Exhibit 1.01
NOKIA CONFLICT MINERALS REPORT FOR 2022
25 May 2023
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, ESG, and legal teams. 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 Sustainability Council (cross-functional committee for sustainability governance composed of group ESG management and senior leaders from business units). |
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1 Columbite-tantalite (coltan) (or its derivative tantalum), cassiterite (or its derivative tin), gold and wolframite (or its derivative tungsten).
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| 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 or dropped their Conformant status. 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. |
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| 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 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 2022, there were 14 grievances reported via RMI Grievance Channel which were all follow up grievances from issues reported in previous years and one 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 |
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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. |
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| 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 Business Groups Sourcing organizations and followed up by the cross-functional responsible minerals working group that oversees the implementation of the 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 2022, we asked suppliers to remove 92 smelters that were not conformant to RMAP and LBMA programmes unless we had evidence that they can be reasonably considered as recyclers or sourcing from outside of Covered Countries. 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 2022, 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 2022, Nokia also continued to participate in the Public Private Alliance and 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/ |
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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. | |
| 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 2022
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 934. Of these, 320 suppliers were above the supplier spend threshold applied by Nokia, in the aggregate representing 99% 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%. 43 of the suppliers surveyed did not supply materials containing Conflict Minerals.
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Based on our due diligence efforts we found on a supplier level that, of the suppliers in scope:
| • | 98% of suppliers have adopted a Responsible/Conflict Minerals Policy (99% in 2021), 84% public and 16% 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 95%. |
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Suppliers sourcing from the Covered Countries: 88% (2021: 98%)
Figure 1: Supplier smelter identification completion and Conflict-Free Status
In total, we have identified 337 smelters (337 in 2021) of the smelters:
| • | 69% of smelters have been validated by RMAP or mutually recognized programs (out of known smelters) (71% in 2021): gold 60%, tantalum 97%, tin 69%, tungsten 79%. |
| • | 73% of smelters have been validated by RMAP or mutually recognized programs or are active in the validation process (out of known smelters) (78% in 2021): gold 64%, tantalum 97%, tin 78%, tungsten 79%. Several smelters that were validated as conformant previous year, have lost their conformance status due to updated compliance protocols and due to suspension of RMAP assessments in Russia. Although progress on smelter compliance level is hardly visible, number of Nokia suppliers that remain to report non-conformant suppliers is 7 (10 in 2021). |
| • | 14% 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 | 34 | 0 | 1 | 35 |
| 97% | 0% | 3% | ||
| Tin | 56 | 7 | 18 | 81 |
| 69% | 9% | 12% | ||
| Gold | 103 | 7 | 63 | 173 |
| 60% | 4% | 36% | ||
| Tungsten | 38 | 0 | 10 | 48 |
| 84% | 0% | 16% | ||
| Total | 231 | 14 | 92 | 337 |
| 69% | 4% | 27% | 100% |
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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, 2023.
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 | Smelter Name | Country Location |
| Gold | CID000189 | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | CID000981 | Kojima Chemicals Co., Ltd. | JAPAN |
| Gold | CID001157 | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | CID001955 | Torecom | KOREA, REPUBLIC OF |
| Gold | CID002129 | Yokohama Metal Co., Ltd. | JAPAN |
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| Gold | CID001161 | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | CID000077 | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | CID002919 | Planta Recuperadora de Metales SpA | CHILE |
| Gold | CID002918 | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | CID001149 | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| Gold | CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | CID001147 | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | CID000855 | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | CID001397 | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | CID002003 | Valcambi S.A. | SWITZERLAND |
| Gold | CID003575 | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Gold | CID000185 | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | CID001153 | Metalor Technologies S.A. | SWITZERLAND |
| Gold | CID002243 | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | CID000969 | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | CID001938 | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | CID001259 | Nihon Material Co., Ltd. | JAPAN |
| Gold | CID001498 | PX Precinox S.A. | SWITZERLAND |
| Gold | CID002224 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | CID000176 | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CID000957 | Kazzinc | KAZAKHSTAN |
| Gold | CID003425 | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Gold | CID000035 | Agosi AG | GERMANY |
| Gold | CID003424 | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | CID000157 | Boliden AB | SWEDEN |
| Gold | CID000711 | Heraeus Germany GmbH Co. KG | GERMANY |
| Gold | CID002459 | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | CID002582 | REMONDIS PMR B.V. | NETHERLANDS |
| Gold | CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | CID002580 | T.C.A S.p.A | ITALY |
| Gold | CID002100 | Yamakin Co., Ltd. | JAPAN |
| Gold | CID001916 | Shandong Gold Smelting Co., Ltd. | CHINA |
| Gold | CID000707 | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | CID001236 | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | CID001113 | Materion | UNITED STATES OF AMERICA |
| Gold | CID001119 | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | CID000823 | Japan Mint | JAPAN |
| Gold | CID000937 | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | CID000814 | Istanbul Gold Refinery | TURKEY |
| Gold | CID000015 | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | CID002314 | Umicore Precious Metals Thailand | THAILAND |
| Gold | CID000019 | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | CID002560 | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | CID000264 | Chugai Mining | JAPAN |
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| Gold | CID001352 | MKS PAMP SA | SWITZERLAND |
| Gold | CID002561 | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | CID000924 | Asahi Refining Canada Ltd. | CANADA |
| Gold | CID000807 | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | CID000920 | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | CID001585 | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | CID003641 | Gold by Gold Colombia | COLOMBIA |
| Gold | CID001220 | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | CID001325 | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | CID000233 | Chimet S.p.A. | ITALY |
| Gold | CID000113 | Aurubis AG | GERMANY |
| Gold | CID002779 | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | CID000359 | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | CID002778 | WIELAND Edelmetalle GmbH | GERMANY |
| Gold | CID001555 | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | CID001798 | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | CID002765 | Italpreziosi | ITALY |
| Gold | CID002763 | 8853 S.p.A. | ITALY |
| Gold | CID003189 | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | CID002511 | KGHM Polska Miedz Spolka Akcyjna | POLAND |
| Gold | CID002516 | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | CID002762 | L'Orfebre S.A. | ANDORRA |
| Gold | CID002761 | SAAMP | FRANCE |
| Gold | CID002509 | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | CID001534 | Royal Canadian Mint | CANADA |
| Gold | CID002863 | Bangalore Refinery | INDIA |
| Gold | CID000689 | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | CID000694 | Heimerle + Meule GmbH | GERMANY |
| Gold | CID002973 | Safimet S.p.A | ITALY |
| Gold | CID002615 | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | CID001512 | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | CID001875 | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | CID001993 | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA |
| Gold | CID002605 | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | CID000425 | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Gold | CID001761 | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | CID002290 | SAFINA A.S. | CZECH REPUBLIC |
| Gold | CID001622 | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | CID001193 | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | CID001078 | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | CID000401 | Dowa | JAPAN |
| Gold | CID001736 | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | CID002030 | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA |
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| Gold | CID001188 | Mitsubishi Materials Corporation | JAPAN |
| Gold | CID001980 | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
| Gold | CID000090 | Asaka Riken Co., Ltd. | JAPAN |
| Gold | CID000082 | Asahi Pretec Corp. | JAPAN |
| Tantalum | CID003583 | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| Tantalum | CID001163 | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | CID000616 | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA |
| Tantalum | CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | CID002557 | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA |
| Tantalum | CID002558 | Global Advanced Metals Aizu | JAPAN |
| Tantalum | CID002545 | TANIOBIS GmbH | GERMANY |
| Tantalum | CID002544 | TANIOBIS Co., Ltd. | THAILAND |
| Tantalum | CID002549 | TANIOBIS Japan Co., Ltd. | JAPAN |
| Tantalum | CID002548 | Materion Newton Inc. | UNITED STATES OF AMERICA |
| Tantalum | CID002547 | QSIL Metals Hermsdorf GmbH | GERMANY |
| Tantalum | CID002550 | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tantalum | CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | CID000917 | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | CID002539 | KEMET de Mexico | MEXICO |
| Tantalum | CID001200 | NPM Silmet AS | ESTONIA |
| Tantalum | CID002512 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | CID000211 | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | CID000460 | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | CID002508 | XinXing HaoRong Electronic Material Co., Ltd. | CHINA |
| Tantalum | CID002506 | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | CID002505 | FIR Metals & Resource Ltd. | CHINA |
| Tantalum | CID002504 | D Block Metals, LLC | UNITED STATES OF AMERICA |
| Tantalum | CID001522 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tantalum | CID001891 | Telex Metals | UNITED STATES OF AMERICA |
| Tantalum | CID002842 | Jiangxi Tuohong New Raw Material | CHINA |
| Tantalum | CID001508 | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | CID001869 | Taki Chemical Co., Ltd. | JAPAN |
| Tantalum | CID001076 | AMG Brasil | BRAZIL |
| Tantalum | CID001192 | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | CID002707 | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | CID001969 | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
| Tantalum | CID001175 | Mineracao Taboca S.A. | BRAZIL |
| Tin | CID001399 | PT Artha Cipta Langgeng | INDONESIA |
| Tin | CID003582 | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
| Tin | CID003205 | PT Bangka Serumpun | INDONESIA |
| Tin | CID003325 | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | CID003449 | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | CID002468 | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | CID000292 | Alpha | UNITED STATES OF AMERICA |
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| Tin | CID001142 | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | CID001493 | PT Tommy Utama | INDONESIA |
| Tin | CID001490 | PT Tinindo Inter Nusa | INDONESIA |
| Tin | CID001477 | PT Timah Tbk Kundur | INDONESIA |
| Tin | CID001482 | PT Timah Tbk Mentok | INDONESIA |
| Tin | CID002570 | CV Ayi Jaya | INDONESIA |
| Tin | CID002696 | PT Cipta Persada Mulia | INDONESIA |
| Tin | CID001105 | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | CID001468 | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | CID003524 | CRM Synergies | SPAIN |
| Tin | CID001231 | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | CID001337 | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | CID001458 | PT Prima Timah Utama | INDONESIA |
| Tin | CID001460 | PT Refined Bangka Tin | INDONESIA |
| Tin | CID001463 | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | CID002774 | Aurubis Berango | SPAIN |
| Tin | CID003868 | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tin | CID001453 | PT Mitra Stania Prima | INDONESIA |
| Tin | CID003190 | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | CID001314 | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | CID000228 | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | CID000468 | Fenix Metals | POLAND |
| Tin | CID002773 | Aurubis Beerse | BELGIUM |
| Tin | CID002517 | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | CID001428 | PT Bukit Timah | INDONESIA |
| Tin | CID001539 | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | CID000448 | Estanho de Rondonia S.A. | BRAZIL |
| Tin | CID001898 | Thaisarco | THAILAND |
| Tin | CID002503 | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | CID000555 | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | CID001402 | PT Babel Inti Perkasa | INDONESIA |
| Tin | CID000438 | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | CID001406 | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | CID002180 | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| Tin | CID000309 | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | CID003387 | Luna Smelter, Ltd. | RWANDA |
| Tin | CID003381 | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | CID000538 | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | CID002158 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | CID002835 | PT Menara Cipta Mulia | INDONESIA |
| Tin | CID001070 | China Tin Group Co., Ltd. | CHINA |
| Tin | CID001191 | Mitsubishi Materials Corporation | JAPAN |
| Tin | CID002706 | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | CID003116 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
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| Tin | CID000402 | Dowa | JAPAN |
| Tin | CID001182 | Minsur | PERU |
| Tin | CID002036 | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | CID003486 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | CID002816 | PT Sukses Inti Makmur | INDONESIA |
| Tin | CID001173 | Mineracao Taboca S.A. | BRAZIL |
| Tungsten | CID002494 | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | CID002589 | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | CID000966 | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | CID000825 | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | CID003417 | Hubei Green Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002315 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | CID000258 | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | CID003401 | Fujian Ganmin RareMetal Co., Ltd. | CHINA |
| Tungsten | CID002319 | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002318 | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | CID003407 | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002321 | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tungsten | CID000004 | A.L.M.T. Corp. | JAPAN |
| Tungsten | CID002543 | Masan High-Tech Materials | VIET NAM |
| Tungsten | CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA |
| Tungsten | CID002542 | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | CID002541 | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | CID002645 | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA |
| Tungsten | CID000105 | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | CID003609 | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002513 | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA |
| Tungsten | CID000218 | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002641 | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002082 | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | CID002502 | Asia Tungsten Products Vietnam Ltd. | VIET NAM |
| Tungsten | CID000568 | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| Tungsten | CID002845 | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | CID002830 | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA |
| Tungsten | CID002833 | ACL Metais Eireli | BRAZIL |
| Tungsten | CID002044 | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | CID000769 | Hunan Jintai New Material Co., Ltd. | CHINA |
| Tungsten | CID002827 | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | CID000766 | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | CID003468 | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | CID000875 | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
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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 | Smelter Name | Country Location |
| Gold | CID003663 | Dongwu Gold Group | CHINA |
| Gold | CID001909 | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | CID000343 | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | CID002750 | Shenzhen CuiLu Gold Co., Ltd. | 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 | Smelter Name | Country Location |
| Gold | CID003461 | Augmont Enterprises Private Limited | INDIA |
| Gold | CID003421 | C.I Metales Procesados Industriales SAS | COLOMBIA |
| Gold | CID003529 | Sancus ZFS (L’Orfebre, SA) | COLOMBIA |
| Gold | CID003500 | Alexy Metals | UNITED STATES OF AMERICA |
| Gold | CID003615 | WEEEREFINING | FRANCE |
| Gold | CID002852 | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | CID002708 | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Tin | CID002455 | CV Venus Inti Perkasa | INDONESIA |
| Tin | CID001486 | PT Timah Nusantara | INDONESIA |
| Tin | CID002776 | PT Bangka Prima Tin | INDONESIA |
| Tin | CID001421 | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | CID002756 | Super Ligas | BRAZIL |
| Tin | CID003831 | DS Myanmar | MYANMAR |
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 | Smelter Name | Country Location |
| Gold | CID000197 | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | CID003463 | Kundan Care Products Ltd. | INDIA |
| Gold | CID001947 | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | CID003324 | QG Refining, LLC | UNITED STATES OF AMERICA |
| Gold | CID001029 | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | CID001032 | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | CID000180 | Caridad | MEXICO |
| Gold | CID003557 | Metallix Refining Inc. | UNITED STATES OF AMERICA |
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| Gold | CID002588 | Shirpur Gold Refinery Ltd. | INDIA |
| Gold | CID002587 | Industrial Refining Company | BELGIUM |
| Gold | CID001810 | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | CID001386 | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | CID000956 | Kazakhmys Smelting LLC | KAZAKHSTAN |
| Gold | CID003548 | MD Overseas | INDIA |
| Gold | CID002584 | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | CID002567 | Sudan Gold Refinery | SUDAN |
| Gold | CID001362 | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | CID003540 | Sellem Industries Ltd. | MAURITANIA |
| Gold | CID002312 | Guangdong Jinding Gold Limited | CHINA |
| Gold | CID002563 | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | CID002562 | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Gold | CID000929 | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | CID000927 | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | CID000493 | JSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | CID001204 | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | CID001326 | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | CID000103 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | CID002527 | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | CID002525 | Shandong Humon Smelting Co., Ltd. | CHINA |
| Gold | CID003186 | Gold Coast Refinery | GHANA |
| Gold | CID003185 | African Gold Refinery | UGANDA |
| Gold | CID001562 | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | CID002893 | JALAN & Company | INDIA |
| Gold | CID001546 | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | CID002515 | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| 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 | CID002853 | Sai Refinery | INDIA |
| Gold | CID002857 | Modeltech Sdn Bhd | MALAYSIA |
| Gold | CID003153 | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | CID001093 | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | CID002606 | Marsam Metals | BRAZIL |
| Gold | CID001756 | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | CID003383 | Sovereign Metals | INDIA |
| Gold | CID003382 | CGR Metalloys Pvt Ltd. | INDIA |
| Gold | CID000671 | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | CID002850 | AU Traders and Refiners | SOUTH AFRICA |
| Gold | CID000651 | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | CID000773 | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Gold | CID003489 | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| Gold | CID000778 | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Gold | CID002282 | Morris and Watson | NEW ZEALAND |
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| Gold | CID003497 | K.A. Rasmussen | NORWAY |
| Gold | CID003490 | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| Gold | CID001619 | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | CID000522 | Refinery of Seemine Gold Co., Ltd. | CHINA |
| Gold | CID001058 | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | CID000767 | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | CID003488 | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| Gold | CID003487 | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| Gold | CID003348 | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Gold | CID001056 | Lingbao Gold Co., Ltd. | CHINA |
| Tantalum | CID001769 | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| Tin | CID002478 | PT Tirus Putra Mandiri | INDONESIA |
| Tin | CID003208 | Pongpipat Company Limited | MYANMAR |
| Tin | CID000942 | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | CID002574 | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | CID002573 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | CID002572 | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | CID003409 | Precious Minerals and Smelting Limited | INDIA |
| Tin | CID001908 | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | CID003410 | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CHINA |
| Tin | CID001457 | PT Panca Mega Persada | INDONESIA |
| Tin | CID001305 | Novosibirsk Tin Combine | RUSSIAN FEDERATION |
| Tin | CID001419 | PT Bangka Tin Industry | INDONESIA |
| Tin | CID002500 | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | CID002858 | Modeltech Sdn Bhd | MALAYSIA |
| Tin | CID003397 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | CID002703 | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | CID002015 | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | CID003356 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tungsten | CID003427 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | CID000281 | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tungsten | CID003553 | Artek LLC | RUSSIAN FEDERATION |
| Tungsten | CID003416 | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| Tungsten | CID002313 | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | CID003408 | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | CID003612 | OOO “Technolom” 2 | RUSSIAN FEDERATION |
| Tungsten | CID002649 | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | CID003614 | OOO “Technolom” 1 | RUSSIAN FEDERATION |
| Tungsten | CID002724 | Unecha Refractory metals plant | RUSSIAN FEDERATION |
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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, Burkina Faso, Cambodia, Canada, Chile, China, Colombia, Democratic Republic of the Congo, Cote d'Ivoire, Djibouti, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Finland, France, French Guiana, Georgia, Germany, Ghana, Guatemala, Guinea, Guyana, Honduras, Hungary, India, Indonesia, Italy, Japan, Kazakhstan, Kenya, Kyrgyzstan, Laos, Liberia, Liechtenstein, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, Netherlands, New Zealand, Nicaragua, Niger, Nigeria, Oman, Panama, Papua New Guinea, Peru, Philippines, Portugal, Russian Federation, Saudi Arabia, Senegal, Serbia, Sierra Leone, Slovakia, South Africa, South Korea, Spain, Sudan, Suriname, Swaziland, Sweden, Tanzania, Thailand, Turkey, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, Vietnam, Zambia, Zimbabwe.
The countries of origin for Tantalum may include: Australia, Brazil, Burundi, China, Democratic Republic of the Congo, Ethiopia, Mozambique, Nigeria, Rwanda, Sierra Leone, 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, France, Indonesia, Laos, Malaysia, Myanmar, Namibia, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Spain, Tanzania, Taiwan, Thailand, United Kingdom of Great Britain and Northern Ireland, Venezuela, Vietnam.
The countries of origin for Tungsten may include: Australia, Austria, Bolivia, Brazil, Burundi, China, Democratic Republic of the Congo, Kazakhstan, Kyrgyzstan, Malaysia, Mexico, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Spain, Thailand, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, 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, 242 (268 in 2021) had reported smelters that process conflict minerals originating in one or more of the Covered Countries and 243 (245 in 2021) from other Conflict-Affected Countries and High-Risk Areas. Altogether 82 smelters in the consolidated smelter list (24% 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. 67 smelters were found to be conformant and 2 active in the RMAP validation process. 31 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 2023 with regard to those smelters.
Extending Due Diligence to Cobalt and Mica
In 2022, we also undertook a mapping of cobalt and mica in our components based on extended minerals material declarations for product parts. We addressed 79 relevant suppliers about our requirements regarding cobalt and requested them to exercise due diligence over the cobalt supply
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chain and 19 suppliers with mica. 68% of suppliers for cobalt and 21% for mica have completed mapping their cobalt and mica supply chains and as a result, we have been able to identify 71 cobalt and 17 mica smelters in our cobalt supply chain, out of which 59% (cobalt) and 18% (mica) have gone through the Responsible Minerals Assurance Program and have either Conformant or Active status. In 2022, we undertook an assessment of our entire list of materials against ESG risks and beyond 3TGs, cobalt and mica and started to map the mechanics supply chains related to copper, steel, nickel and aluminum.
For upstream engagement we have continued our work with the Public-Private Alliance, contributing to the development of in-region programs. In 2022, we helped to fund one of the local programs dealing with expanding children's educational access and socio-economic 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.
Progress on Commitments made in 2022 Conflict Minerals Report
| Target for 2022 | Progress 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; | 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 2022, Smelter mapping by our suppliers was completed at 97% on average (Tantalum 96%, Tin 97%, Tungsten 96%, Gold 97%). 97% of the smelters from which our suppliers sourced tantalum were conflict-free, for tungsten 79% of smelters were conflict-free and for tin 69% and for gold (60%). The phase-out of problematic smelters continued with 7 suppliers reporting such entities in 2022 against 10 in 2021. |
| 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, 73% of smelters were validated as conflict-free or currently engaged in industry third party validation process and 14% 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 or suspended from the audit program (Russian smelters) and dropped on their conformant status. |
| Validating the due diligence efforts of our suppliers as part of overall supplier assessments. | In 2022, we did not conduct independent third party onsite audits to our suppliers focused on conflict-free sourcing due to pandemic related restrictions. However, 67 of our Corporate Responsibility audits included conflict minerals sourcing as part of assessment checklist. |
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NOKIA COMMITMENTS FOR 2023:
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 2023:
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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