1 PURPOSE OF THE CODE OF CONDUCT
This Code of Conduct describes the operating culture at Nokian Tyres, generally accepted courses of action and commitment to working in accordance with the legislation and regulations. We at Nokian Tyres are committed to acting ethically, responsibly and in support of sustainable development. The purpose of this Code of Conduct is to assist people in making the ethically right decisions in their daily work throughout the Nokian Tyres organisation. The Code of Conduct also invites thoughts and discussion regarding the further development and expansion of ethically sound operations.
1.2 Application of the Code of Conduct
This Code of Conduct applies to all Nokian Tyres’ employees in all countries, regardless of their position or the nature of their employment. The management and supervisors in particular are responsible for leading by example and acting in compliance with the Code of Conduct. The Code of Conduct applies to all companies within the Nokian Tyres group. This Code of Conduct contains the general principles that all personnel need to adhere to in all their activities related to Nokian Tyres. The Code of Conduct shall also be applied when a person is representing Nokian Tyres outside of the work context, such as when representing Nokian Tyres on social media.
We will also provide guidance to employees regarding the company’s courses of action by means of separate written procedures that define the responsibilities of different parties for implementing these coursesof action. This Code of Conduct does not only apply to Nokian Tyres’ personnel, since external people and companies are essential for our work. We require that all third parties adhere to the appropriate parts of this Code of Conduct when operating with us or on our behalf.
This Code of Conduct has been approved by Nokian Tyres’ Board of Directors, and the Board has overall responsibility for adherence to the Code at Nokian Tyres. The President & CEO is responsible for the Code being adhered to systematically and by means of clearly defined authority. The Board of Directors, President and CEO and the other senior management must, by means of a visible, active example, demonstrate that they are applying these principles in all of their activities.
All Nokian Tyres personnel are, for their part, responsible for adhering to the Code.
The Group General Counsel is responsible for keeping the Code of Conduct up to date and providing practical advice for its application.
2 FAIR AND RESPECTFUL TREATMENT OF INDIVIDUALS
2.1 Commitment to international principles
We are committed to acting in the manner required by the UN’s Guiding Principles for Business and Human Rights, and to following the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work.
Nokian Tyres has joined the UN’s Global Compact initiative as a supporting member and follows the ethical principles of the initiative.
We respect human rights and treat all individuals equally.
We value diversity and do not allow any form of discrimination, harassment or bullying at the workplace. Everyone is responsible for acting fairly and creating a pleasant, inspiring work atmosphere.
Everyone has the freedom of expression, but everyone is also responsible for their own expression.
2.3 Working conditions
Our goal is to minimise the number of occupational accidents and promote occupational health. Occupational health and safety is an integral part of our daily management. Everyone is responsible for adhering to occupational safety guidelines, observing defects and shortcomings and removing hazards. In our activities, we emphasise the prevention of occupational accidents in order to avoid hazardous situations.
2.4 Participation and terms of employment
Active participation at different levels of the organisation and respecting the right of participation are parts of our working culture. Nokian Tyres respects the freedom of association and the freedom of workers to organise.
We do not approve of forced labour, human trafficking or child labour.
Contracts of employment are drawn up in writing and in adherence with the local legislation. Nokian Tyres will never pay anyone less than the minimum wage defined in the local legislation.
3 CARING FOR THE ENVIRONMENT
We are committed to continuously developing our products, functions and production facilities in order to reduce our adverse effects on the environment and optimise our consumption of natural resources. We are also committed to protecting biodiversity.
Furthermore, we are committed to reducing greenhouse gas emissions and preventing the pollution of the air, water systems and the soil. We also take environmental impacts into account in our delivery chain.
In all our activities, we also consider the environmental principles of the UN Global Compact initiative.
4 BUSINESS INTEGRITY
4.1 Compliance with the legislation
In our operations, we comply with existing acts and decrees, good Western business practices and the company’s own rules and policies.
Adherence to the applicable legislation and a respect for international commitments and the principles of sound governance form the basis of these policies.
Operating in a morally and ethically sound manner is important in international business. We are committed to working as a company that is aware of its corporate social responsibility and that acts responsibly while supporting sustainable development. Our goal is to continuously improve our own operations.
4.2 Financial information
As a publicly listed company, we follow all the legislation related to companies listed on the stock exchange.
In our accounting and reporting, we follow the local laws and generally accepted standards for financial statements. These allow us to make responsible decisions and to provide truthful, complete, up to date and accurate information on our operations.
We enter all business transactions completely and correctly in our accounting. Entries that are incorrect and do not depict the factual nature of the transaction are prohibited. We act in compliance with the legislation concerning money laundering.
4.3 Insider trading regulations
As regards insider trading matters, we follow the Finnish legislation, the Securities Markets Act, the Market Abuse Regulation (MAR) of the European Parliament and of the Council and its supplementary provisions, and the Guidelines for Insiders of Helsinki Stock Exchange.
Nokian Tyres’ Board of Directors has approved the company's internal Insider Guidelines.
4.4 Confidential information
We protect our business secrets and other confidential information as well as that of our partners. Our personnel or partners may not disclose or use such information without permission.
We respect the protection of privacy and adhere to privacy legislation.
Personal data provided by employees, customers, partners and other parties will only be used in the manner stipulated in the legislation concerning privacy.
4.6 Anti-bribery activities
We do not condone any form of bribery within our operations. Our employees or their closely associated persons may not offer, accept or otherwise approve of benefits, gifts or hospitality that may have an inappropriate effect on their decision-making at work.
We take special care and caution as regards to offering benefits, gifts and hospitality when dealing with government officials.
4.7 Protection of the company’s assets
We protect the company’s financial, material and immaterial assets, such as the company’s trade secrets, copyrights, trademarks, patents, tools and real estate. Nokian Tyres’ assets must be used carefully and only for the purposes of achieving the company’s business goals. The use of the company’s assets for personal purposes or to the detriment of the company is prohibited.
4.8 Conflicts of interest
We are loyal towards the company in everything we do. A conflict of interest is created when an employee or their closely associated person has a personal, financial or other interest that may be in conflict with the interest of Nokian Tyres. Before proceeding on the matter, our employees must notify their supervisor of any conflicts of interest.
We choose our employees and partners based on their competence and professional skill. We do not hire or sign contracts with relatives, friends or acquaintances or companies they represent on the basis of their personal relationships with our personnel. In such a case, the employee with a conflict of interest cannot participate in the decision on the selection of the employee or partner.
4.9 Anti-trust legislation
We at Nokian Tyres support fair and open competition. We adhere to applicable anti-trust legislation and do not condone any infringements thereto. All our employees must avoid situations that may lead to infringements of anti-trust legislation. Our employees must take into account the company’s guidelines concerning anti-trust legislation in all their actions.
4.10 Sanctions and other restrictions of trade
In cross-border trade, we adhere to any possible sanctions and other restrictions of trade and the limitations they set on the export and import of products.
4.11 Working with our partners
We identify our partners and require that they act ethically, responsibly and in a sustainable manner in terms of the environment. We require that our partners adhere to the legislation and the international regulations and principles concerning human rights, working conditions and the environment.
5 RESPONSIBLE COMMUNICATIONS AND MARKETING
5.1 Communications and marketing
Our goal is to achieve efficient contact with our personnel and interest groups. We will always communicate reliably and in a balanced and timely manner.
All our employees represent Nokian Tyres, its functions and activities in a suitable manner towards the different interest groups.
We market according to good practice and provide truthful information in our marketing.
5.2 Sponsorships and donations
Our sponsorship activities are aimed at promoting business and increasing awareness of the company. Our sponsorship activities are honest and in line with the legislation and good business practices. All sponsored activities must support the company’s values and the corporate image.
Nokian Tyres may also make donations to charitable purposes in accordance with the principles defined by the company.
Nokian Tyres does not provide monetary support to political parties or groups or individual politicians.
6 NOTIFYING OF SUSPECTED VIOLATIONS
Every employee at Nokian Tyres is obligated to be aware of this Code of Conduct and the more detailed guidelines related to it, and to adhere to them.
If you, as a Nokian Tyres employee, observe or suspect financial malpractice or observe a practice that is in violation of this Code of Conduct, please immediately contact your supervisor. Your supervisor must take immediate action. You can also contact Internal Audit, Legal & Compliance or HR unit.
Regarding questions of interpretation concerning the working environment, HR matters or other similar questions, you should primarily contact Nokian Tyres’ HR unit.
Suspected infringements can always be reported by sending an email to email@example.com or by regular mail to Nokian Tyres plc, Compliance, PO Box 20, FI-37101, Finland. These reporting channels are also available to all third parties.
Primarily, you should state your own name in your report in order to make further investigation more efficient. However, you can also make an anonymous report.
At Nokian Tyres, we also commit ourselves to carefully investigating all reports and taking the necessary action in relation to the report, regardless of the channel that it arrives through. We do not tolerate any form of inappropriate treatment towards the person making the report.
It is prohibited to make reports with malicious intent or otherwise using incorrect information.
The personal data in the whistleblowing system is protected against unauthorised access. At Nokian Tyres, we process the personal data and other information entered into the whistleblowing system with absolute confidentiality and in the manner required by the privacy legislation. For more information regarding the processing of personal data, please read our Privacy Policies.
Nokian Tyres’ Whistleblowing instructions also apply to the reporting channel.