SEC Form SD filed by Nokia Corporation Sponsored

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)

Johanna Mandelin, Vice President, Corporate Legal
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:

Section 1 – Conflict Minerals Disclosure

Nokia Corporation (the “Company” or “Nokia”) invests in technologies important in a world where billions of devices are connected.

At the end of 2024, Nokia had four business groups: Network Infrastructure, Mobile Networks, Cloud and Network Services and Nokia Technologies, each of them aiming to become a technology and market leader in their respective sector. Network Infrastructure delivers fixed access, IP routing and optical transport for business-critical and mission-critical applications for communications service providers, enterprise and webscale customers. Mobile Networks creates products and services covering all 3GPP mobile technology generations. Its portfolio includes products for radio access networks (RAN) and microwave radio links for transport networks, solutions for network management, as well as network planning, optimization, network deployment and technical support services. Cloud and Network Services provides open, secure, automated and scalable software and solutions that accelerate the journey of service providers and enterprises to autonomous networks and new value creation. Nokia Technologies is responsible for managing Nokia’s patent portfolio and monetizing Nokia’s intellectual property, including patents and technologies.

Products manufactured by Nokia, or for which Nokia contracted with third parties to manufacture, during the year ended December 31, 2024 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.

Nokia has a policy which describes Nokia’s commitment to responsible minerals sourcing and measures taken to reach that goal. Nokia’s long-term commitment to sustainability and responsible sourcing has seen us take action individually and collectively to move this agenda forward in search of solutions. We have been members in joint industry efforts such as the Responsible Minerals Initiative (“RMI”), participants in the development and implementation of the OECD Due Diligence Guidance for Responsible Supply Chains together with other stakeholders, and we support various initiatives that seek to support the development of traceable, responsible trade in the Covered Countries (defined below) such as Public-Private Alliance for Responsible Minerals Trade.

Nokia has performed a reasonable country of origin inquiry that was designed to reasonably determine whether any of the Conflict Minerals originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (the “Covered Countries”) or are from fully recycled or scrap sources. In the design of our reasonable country of origin inquiry and due diligence activities, we have aligned with the internationally recognized due diligence framework provided by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas (OECD 2016). All businesses subject to the Rule are covered.

As a downstream company, Nokia is many supply chain tiers away from mining activities and has no direct business relationship with mines or metal processing facilities. Nokia does not directly buy any mineral ores or even refined metals. Therefore, in order to conduct the reasonable country of origin inquiry, Nokia used a combination of actions. For instance, 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’s due diligence process relies 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 places of origin 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 2024 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, 2024 originated in the Covered Countries.

For 2024, we determined that the Conflict Minerals used in Nokia’s products originated from the following countries:

Argentina, Australia, Austria, Azerbaijan, Benin, Bolivia (Plurinational State of), Bosnia and Herzegovina, Botswana, Brazil, Bulgaria, Burkina Faso, Burundi, Cambodia, Canada, Chile, China, Colombia, Republic of Congo (Congo-Brazzaville), Democratic Republic of the Congo, Costa Rica, Côte d'Ivoire, Djibouti, Dominican Republic, Ecuador, Egypt, Eswatini, Ethiopia, Finland, France, French Guiana, Georgia, Germany, Ghana, Guinea, Guyana, Honduras, Hungary, India, Indonesia, Japan, Kazakhstan, Kenya, Republic of Korea, Kyrgyzstan, Lao People's Democratic Republic, Liberia, Madagascar, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Myanmar, Namibia, New Zealand, Nicaragua, Niger, Nigeria,

Oman, Panama, Papua New Guinea, Peru, Philippines, Portugal, Russia, Rwanda, Saudi Arabia, Senegal, Sierra Leone, Slovakia, South Africa, Spain, Sudan, Suriname, Sweden, Tajikistan, Tanzania, Thailand, Turkey, Uganda, United Kingdom of Great Britain and Northern Ireland, United States of America, Uzbekistan, 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.

Section 2 – Resource Extraction Issuer Disclosure

Not applicable.

Section 3 – 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.

Dated: May 28, 2025