suppliers that remain to report non-conformant suppliers is 10 (13 in 2020).

8% of the smelters who are currently not validated by RMAP or Active towards validation are either Recyclers, or where our due- diligence have shown there is no reason to believe they are sourcing from the Covered Countries and can be reasonably considered as conflict-free.

 
Conformant
Active
No participation
Total
Tantalum
36
0
0
36
100%
0%
0%
Tin
54
12
14
80
68%
15%
17%
Gold
109
6
57
172
63%
4%
33%
Tungsten
41
5
3
49
84%
10%
6%
Total
240
23
74
337
71%
7%
22%
100%


________________________
2 The number of identified smelters increased from 308 in 2020 to 337 in 2021




Figure 2. Conflict-Free validation status of the 337 identified smelters

In support of supply chain transparency, we disclose in the tables below: the processing facilities we have identified through our due diligence process as having processed conflict minerals contained in the products manufactured by Nokia and in products for which Nokia has contracted with third parties to manufacture. The processing facilities (including smelters and refiners) are listed on an aggregated basis per metal and classified within three categories – “validated”, “active”, and “no public participation in validation program”. Smelter validation status is based on Responsible Minerals Initiative data as of January 27, 2022.

Responsible Minerals Assurance Process (RMAP) or LBMA Conformant Processing Facilities
The smelters and refiners identified as part of our reasonable country of origin inquiry and validated as conformant according to RMAP protocol:
Metal
Smelter ID
Standard Smelter Name
Country Location
Gold
CID000015
Advanced Chemical Company
UNITED STATES OF AMERICA
Gold
CID000019
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
CID000035
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
CID000041
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Gold
CID000058
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
CID000077
Argor-Heraeus S.A.
SWITZERLAND
Gold
CID000082
Asahi Pretec Corp.
JAPAN
Gold
CID000090
Asaka Riken Co., Ltd.
JAPAN
Gold
CID000113
Aurubis AG
GERMANY
Gold
CID000128
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
CID000157
Boliden AB
SWEDEN
Gold
CID000176
C. Hafner GmbH + Co. KG
GERMANY
Gold
CID000185
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
CID000189
Cendres + Metaux S.A.
SWITZERLAND
Gold
CID000233
Chimet S.p.A.
ITALY
Gold
CID000264
Chugai Mining
JAPAN
Gold
CID000359
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF



Gold
CID000362
DODUCO Contacts and Refining GmbH
GERMANY
Gold
CID000401
Dowa
JAPAN
Gold
CID000425
Eco-System Recycling Co., Ltd. East Plant
JAPAN
Gold
CID000493
JSC Novosibirsk Refinery
RUSSIAN FEDERATION
Gold
CID000689
LT Metal Ltd.
KOREA, REPUBLIC OF
Gold
CID000694
Heimerle + Meule GmbH
GERMANY
Gold
CID000707
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
CID000711
Heraeus Germany GmbH Co. KG
GERMANY
Gold
CID000801
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
CID000807
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
CID000814
Istanbul Gold Refinery
TURKEY
Gold
CID000823
Japan Mint
JAPAN
Gold
CID000855
Jiangxi Copper Co., Ltd.
CHINA
Gold
CID000920
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
CID000924
Asahi Refining Canada Ltd.
CANADA
Gold
CID000929
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
CID000937
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
CID000957
Kazzinc
KAZAKHSTAN
Gold
CID000969
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
CID000981
Kojima Chemicals Co., Ltd.
JAPAN
Gold
CID001078
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Gold
CID001113
Materion
UNITED STATES OF AMERICA
Gold
CID001119
Matsuda Sangyo Co., Ltd.
JAPAN
Gold
CID001147
Metalor Technologies (Suzhou) Ltd.
CHINA
Gold
CID001149
Metalor Technologies (Hong Kong) Ltd.
CHINA
Gold
CID001152
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Gold
CID001153
Metalor Technologies S.A.
SWITZERLAND
Gold
CID001157
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Gold
CID001161
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
CID001188
Mitsubishi Materials Corporation
JAPAN
Gold
CID001193
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Gold
CID001204
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
CID001220
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
CID001236
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Gold
CID001259
Nihon Material Co., Ltd.
JAPAN
Gold
CID001325
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
CID001326
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
CID001352
PAMP S.A.
SWITZERLAND
Gold
CID001386
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Gold
CID001397
PT Aneka Tambang (Persero) Tbk
INDONESIA
Gold
CID001498
PX Precinox S.A.
SWITZERLAND
Gold
CID001512
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Gold
CID001534
Royal Canadian Mint
CANADA
Gold
CID001555
Samduck Precious Metals
KOREA, REPUBLIC OF



Gold
CID001585
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
CID001622
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
CID001736
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Gold
CID001756
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
CID001761
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
CID001798
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
CID001875
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
CID001916
Shandong Gold Smelting Co., Ltd.
CHINA
Gold
CID001938
Tokuriki Honten Co., Ltd.
JAPAN
Gold
CID001955
Torecom
KOREA, REPUBLIC OF
Gold
CID001980
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
CID001993
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
CID002003
Valcambi S.A.
SWITZERLAND
Gold
CID002030
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
CID002100
Yamakin Co., Ltd.
JAPAN
Gold
CID002129
Yokohama Metal Co., Ltd.
JAPAN
Gold
CID002224
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
CID002243
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Gold
CID002290
SAFINA A.S.
CZECHIA
Gold
CID002314
Umicore Precious Metals Thailand
THAILAND
Gold
CID002459
Geib Refining Corporation
UNITED STATES OF AMERICA
Gold
CID002509
MMTC-PAMP India Pvt., Ltd.
INDIA
Gold
CID002511
KGHM Polska Miedz Spolka Akcyjna
POLAND
Gold
CID002516
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Gold
CID002560
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Gold
CID002561
Emirates Gold DMCC
UNITED ARAB EMIRATES
Gold
CID002580
T.C.A S.p.A
ITALY
Gold
CID002582
REMONDIS PMR B.V.
NETHERLANDS
Gold
CID002605
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
Gold
CID002606
Marsam Metals
BRAZIL
Gold
CID002615
TOO Tau-Ken-Altyn
KAZAKHSTAN
Gold
CID002761
SAAMP
FRANCE
Gold
CID002762
L'Orfebre S.A.
ANDORRA
Gold
CID002763
8853 S.p.A.
ITALY
Gold
CID002765
Italpreziosi
ITALY
Gold
CID002777
SAXONIA Edelmetalle GmbH
GERMANY
Gold
CID002778
WIELAND Edelmetalle GmbH
GERMANY
Gold
CID002779
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Gold
CID002863
Bangalore Refinery
INDIA
Gold
CID002918
SungEel HiMetal Co., Ltd.
KOREA, REPUBLIC OF
Gold
CID002919
Planta Recuperadora de Metales SpA
CHILE
Gold
CID002973
Safimet S.p.A
ITALY
Gold
CID003189
NH Recytech Company
KOREA, REPUBLIC OF
Gold
CID003424
Eco-System Recycling Co., Ltd. North Plant
JAPAN



Gold
CID003425
Eco-System Recycling Co., Ltd. West Plant
JAPAN
Gold
CID003575
Metal Concentrators SA (Pty) Ltd.
SOUTH AFRICA
Tantalum
CID000211
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
CID000456
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
CID000460
F&X Electro-Materials Ltd.
CHINA
Tantalum
CID000616
XIMEI RESOURCES (GUANGDONG) LIMITED
CHINA
Tantalum
CID000914
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
CID000917
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
CID001076
AMG Brasil
BRAZIL
Tantalum
CID001163
Metallurgical Products India Pvt., Ltd.
INDIA
Tantalum
CID001175
Mineracao Taboca S.A.
BRAZIL
Tantalum
CID001192
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
CID001200
NPM Silmet AS
ESTONIA
Tantalum
CID001277
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
CID001508
QuantumClean
UNITED STATES OF AMERICA
Tantalum
CID001522
Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
CID001769
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
CID001869
Taki Chemical Co., Ltd.
JAPAN
Tantalum
CID001891
Telex Metals
UNITED STATES OF AMERICA
Tantalum
CID001969
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Tantalum
CID002492
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
CID002504
D Block Metals, LLC
UNITED STATES OF AMERICA
Tantalum
CID002505
FIR Metals & Resource Ltd.
CHINA
Tantalum
CID002506
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
CID002508
XinXing HaoRong Electronic Material Co., Ltd.
CHINA
Tantalum
CID002512
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
CID002539
KEMET de Mexico
MEXICO
Tantalum
CID002544
TANIOBIS Co., Ltd.
THAILAND
Tantalum
CID002545
TANIOBIS GmbH
GERMANY
Tantalum
CID002547
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
CID002548
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
CID002549
TANIOBIS Japan Co., Ltd.
JAPAN
Tantalum
CID002550
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Tantalum
CID002557
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
CID002558
Global Advanced Metals Aizu
JAPAN
Tantalum
CID002707
Resind Industria e Comercio Ltda.
BRAZIL
Tantalum
CID002842
Jiangxi Tuohong New Raw Material
CHINA
Tantalum
CID003583
RFH Yancheng Jinye New Material Technology Co., Ltd.
CHINA
Tin
CID000228
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
Tin
CID000292
Alpha
UNITED STATES OF AMERICA
Tin
CID000402
Dowa
JAPAN
Tin
CID000438
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
CID000468
Fenix Metals
POLAND



Tin
CID000538
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
CID000555
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Tin
CID000942
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
CID001070
China Tin Group Co., Ltd.
CHINA
Tin
CID001105
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
CID001142
Metallic Resources, Inc.
UNITED STATES OF AMERICA
Tin
CID001173
Mineracao Taboca S.A.
BRAZIL
Tin
CID001182
Minsur
PERU
Tin
CID001191
Mitsubishi Materials Corporation
JAPAN
Tin
CID001231
Jiangxi New Nanshan Technology Ltd.
CHINA
Tin
CID001314
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
CID001337
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
CID001399
PT Artha Cipta Langgeng
INDONESIA
Tin
CID001402
PT Babel Inti Perkasa
INDONESIA
Tin
CID001406
PT Babel Surya Alam Lestari
INDONESIA
Tin
CID001453
PT Mitra Stania Prima
INDONESIA
Tin
CID001458
PT Prima Timah Utama
INDONESIA
Tin
CID001460
PT Refined Bangka Tin
INDONESIA
Tin
CID001463
PT Sariwiguna Binasentosa
INDONESIA
Tin
CID001468
PT Stanindo Inti Perkasa
INDONESIA
Tin
CID001477
PT Timah Tbk Kundur
INDONESIA
Tin
CID001482
PT Timah Tbk Mentok
INDONESIA
Tin
CID001490
PT Tinindo Inter Nusa
INDONESIA
Tin
CID001539
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
CID001758
Soft Metais Ltda.
BRAZIL
Tin
CID001898
Thaisarco
THAILAND
Tin
CID001908
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
Tin
CID002036
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
CID002158
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
CID002468
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
Tin
CID002500
Melt Metais e Ligas S.A.
BRAZIL
Tin
CID002503
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
CID002517
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
CID002696
PT Cipta Persada Mulia
INDONESIA
Tin
CID002706
Resind Industria e Comercio Ltda.
BRAZIL
Tin
CID002773
Metallo Belgium N.V.
BELGIUM
Tin
CID002774
Metallo Spain S.L.U.
SPAIN
Tin
CID002834
Thai Nguyen Mining and Metallurgy Co., Ltd.
VIET NAM
Tin
CID002835
PT Menara Cipta Mulia
INDONESIA
Tin
CID002844
HuiChang Hill Tin Industry Co., Ltd.
CHINA
Tin
CID003116
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
Tin
CID003190
Chifeng Dajingzi Tin Industry Co., Ltd.
CHINA
Tin
CID003205
PT Bangka Serumpun
INDONESIA
Tin
CID003325
Tin Technology & Refining
UNITED STATES OF AMERICA
Tin
CID003379
Ma'anshan Weitai Tin Co., Ltd.
CHINA



Tin
CID003381
PT Rajawali Rimba Perkasa
INDONESIA
Tin
CID003387
Luna Smelter, Ltd.
RWANDA
Tin
CID003397
Yunnan Yunfan Non-ferrous Metals Co., Ltd.
CHINA
Tin
CID003582
Fabrica Auricchio Industria e Comercio Ltda.
BRAZIL
Tungsten
CID000004
A.L.M.T. Corp.
JAPAN
Tungsten
CID000105
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
CID000218
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
CID000258
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
CID000568
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
CID000766
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
CID000769
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
Tungsten
CID000825
Japan New Metals Co., Ltd.
JAPAN
Tungsten
CID000875
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
CID000966
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
CID002044
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
CID002082
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
CID002315
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
CID002316
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
Tungsten
CID002317
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
CID002318
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
Tungsten
CID002319
Malipo Haiyu Tungsten Co., Ltd.
CHINA
Tungsten
CID002320
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tungsten
CID002321
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
Tungsten
CID002494
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
Tungsten
CID002502
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Tungsten
CID002513
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
CID002541
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
CID002542
TANIOBIS Smelting GmbH & Co. KG
GERMANY
Tungsten
CID002543
Masan High-Tech Materials
VIET NAM
Tungsten
CID002551
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
Tungsten
CID002589
Niagara Refining LLC
UNITED STATES OF AMERICA
Tungsten
CID002641
China Molybdenum Tungsten Co., Ltd.
CHINA
Tungsten
CID002645
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
Tungsten
CID002649
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
CID002724
Unecha Refractory metals plant
RUSSIAN FEDERATION
Tungsten
CID002827
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
Tungsten
CID002830
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
Tungsten
CID002833
ACL Metais Eireli
BRAZIL
Tungsten
CID002845
Moliren Ltd.
RUSSIAN FEDERATION
Tungsten
CID003388
KGETS Co., Ltd.
KOREA, REPUBLIC OF
Tungsten
CID003401
Fujian Ganmin RareMetal Co., Ltd.
CHINA
Tungsten
CID003407
Lianyou Metals Co., Ltd.
TAIWAN, PROVINCE OF CHINA
Tungsten
CID003408
JSC "Kirovgrad Hard Alloys Plant"
RUSSIAN FEDERATION
Tungsten
CID003468
Cronimet Brasil Ltda
BRAZIL



Tungsten
CID003609
Fujian Xinlu Tungsten
CHINA




The smelters and refiners identified as part of our reasonable country of origin inquiry and validated as conformant according to LBMA Good Delivery List.
Metal
Smelter ID
Standard Smelter Name
Country Location
Gold
CID000343
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Gold
CID001909
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA










RMAP Participating Processing Facilities

Smelters and refiners identified as part of our reasonable country of origin inquiry and that have agreed to participate in the RMAP audit:
Metal
Smelter ID
Standard Smelter Name
Country Location
Gold
CID002852
GGC Gujrat Gold Centre Pvt. Ltd.
INDIA
Gold
CID003421
C.I Metales Procesados Industriales SAS
COLOMBIA
Gold
CID003461
Augmont Enterprises Private Limited
INDIA
Gold
CID003500
Alexy Metals
UNITED STATES OF AMERICA
Gold
CID003529
Sancus ZFS (L’Orfebre, SA)
COLOMBIA
Gold
CID003615
WEEEREFINING
FRANCE
Tin
CID000448
Estanho de Rondonia S.A.
BRAZIL
Tin
CID001305
Novosibirsk Processing Plant Ltd.
RUSSIAN FEDERATION
Tin
CID001428
PT Bukit Timah
INDONESIA
Tin
CID001486
PT Timah Nusantara
INDONESIA
Tin
CID002180
Tin Smelting Branch of Yunnan Tin Co., Ltd.
CHINA
Tin
CID002455
CV Venus Inti Perkasa
INDONESIA
Tin
CID002756
Super Ligas
BRAZIL
Tin
CID002816
PT Sukses Inti Makmur
INDONESIA
Tin
CID003380
PT Masbro Alam Stania
INDONESIA
Tin
CID003449
PT Mitra Sukses Globalindo
INDONESIA
Tin
CID003486
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
BRAZIL
Tin
CID003524
CRM Synergies
SPAIN
Tungsten
CID003416
NPP Tyazhmetprom LLC
RUSSIAN FEDERATION
Tungsten
CID003417
Jingmen Dewei GEM Tungsten Resources Recycling Co., Ltd.
CHINA
Tungsten
CID003427
Albasteel Industria e Comercio de Ligas Para Fundicao Ltd.
BRAZIL
Tungsten
CID003612
OOO “Technolom” 2
RUSSIAN FEDERATION
Tungsten
CID003614
OOO “Technolom” 1
RUSSIAN FEDERATION


Processing facilities with no public participation in validation program whom we have requested to be removed from Nokia supply chain
Together with our suppliers and industry cooperation, we will continue requesting participation in RMAP or an equivalent program or remove from the supply chain:

Metal
Smelter ID
Standard Smelter Name
Country Location
Gold
CID000103
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Gold
CID000180
Caridad
MEXICO
Gold
CID000197
Yunnan Copper Industry Co., Ltd.
CHINA
Gold
CID000522
Refinery of Seemine Gold Co., Ltd.
CHINA
Gold
CID000651
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Gold
CID000671
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Gold
CID000767
Hunan Chenzhou Mining Co., Ltd.
CHINA
Gold
CID000773
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
CHINA
Gold
CID000778
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Gold
CID000927
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION



Gold
CID000956
Kazakhmys Smelting LLC
KAZAKHSTAN
Gold
CID001029
Kyrgyzaltyn JSC
KYRGYZSTAN
Gold
CID001032
L'azurde Company For Jewelry
SAUDI ARABIA
Gold
CID001056
Lingbao Gold Co., Ltd.
CHINA
Gold
CID001058
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Gold
CID001093
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Gold
CID001362
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Gold
CID001546
Sabin Metal Corp.
UNITED STATES OF AMERICA
Gold
CID001562
Samwon Metals Corp.
KOREA, REPUBLIC OF
Gold
CID001619
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Gold
CID001947
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Gold
CID002282
Morris and Watson
NEW ZEALAND
Gold
CID002312
Guangdong Jinding Gold Limited
CHINA
Gold
CID002515
Fidelity Printers and Refiners Ltd.
ZIMBABWE
Gold
CID002525
Shandong Humon Smelting Co., Ltd.
CHINA
Gold
CID002527
Shenzhen Zhonghenglong Real Industry Co., Ltd.
CHINA
Gold
CID002562
International Precious Metal Refiners
UNITED ARAB EMIRATES
Gold
CID002563
Kaloti Precious Metals
UNITED ARAB EMIRATES
Gold
CID002567
Sudan Gold Refinery
SUDAN
Gold
CID002584
Fujairah Gold FZC
UNITED ARAB EMIRATES
Gold
CID002587
Industrial Refining Company
BELGIUM
Gold
CID002588
Shirpur Gold Refinery Ltd.
INDIA
Gold
CID002708
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Gold
CID002850
AU Traders and Refiners
SOUTH AFRICA
Gold
CID002853
Sai Refinery
INDIA
Gold
CID002857
Modeltech Sdn Bhd
MALAYSIA
Gold
CID002865
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Gold
CID002867
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Gold
CID002872
Pease & Curren
UNITED STATES OF AMERICA
Gold
CID002893
JALAN & Company
INDIA
Gold
CID003153
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Gold
CID003185
African Gold Refinery
UGANDA
Gold
CID003186
Gold Coast Refinery
GHANA
Gold
CID003324
QG Refining, LLC
UNITED STATES OF AMERICA
Gold
CID003348
Dijllah Gold Refinery FZC
UNITED ARAB EMIRATES
Gold
CID003382
CGR Metalloys Pvt Ltd.
INDIA
Gold
CID003383
Sovereign Metals
INDIA
Gold
CID003463
Kundan Care Products Ltd.
INDIA
Gold
CID003487
Emerald Jewel Industry India Limited (Unit 1)
INDIA
Gold
CID003488
Emerald Jewel Industry India Limited (Unit 2)
INDIA
Gold
CID003489
Emerald Jewel Industry India Limited (Unit 3)
INDIA
Gold
CID003490
Emerald Jewel Industry India Limited (Unit 4)
INDIA
Gold
CID003497
K.A. Rasmussen
NORWAY
Gold
CID003540
Sellem Industries Ltd.
MAURITANIA
Gold
CID003548
MD Overseas
INDIA
Gold
CID003557
Metallix Refining Inc.
UNITED STATES OF AMERICA



Gold
CID003617
Value Trading
BELGIUM
Tin
CID000309
PT Aries Kencana Sejahtera
INDONESIA
Tin
CID001421
PT Belitung Industri Sejahtera
INDONESIA
Tin
CID001457
PT Panca Mega Persada
INDONESIA
Tin
CID002015
VQB Mineral and Trading Group JSC
VIET NAM
Tin
CID002478
PT Tirus Putra Mandiri
INDONESIA
Tin
CID002572
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
VIET NAM
Tin
CID002573
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
CID002574
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Tin
CID002703
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Tin
CID002858
Modeltech Sdn Bhd
MALAYSIA
Tin
CID003208
Pongpipat Company Limited
MYANMAR
Tin
CID003356
Dongguan CiEXPO Environmental Engineering Co., Ltd.
CHINA
Tin
CID003409
Precious Minerals and Smelting Limited
INDIA
Tin
CID003410
Gejiu City Fuxiang Industry and Trade Co., Ltd.
CHINA
Tungsten
CID000281
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Tungsten
CID002313
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Tungsten
CID003553
Artek LLC
RUSSIAN FEDERATION


Reasonable Country of Origin Inquiry
In order to identify countries of origin, Nokia made use of Conflict Minerals templates provided by suppliers and aggregated country of origin information of smelters provided by RMI to its members. Based on these, the countries of origin of the Conflict Minerals in the Nokia supply chain may include:
The countries of origin for Gold may include: Argentina, Armenia, Australia, Azerbaijan, Benin, Bolivia (Plurinational State of), Botswana, Brazil, Bulgaria, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Costa Rica, Cote d'Ivoire, Cuba, Cyprus, Djibouti, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, Hungary, India, Indonesia, Italy, Ivory Coast, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Liechtenstein, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Montenegro, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Oman, Papua New Guinea, Peru, Philippines, Portugal, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Solomon Islands, South Africa, South Korea, Spain, Sudan, Suriname, Swaziland, Sweden, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Vietnam, Zambia, Zimbabwe.

The countries of origin for Tantalum may include: Australia, Bolivia, Brazil, Burundi, China, Colombia, Democratic Republic of the Congo, Ethiopia, France, Germany, India, Madagascar, Malaysia, Mozambique, Myanmar, Namibia, Nigeria, Russian Federation, Rwanda, Sierra Leone, Spain, Thailand, Uganda, United States of America, Zimbabwe.

The countries of origin for Tin may include: Australia, Belgium, Bolivia (Plurinational State of), Brazil, Burundi, China, Colombia, Democratic Republic of the Congo, Germany, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda,



South Korea, Spain, Taiwan, Thailand, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Venezuela, Vietnam.

The countries of origin for Tungsten may include: Australia, Austria, Bolivia, Brazil, Burundi, China, Colombia, Democratic Republic of the Congo, Kazakhstan, Kyrgyzstan, Malaysia, Mexico, Mongolia, Myanmar, Nigeria, Peru, Philippines, Portugal, Russian Federation, Rwanda, Spain, Thailand, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zimbabwe.
Nokia supports seeking a sustainable solution to the issue of conflict minerals and aims to ensure responsible and conflict-free sourcing, thus supporting legitimate trade and positive development in the DRC and adjoining countries. Of Nokia’s suppliers, 268 had reported smelters that process conflict minerals originating in one or more of the Covered Countries and 245 from other Conflict-Affected Countries and High-Risk Areas. Altogether 90 smelters in the consolidated smelter list (27% of identified smelters) were confirmed to process Conflict Minerals sourcing from the Covered Countries. As part of our due diligence, we have followed up with all such suppliers to verify whether the smelters that sourced Conflict Minerals from Covered Countries are compliant smelters under the RMAP. 80 smelters were found to be conformant and 4 active in the RMAP validation process. 34 of these (10% of all identified smelters) were sourcing from the DRC. We believe this is a positive development for the countries whose livelihood depends on these efforts continuing. For five of the smelters we cannot rule out that they source from the Covered Countries due to their geographic proximity, and we will continue to take further due diligence efforts in 2022 with regard to those smelters.
Extending Due Diligence to Cobalt
In 2021 we also undertook a mapping of cobalt in our components based on material declarations for product parts. We addressed 65 relevant suppliers about our requirements regarding cobalt and engaged them to conduct due diligence over the cobalt supply chain. As a result, we have been able to identify 63 cobalt smelters in our cobalt supply chain, out of which 38 have gone through the Responsible Minerals Assurance Program and have either Conformant or Active status. Similarly to 3TG Due Diligence, we have provided individual feedback to all of the relevant suppliers, including asking them to source from Conformant smelters or help to receive the commitments to participate in Responsible Minerals Assurance Program and continued to contribute to industry outreach to Cobalt smelters.
Progress on Commitments made in 2021 Conflict Minerals Report

Target for 2021
Progress in 2021
Engaging in further awareness raising and due diligence capability building efforts jointly in collaboration with relevant stakeholder forums and/or independently with our suppliers;
All suppliers that are not yet fully compliant with Nokia expectations were followed up with one to one feedback. In addition, live webinars were conducted to suppliers with high or medium risk. Significant effort was also spent on improving the quality and completeness of supplier reporting, turning supplier declarations from company to Nokia relevant product scope. This has helped to eliminate erroneous smelter data from our reports. Suppliers were also encouraged to participate in industry forums and collaboration.
Requesting non-conformant suppliers to improve quality of the reporting and to finalize the phase out of the non-conformant smelters;
In 2021, Smelter mapping by our suppliers was completed at 97% on average (Tantalum 96%, Tin 97%, Tungsten 96%, Gold 97%).  100% of the smelters from which our suppliers sourced tantalum were conflict-free, for tungsten 94% of smelters were conflict-free and for tin 83% and for




 
gold (67%). The phase-out of problematic smelters continued with 10 suppliers reporting such entities in 2021 against 13 in 2020.
Actively engaging with our supply chain to get more smelters validated as conflict-free through the third-party validation mechanisms available, with the aim of increasing the number of smelters on the list of RMAP compliant smelters;
Engagement was two-fold: on the supplier level directly with smelters and through the respective working group of Responsible Minerals Initiative. As a result 78% of smelters were validated as conflict-free or currently engaged in industry third party validation process and 8% were identified as low risk of sourcing from the Covered Countries. Although several of the non-conformant smelters were phased out, many of our smelters could also not meet updated audit protocol requirements and dropped on their conformant status.
Validating the due diligence efforts of our suppliers as part of overall supplier assessments.
 
In 2021 we also conducted 8 third-party audits focused on conflict-free sourcing. In addition, 64 of our Corporate Responsibility audits included conflict minerals sourcing as part of assessment checklist.



NOKIA COMMITMENTS FOR 2022:
In order to mitigate the risk that the conflict minerals contained in, and necessary to the functionality or production of, Nokia’s products benefit armed groups, and to improve our conflict minerals due diligence efforts further in the coming year, we plan to concentrate on the following activities in 2022:
engaging in further awareness raising and due diligence capability building efforts jointly in collaboration with relevant stakeholder forums and/or independently with our suppliers;
requesting non-conformant suppliers to improve quality of the reporting and to finalize the phase out of the non-conformant smelters;
actively engaging with our supply chain to get more smelters validated as conflict-free through the third-party validation mechanisms, with the aim of sourcing only from the list of RMAP compliant smelters;

validating the due diligence efforts of our suppliers as part of overall supplier assessment;
Statements relating to due diligence process improvement, as well as similar strategy and compliance process statements made in this conflict minerals report are forward-looking in nature and are based on Nokia’s management’s current expectations or beliefs. These forward-looking statements are not a guarantee of performance and are subject to a number of uncertainties and other factors (such as whether industry organizations and initiatives such as RMI remain effective as a source of external support to us in the conflict minerals compliance process), which may be outside of Nokia’s control and which could cause actual events to differ materially from those expressed or implied by the statements made herein.

Unless otherwise expressly stated herein, any documents, third party materials or references to websites are not incorporated by reference in, or considered to be a part of, this conflict minerals report.



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