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"In 2022, our audits uncovered 15 cases related to non-compliance or the potential risk of forced labor."

Case 1

Several cases concerned the recruitment process and the recruitment costs such as the cost of medical examination, COVID-19 testing or travel tickets that were initially borne by the migrant laborer in their home country and compensated only upon arrival into the destination country or as part of the first salary. This delay increases the potential risk of bonded labor. In one of the cases, supplier only supported partial return transportation cost back to their home country (flight but not ground transportation costs from the airport to the employee’s residence). Such findings were addressed by setting up a process where transportation fees are to be paid directly by the supplier or the labor agency, not by the worker. Nokia also highlighted these learnings from in its ethical recruitment webinar conducted for suppliers in 2022.

Case 2

There was also an instance of involuntary overtime work detected among the on-site security service provider workers who performed involuntary overtime work for 2.5 hours every day for six consecutive days in a week. The supplier addressed this and obtained a memo from the managing director of the security company stating working hours, overtime and break time have been communicated to and acknowledged with a signature by every security guard.

Case 3

Other cases included the auditee practicing an educational training bond (bonded labor) based on its training procedure which stated that workers who attend overseas training will be bonded for a period of six months up to a maximum of two years depending on the length of the training period. If the worker fails to serve the supplier after their training, the worker needs to pay back the training costs as per the training agreement signed between the employer and employee. The supplier verified that there were no cases of training bonds for workers and revised its training procedure at our request.

Case 4

We also uncovered three (four in 2021) instances of non-conformity related to child labor avoidance. Cases included a missing child labor policy or missing identity cards which meant that the auditor could not immediately verify the worker’s identity card. The suppliers took corrective actions by first developing a policy which also ensures worker files include a checklist requiring a copy of the identity card.

Case5

In April 2022, Nokia was notified, by a former business partner and employee of a supplier, of an alleged use of child labor and unsafe working practices by a subcontractor supplying services for a project between May and August 2021 in The Philippines. Nokia initiated its investigation process and immediately suspended the supplier from any further projects. Despite our best efforts, the potential victims could not be identified mainly due to the lack of documentation from the supplier. Although the supplier denied the allegations, evidence was gathered including professional medical opinion concerning the likely age of some individuals shown in received photo evidence. In the absence of certainty relating to some of the actual facts and circumstances, Nokia believes it is prudent to conclude that there may well have been a breach of Nokia’s Code of Conduct, and Human Rights Policy, related to the zero tolerance for child or forced labor of any kind in its own or supplier operations.Nokia made the decision to permanently block the supplier in question and any future supplier linked with the owner. For this case a remediation committee was established. As we could not conduct mitigation directly, we took a broader approach to help address one of the root causes for children and young people reaching the informal labor market. This root cause relates to dropping out of the formal education system. We have agreed a two-year program in The Philippines with an NGO partner that aims to strengthen alternative learning systems and ensure that young people complete an educational qualification.

"In 2022, our audits uncovered 15 cases related to non-compliance or the potential risk of forced labour. A few of the cases concerned missing or inadequate documentation, such as missing contract or appointment letter or missing content in the contract such as salary, working hours, and leave and benefit entitlements. There was also a case where contracts were not renewed after the fixed-term contract had ended. Most of these findings were addressed and closed, a few were still to be addressed in 2023. "