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
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, 2019. |
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.
We have organized our businesses into seven business groups: Mobile Networks, Fixed Networks, Global Services, IP/Optical Networks, Nokia Software, Nokia Enterprise and Nokia Technologies
At the end of 2019, we had three reportable segments: (i) Networks, (ii) Nokia Software, and (iii) Nokia Technologies, in addition to which we disclose segment-level data for Group Common and Other.
Products manufactured by Nokia, or for which Nokia contracted with third parties to manufacture, during the year ended December 31, 2019 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). Due-diligence results in this Report cover the Networks segment.
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 2019 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 levels 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, 2019 originated in the Covered Countries.
For 2019, we determined that the Conflict Minerals used in Nokia’s products originated from the following countries:
Argentina, Australia, Azerbaijan, Benin, Bolivia (Plurinational State of), Botswana, Brazil, Burundi, Burkina Faso, Canada, Chile, China, Colombia, Cuba, Cyprus, Democratic Republic of the Congo, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Finland, France, Germany, Georgia, Ghana, Guatemala, Guinea, Guyana, Honduras, India, Indonesia, Iran, Ivory Coast, Japan, Kazakhstan, Kenya, Laos, Liberia, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Papua New Guinea, Peru, Phillippines, Portugal, Puerto Rico, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Slovakia, Solomon Islands, South Africa, Spain, Suriname, Swaziland, Sweden, Taiwan, Tajikistan, Tanzania, Thailand, Togo, Turkey, Uganda, United Kingdom, 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 2019.
Section 2 – Exhibits
| Item 2.01 | 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: May 29, 2020
NOKIA CONFLICT MINERALS REPORT FOR 2019
May 28, 2020
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 2017) (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. In 2019 our Conflict Minerals Policy has been revised and updated to Nokia Responsible Minerals Policy. 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 Dedicated Quality Reviews) and Sustainability Council (cross-functional committee for sustainability governance composed of group responsibility 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”) (formerly known as the Conflict-Free Sourcing Initiative (“CFSI”). 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 conflict 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 a conflict-free smelter list, which is composed of mineral processing facilities that have been reviewed by an independent third-party audit to assess whether the facility employs policies, practices, and procedures to provide assurance that the material sourced is DRC conflict-free. 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 were 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 as well as onsite workshop with suppliers to further explain our conflict 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 2019 there were 9 grievances reported via RMI Grievance Channel and 1 grievance 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. 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 throughout the year are reported to Nokia’s Head of Supply Quality, Product Procurement Leadership and Sustainability Council. |
| 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, 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, 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 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. | Risk management plans, monitoring and performance tracking is done in close collaboration with sourcing and followed up by the cross-functional conflict minerals working group that oversees the implementation of the Policy. The results are reported to Sourcing category leaders and also back to Head of Supply Quality and 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 2019 we asked suppliers to remove 54 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, 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 2019 there were 9 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 2019 Nokia also joined industry delegation to the DRC and Rwanda that included facilitated meetings and forums with national and local governmental leaders, human rights NGOs and local business as well as mine-site visits and community member visits. |
| 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 2019
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, RF MW circuits 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 1264. Of these, 274 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 100%. 24 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:
| ● | 100% of suppliers have adopted a Responsible/Conflict Minerals Policy (100% in 2018), 86% public and 14% not public. |
| ● | Suppliers tracing all smelters (per mineral): tantalum 95%, tin 97%, tungsten 94%, gold 97%. |
| ● | Suppliers with conflict-free status (per mineral, including conflict-free status of respective reported smelters): tantalum 95%, tin 91%, tungsten 85%, gold 90%. |
| Figure 1: Supplier smelter identification completion and Conflict-Free Status |
Suppliers sourcing from the Covered Countries: 246/250=98% (2018: 251 suppliers)
In total, we have identified 298 of the smelters:
| ● | 79% of smelters have been validated by RMAP or mutually recognized programs (out of known smelters) (82% in 20182): gold 71%, tantalum 97%, tin 80%, tungsten 88%. |
| ● | 82% of smelters have been validated by RMAP or mutually recognized programs or are active in the validation process (out of known smelters) (84% in 2018): gold 71%, tantalum 100%, tin 86%, tungsten 96%. 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 have come down from 32 in 2018 to 23 in 2019. |
| ● | 5% 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 | 38 | 1 | 0 | 39 |
| 97% | 3% | 0% | ||
| Tin | 45 | 3 | 8 | 56 |
| 80% | 5% | 14% | ||
| Gold | 109 | 1 | 44 | 154 |
| 71% | 1% | 29% | ||
| Tungsten | 43 | 4 | 2 | 49 |
| 88% | 8% | 4% | ||
| Total | 235 | 9 | 54 | 298 |
| 79% | 3% | 18% | 100% |
2 The number of identified smelters decreased from 313 in 2018 to 298 in 2019.
Figure 2. Conflict-Free validation status of the 298 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 30, 2020.
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 | OJSC 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 Precious Metals 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 | CID001029 | Kyrgyzaltyn JSC | KYRGYZSTAN |
| 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 | 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 | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | CID001938 | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | CID001955 | Torecom | KOREA, REPUBLIC OF |
| Gold | CID001977 | Umicore Brasil Ltda. | BRAZIL |
| 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 | 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 | 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 | 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 | CID002850 | AU Traders and Refiners | SOUTH AFRICA |
| 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 | CID003195 | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | CID003424 | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | CID003425 | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Tantalum | CID000092 | Asaka Riken Co., Ltd. | JAPAN |
| 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 | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | CID000917 | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | CID001076 | LSM Brasil S.A. | 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 Blue Metals | MEXICO |
| Tantalum | CID002544 | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | CID002545 | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
| Tantalum | CID002547 | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | CID002548 | H.C. Starck Inc. | UNITED STATES OF AMERICA |
| Tantalum | CID002549 | H.C. Starck Ltd. | JAPAN |
| Tantalum | CID002550 | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tantalum | CID002557 | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | CID002558 | Global Advanced Metals Aizu | JAPAN |
| Tantalum | CID002568 | KEMET Blue Powder | UNITED STATES OF AMERICA |
| Tantalum | CID002707 | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | CID002842 | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | CID002847 | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF |
| 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 | CID000760 | Huichang Jinshunda Tin 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 | CID001453 | PT Mitra Stania Prima | INDONESIA |
| Tin | CID001460 | PT Refined Bangka Tin | INDONESIA |
| Tin | CID001477 | PT Timah Tbk Kundur | INDONESIA |
| Tin | CID001482 | PT Timah Tbk Mentok | 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 | CID002180 | Yunnan Tin Company Limited | 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 | 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 | CID002844 | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | CID002849 | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA |
| Tin | CID003116 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | CID003190 | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | CID003325 | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | CID003379 | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | CID003397 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| 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 | CID000499 | Fujian Jinxin 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 | CID001889 | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | CID002044 | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | CID002082 | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002095 | Xinhai Rendan Shaoguan 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 | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
| Tungsten | CID002543 | Masan Tungsten Chemical LLC (MTC) | VIET NAM |
| Tungsten | CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | CID002579 | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | CID002589 | Niagara Refining LLC | UNITED STATES OF AMERICA |
| 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 | CID002843 | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | CID002845 | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | CID003182 | Hunan Litian Tungsten Industry Co., Ltd. | CHINA |
| 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 |
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 | CID001236 | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | CID001909 | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | CID002615 | TOO Tau-Ken-Altyn | KAZAKHSTAN |
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 | CID002290 | SAFINA A.S. | CZECH REPUBLIC |
| Tantalum | CID003402 | CP Metals Inc. | UNITED STATES OF AMERICA |
| Tin | CID003356 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | CID003387 | Luna Smelter, Ltd. | RWANDA |
| Tin | CID003409 | Precious Minerals and Smelting Limited | INDIA |
| Tungsten | CID002647 | Jiangxi Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | CID003408 | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | CID003427 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | CID003448 | CP Metals Inc. | UNITED STATES OF AMERICA |
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:
| 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 | 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 | CID002560 | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| 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 | Tony Goetz NV | BELGIUM |
| Gold | CID002708 | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | CID002852 | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| 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 | CID003153 | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | CID003185 | African Gold Refinery | UGANDA |
| Gold | CID003189 | NH Recytech Company | KOREA, REPUBLIC OF |
| 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 |
| Tin | CID000448 | Estanho de Rondonia S.A. | BRAZIL |
| 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 | CID002756 | Super Ligas | BRAZIL |
| Tin | CID002858 | Modeltech Sdn Bhd | MALAYSIA |
| Tin | CID003208 | Pongpipat Company Limited | MYANMAR |
| Tungsten | CID000281 | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tungsten | CID002313 | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
We have identified an additional 23 facilities that were reported as smelters by our suppliers but that we were not able to confirm as smelters or refiners based on industry or public sources of information, and will be reaching out to these facilities in 2020 to perform additional due diligence.
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, Australia, Azerbaijan, Benin, Bolivia (Plurinational State of), Botswana, Brazil, Burkina Faso, Canada, Chile, China, Colombia, Democratic Republic of the Congo, Cuba, Cyprus, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Finland, Georgia, Ghana, Guatemala, Guinea, Guyana, Honduras, Indonesia, Iran, Ivory Coast, Japan, Kazakhstan, Kenya, Laos, Liberia, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Papua New Guinea, Peru, Philippines, Puerto Rico, Russian Federation, Rwanda, Saudi Arabia, Senegal, Serbia, Slovakia, Solomon Islands, South Africa, Spain, Suriname, Swaziland, Sweden, Tajikistan, Tanzania, Togo, Turkey, Uganda, United Kingdom, United States of America, Uruguay, Zambia, Zimbabwe.
The countries of origin for Tantalum may include: Australia, Austria, Bolivia, Bolivia (Plurinational State of), Brazil, Burundi, China, Colombia, Democratic Republic of the Congo, Ethiopia, France, Germany, Guinea, India, Madagascar, Malaysia, Mozambique, Namibia, Nigeria, Russian Federation, Rwanda, Sierra Leone, Somaliland, Spain, Thailand, Zimbabwe.
The countries of origin for Tin may include: Australia, Bolivia (Plurinational State of), Brazil, Burundi, China, Colombia, Democratic Republic of the Congo, Guinea, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Taiwan, Thailand, Uganda, United Kingdom, Venezuela, Vietnam.
The countries of origin for Tungsten may include: Australia, Bolivia, Brazil, Burundi, China, Colombia, Democratic Republic of the Congo, Guinea, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Spain, Taiwan, Thailand, Uganda, United Kingdom, United States of America, Uzbekistan, Vietnam.
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, 246 had reported smelters that process conflict minerals originating in one or more of the Covered Countries. Altogether 56 smelters in the consolidated smelter list (19% 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. 51 smelters were found to be conformant. 28 of these (9% 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 2020 with regard to those smelters.
Progress on Commitments made in 2019 Conflict Minerals Report
| Target for 2019 | Progress in 2019 |
| 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, several live webinars were conducted to suppliers with high or medium risk and an onsite workshop was delivered to our suppliers in China. 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. Nokia also participated in an industry delegation visit to DRC and Rwanda which included convened meetings and fora with conflict minerals related stakeholders (national and regional government, NGOs, private sector) on the ground |
| 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 82% of smelters were validated as conflict-free or currently engaged in industry third party validation process and 5% 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. |
| Requesting suppliers to fully complete smelter mapping, and source over 90% of tin, tantalum, tungsten and gold from conflict-free smelters; and | In 2019, Smelter mapping by our suppliers was completed at 96% on average (Tantalum 95%, Tin 97%, Tungsten 94%, Gold 97%). 97% of the smelters from which our suppliers sourced tantalum were conflict-free, for tungsten 88% of smelters were conflict-free and for tin 80% and for gold (71%). |
| Validating the due diligence efforts of our suppliers as part of overall supplier assessments. | In 2019 we also conducted 8 third-party audits focused on conflict-free sourcing. In addition, 45 of our Corporate Responsibility audits included conflict minerals sourcing as part of assessment checklist. |
NOKIA COMMITMENTS FOR 2020:
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 2020:
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; and
redesign our upstream stakeholder engagement strategy;
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.