Nokian Renkaiden eettiset ohjeet 1 Purpose and Limitations This document describes the basic ethical rules and guidelines Nokian Tyres plc upholds, aiming for good corporate social responsibility and sustainable development. At the same time, this document describes the values and norms Nokian Tyres plc expects all of its employees to conform to when working for or acting as representatives of Nokian Tyres plc. 2 Scope This document applies to all of Nokian Tyres plc and all companies in the Nokian Tyres group, including all sales companies and equity-owned Vianor stores, in all countries. All of these units are commonly referred to as Nokian Tyres in this document. 3 Responsibilities The key responsibilities are listed in the table below. Task Responsibility 1 2 3 3.1 3.2 3.3 3.4 3.5 4 5 6 1 Group level guidelines (this document) X X 2 Distribution of this document X X X X X 3 Implementation of the guidelines X X X X X X X X X X 4 Detailed policies, operational manuals and guidelines for different areas of operations or different tasks X X 5 Internal and external communications on ethics X X 6 Financial information and control X X 7 HR, Labour and safety X X 8 Quality, environmental and responsibility issues X X 9 Management of supplier networks X X 10 Reporting possible deviations to supervisors or specialists X 11 General monitoring X X Responsibilities: 1 = Board of Directors (NT plc) 2 = CEO and President (NT plc) 3 = Named Vice presidents or other persons within Nokian Tyres 3.1. Vice President, Marketing & Communications (NT plc) 3.2. CFO (NT plc) 3.3. Vice President, HR (NT plc) 3.4. Vice President, Quality and Sustainability (NT plc) 3.5. Vice President, Supply Operations (NT plc) 4 = Management, All companies in Nokian Tyres Group 5 = Personnel 6 = Internal auditing 4 Ethics policy When working for Nokian Tyres or representing the company, all personnel should aim at the correct ethical and moral behaviour. Local and International laws must be followed at all times. When facing moral questions or dilemmas, members of staff can ask for support from supervisors and management, or from the various specialists in the service functions. When it is impossible to ask for help, individuals should trust their own judgement. All stakeholders connected with Nokian Tyres should be able to trust the moral and ethical behaviour of Nokian Tyres and its personnel. In global business and a rapidly changing world, morality and ethics are acknowledged as difficult subjects. Identifying problems, acquiring all the necessary information and making the right decisions can be difficult. Regardless, Nokian Tyres is committed to aiming at good corporate social responsibility, sustainable development and continuous improvement. Should any indications or accusations of possible violations to these principles appear, Nokian Tyres is committed to investigating any allegations and taking the necessary actions to correct all unclear situations. All Nokian Tyres personnel are encouraged to bring forward their concerns related to the realization of this document. 5 Operational Principles Nokian Tyres is committed to good corporate citizenship and follows these principles in all of its operations. These principles are available to all Nokian Tyres personnel, who are expected and encouraged to uphold these principles when working for the company. Nokian Tyres aims to be a profitable company and to ensure sustainability. At the same time, the company aims to minimize the use of common resources and negative impacts on the social, economical and environmental surroundings. Local legislation and norms must be followed in all operations. In a case of nonconformity, development plans must be created to correct the situation as soon as possible. If necessary, the authorities must be informed and included in the development work. Besides local legislation, the internal rules and guidelines concerning the whole of the Nokian Tyres group must be followed at all times. As well as good Western business practices and customs, the local customs and legal practices must always be respected. Nokian Tyres follows the local requirements for accounting and financial control as well as the IFRS standards for consolidated accounts in all of its bookkeeping. Nokian Tyres only gives truthful information and aims at a comprehensive and timely description of current events in its internal and external communications. The rules set for publicly listed companies are followed in all communications. Nokian Tyres designs and tests all of its products to ensure good quality and conformity to the law. Nokian Tyres aims to be a forerunner with regard to the safety and environmental aspects of its products. Nokian Tyres supports and respects the protection of human rights as stated in The United Nations Universal Declaration of Human Rights. Nokian Tyres will never approve of or willingly participate in any abuse of human rights under any circumstance.When considering human rights in Nokian Tyres operations the United Nations’ Guiding Principles on Business and Human Rights are noted. Nokian Tyres recognizes the internationally proclaimed rights of Indigenous peoples. Nokian Tyres is committed to the protection of environment and sustainable development. Nokian Tyres wants to act as a forerunner in environmental issues. Nokian Tyres believes that open communication with public offices and honest co-operation with the officials is the best way to ensure the best results for both the company and society. Nokian Tyres does not approve of corruption in any form, including giving or accepting bribes, extortion or misuse of public position. As a non-political entity, Nokian Tyres does not take part in political activity, fund-raising or political donations. Nokian Tyres commits to engage in fair competition, in compliance with antitrust and competition laws and regulations globally. Nokian Tyres does not approve of giving or approving gifts or service, other than those oflow or nominal value that can be considered to be within normal marketing and business customs, and carry no commitments or obligations. Consideration and local legislation must be followed at all times, including possible local legislation forbidding any presents. All personnel working at Nokian Tyres are entitled to fair and proper treatment at work at all times. All forms of discrimination, harassment or abuse are strictly forbidden. Nokian Tyres embraces the idea of equality between all humans, regardless of gender, age, race, education, status, religion, politic opinion, appearance or other external factors. Nokian Tyres upholds the idea of diversity in it’s personnel. Everyone working at Nokian Tyres has the right to contact their supervisors when necessary, to make initiatives and suggestions, and to get feedback on their ideas and concerns. When making suggestions or reporting possible problems, members of staff can by-pass the normal chain of command in order to directly contact the people in charge. When reporting possible violations to these codes or other group policies, a wide array of communication channels are available for use, as described in the group manual for whistleblowing practices. In addition, the personnel can also contact the CEO at all times, should the gravity of the matter so demand. Nokian Tyres respects the privacy of all personnel, and has organized the handling of personal information accordingly. Nokian Tyres recognises the need for due care and fulfilling legal obligations in handling any private or confidential information of its stakeholders and partners. Employment at Nokian Tyres is always based on clear and unambiguous labour contracts, which are drawn up in conformity with the local legislation and any applicable collective agreements. Nokian Tyres never pays less than the minimum wage set in the local legislation. Nokian Tyres upholds freedom of association and works in co-operation with any duly named representatives of labour unions. Nokian Tyres does not approve of child labour or the use of forced or slave work. Penal servitude work is only allowed when it is done within an approved legal context and the funds are collected for the personal use of the penitents. Nokian Tyres does not approve of human trafficking in any form. Nokian Tyres expects a high moral standard from its partners as well, including materials suppliers. Nokian Tyres monitors all partners on a general level, as applicable. Should there be any doubt or suspicion regarding the morality of a partner, Nokian Tyres is committed to investigating the accusations and taking any measures necessary to amend the situation. When disciplinary measures are necessary, local legislation and normally accepted or agreed methods are used. However, Nokian Tyres does not allow any form of physical or mental violence as a disciplinary action. Furthermore, the person accused of the offence must always be allowed to defend or explain his or her actions before any decisions on disciplinary measures are taken. 6 Code of conduct for personnel All persons working for Nokian Tyres or representing Nokian Tyres are expected to act in an ethical and moral way at all times. These basic rules are listed to advise the personnel of proper conduct at work: All personnel must follow the law and company policies at all times. All fraudulent abuse of one’s status, power or possibilities at work is forbidden. All forms of discrimination, bullying or harassment are forbidden. While open discussion of all matters related to work or the working community is encouraged, consideration and courtesy are expected at all times. Most information concerning work or individuals at the workplace is to be considered confidential at all times. Confidentiality must be followed in the distribution of information both internally and outside the company. All personnel are expected to inform their supervisor and ask for permission if they intend to initiate or participate in any uncommon non-work-related activities at their workplace, such as trade, political or religious activities. The personnel are not allowed to accept or give any major or uncommon gifts, i.e. any gifts or services other than those of low or nominal value that can be considered to be within normal marketing and business customs, and carry no commitments or obligations. These rules also apply when a person is representing Nokian Tyres outside of the normal working situation, for example in the social media or in gatherings of people where the person is strongly identified as a representative of Nokian Tyres. All personnel are expected to identify such situations and act accordingly. In addition, the confidentiality of work-related information applies at all times. Should any member of staff witness violations to these rules, he or she is expected to inform a supervisor or other named person of the violation. 7 Implementation, control and monitoring It is the responsibility of each manager and employee to implement and monitor the realization of the principles presented in this document in the actual operations. All personnel are entitled to give feedback, make suggestions and report any witnessed or suspected offences. The first point of contact should be the individual's own supervisor. There is a separate network of named support personnel who can be contacted on various specific issues (for example personnel, safety and environmental specialists). It is also possible to use the elected representatives to carry the messages. Implementation of these rules, the results achieved and any breaches of the rules are monitored by the responsible parties. Many of the issues presented are included in the periodical external communications released by Nokian Tyres, especially in the annual reports and environmental reports. Nokian Tyres aims to improve the communications annually. The final responsibility for putting these principles into practice is always with the President and CEO of Nokian Tyres plc, Vice Presidents and Top Management within the Nokian Tyres group. The general realization of these principles, and any violations are also monitored by the internal auditors, who report their findings to the Board of Directors. If the normal communications channels cannot be used for any major offences, it is possible for the personnel or external parties to directly contact the internal auditors, CEO or Board of Directors to report any findings. In general it is suggested, that any problems noted or suspected by the informers would be handled with the units, departments, or persons in charge of the said issues, to ensure efficiency of handling the issues. In cases where the informer does not want to contact the persons in charge of the current issue, it is possible to contact the higher management of the company, the CFO or CEO of Nokian Tyres plc (ir(at)nokiantyres.com), the Internal Auditors in Vianor companies, or as the final line the group level Internal Audit activity, or the CAE. For the last two, the informer should use the group level contact address whistleblow(at)nokiantyres.com. Please note, that to ensure proper handling of any issue, it is suggested that as much detailed information as possible would be given to the person or persons contacted. It is suggested, that any information includes the name and contact information of the informer, but this is not demanded. In any case, all action is done to prevent any harm to the informer due to the whistleblowing. Please note also, that depending on the complexity of the issue, the local legislation of each country, and other factors, any investigation can take time, and it might not be possible to inform the informer of the progress of the investigation.