Nokia Corp

<!--td {border: 1px solid #ccc;}br {mso-data-placement:same-cell;}--> In 2018, CalSTRS identified Nokia as possibly providing telecommunications equipment and services to Iran and began the review process. (https://www.calstrs.com/sites/main/files/file-attachments/calstrs_investment_reports_2018.pdf)

"GIANTS WITH A FOOT IN TEHRAN: Total, Shell, Statoil, BNP Paribas, Commerzbank, MTN, UPS, Linde, Technip, Nokia, Ericsson, Peugeot, Renault, OMV, Societe Generale, ENI, Mitsubishi, Sumitomo, Siemens, LG, Samsung, Bosch, Valeo, Nestle, Unilever, BAT, Japan Tobacco." (The London Times, "American pressure threatens UK firms," 5/27/06) (http://business.timesonline.co.uk/tol/business/economics/article727079.ece)

Although we evaluate our business activities on an ongoing basis, we intend to continue not accepting any new business in Iran in 2020 and intend to only complete existing contractual obligations in Iran in compliance with applicable economic sanctions and other trade-related laws."

As of April 2022, Nokia's website lists the Iranian company by the name of Pishahang Communications Networks Development Company as an affiliate. (https://www.nokia.com/notices/privacy/affiliates/)

CalPERs 2021 California Public Divest from Iran Act and Sudan Act Legislative Report has maintained the company [Nokia Corp] in “monitor” status for 2021. (https://www.calpers.ca.gov/docs/board-agendas/202111/invest/item06g-01_a.pdf)

We continue to maintain routine contacts with governmental agencies in Iran as required, for example, to maintain a legal presence and office facilities in Iran, pay taxes and employ Iranian nationals.

"Nokia-Siemens Networks on Wednesday, June 2 admitted its share of the blame for Iran's brutal crackdown on anti-government demonstrators last year after selling mobile phone surveillance to the authoritarian regime.

The Finnish-German telecoms joint venture was at the centre of an ethics controversy last year when it emerged that it had supplied surveillance technology to two Iranian mobile phone operators. The technology was used to track down dissidents amid the mass protests following the contested re-election of President Mahmoud Ahmadinejad in June 2009.

"The company has been identified as potentially providing telecommunications services in Iran. In 2019 CalPERS designated the company as under review. In 2020 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS continues to monitor the company for possible changes in status relevant to the Act." (https://www.calpers.ca.gov/docs/forms-publications/iran-sudan-divestment-2020.pdf)

"An imprisoned Iranian activist [Isa Saharkhiz] is suing Nokia Siemens Networks (NSN) over allegations that the telecommunications company provided the Islamic regime with a monitoring system it used to spy on the opposition Green movement.... Saharkhiz, who is still in detention, discovered during his interrogation in Tehran's Evin prison that his whereabouts were revealed when security officials listened in to his mobile phone conversations using technology NSN allegedly sold to Iran, his son Mehdi told the Guardian." (The Guardian, "Iranain activist sues telecom firm over 'spying system,'" 8/24/2010) (http://www.guardian.co.uk/world/2010/aug/24/iranian-sues-nokia-siemens-networks)

"...the Iranian government appears to be engaging in a practice often called deep packet inspection, which enables authorities to not only block communication but to monitor it to gather information about individuals, as well as alter it for disinformation purposes, according to these experts. The monitoring capability was provided, at least in part, by a joint venture of Siemens AG, the German conglomerate, and Nokia Corp., the Finnish cellphone company, in the second half of 2008, Ben Roome, a spokesman for the joint venture, confirmed." (Wall Street Journal, "Iran's Web Spying Aided By Western Technology," 6/22/09) (http://online.wsj.com/article/SB124562668777335653.html)

"Saber Feyzi, managing director of TCI said sanctions havent stopped IT providers from selling to Iran as contracts for equipment such as switches and transmission and radio systems show. Companies including Siemens, Nokia , Eriksson, Alcatel-Lucent, Cisco Systems, Telaps, NEC, ZTE, Huawei Technologies Co and Wuhan Research Institute have all supplied the Islamic republic. Iranian officials have dismissed US sanctions as inefficient, saying that they are finding Asian partners instead. Several Asian firms are negotiating or signing up to deals with Iran." (Gulf Times, "Iran Telecom Firm to offer 50% stake by March," 1/14/09) (http://www.gulf-times.com/site/topics/printArticle.asp?cu_no=2&item_no=266205&version=1&template_id=48&parent_id=28)

According to its 2020 SEC Filing,  "In connection with the business activities relating to Iran, we have two local offices in Iran that employed approximately 55 employees at the end of 2019 through a branch of a Finnish subsidiary. Nokia is the controlling shareholder in Pishahang Communications Network Development Company (Pishahang). The other minority shareholder in Pishahang is Information Technology Application Development TACFAM Company (Tacfam). (https://sec.report/Document/0001558370-20-002053/nok-20191231x20f.htm)

Nokia Corp. (a Finnish company) began its 2017 disclosure by noting its two local offices in Iran that employ 50 employees through a branch of a Finnish subsidiary and three employees through a branch of Alcatel Lucent International. Nokia described “routine contacts with government agencies” required to maintain its legal presence, including its tenancy of office facilities, payment of taxes, and employ of Iranian nationals. Relatedly, Nokia disclosed the maintenance of bank accounts for financial transactions in Iran and providing telecommunication equipment and services to Iranian mobile network operators. (https://www.shearman.com/Perspectives/2018/01/Dynamics-in-the-Era-Iran-Sanctions)

Although it is difficult to evaluate with any reasonable degree of certainty, we have concluded that we cannot exclude the possibility that MCCI, MTN Irancell, TCI or Tacfam is owned or controlled, directly or indirectly, by the government of Iran. None of these activities involve U.S. affiliates of Nokia, or any persons from the United States.

To our knowledge, none of our sales in Iran in 2019 are required to be disclosed pursuant to ITRA Section 219, with the possible exception of the following:

Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, List of Companies Doing Business With State Sponsors Of Terror, Removed from the internet in July of 2007)

In 2018 Nokia was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.     (https://web.archive.org/web/20180304055352/https://comptroller.texas.gov/purchasing/docs/anti-bds.pdf)

Nokia Corporation, a Finnish multinational communications and information technology company, and an Iranian internet service provider company inked an agreement in Helsinki to launch TDD-LTE (high-speed wireless communication for mobile phones and data terminals) in Iran. The agreement was signed in a ceremony participated by the Iranian and Finnish communications ministers as well as the CEOs of Nokia and the Iranian company. According to Mohammad Hassan Shanehsazzadeh, the CEO of the Iranian company, the agreement will open the way for using Nokia's know-how and solutions to launch TDD-LTE services in Iran. (Fars News, "Nokia Signs Contract to Launch TDD-LTE in Iran," 9/14/2016). (http://en.farsnews.com/newstext.aspx?nn=13950624001035)

--

In 2019, we continued only with our existing contractual obligations in compliance with applicable economic sanctions and other trade-related laws including limited local delivery of radio, core and transmission equipment, including associated services, to MTN Irancell and some software and features to Mobile Communications Company of Iran (MCCI). We also provided some services to local fixed networks operators, Telecommunication Company of Iran (TCI) and, additionally, in 2019, we purchased certain fixed line telephony services from TCI and mobile phone subscriptions from MCCI.

In 2017 the U.S. state of Michigan listed Nokia as an Iran restricted company rendering Nokia ineligible for investment and/or state contracting.  (http://www.michigan.gov/documents/treasury/Divested_Securities_380236_7.pdf)

(Businessweek.com, "Nokia-Siemens Rues Iran Crackdown Role," 6/3/2010) (http://www.businessweek.com/globalbiz/content/jun2010/gb2010063_509207.htm)

Nokia does not normally allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Nokia's consolidated financial statements prepared in accordance with IFRS. Therefore, for this exercise Nokia will reflect its sales margin in lieu of the net profit / loss. In 2019, we recognized net sales of EUR 0.47 million and a negative sales margin of EUR 0.2 million from business with MCCI, net sales of EUR 7.76 million and a sales margin of EUR 0.79 million from business with MTN Irancell and net sales of EUR 0.06 million and a negative sales margin of EUR 0.39 million from business with TCI

"Nokia, which has sold mobile devices and accessories to Iran since at least 2004, said in a 2010 Securities and Exchange Commission filing that it was gaining market share there. Nokia's contracts with the American government include providing telecommunication services to the Department of Defense and the Drug Enforcement Administration. Contracts that were separately awarded to Nokia-Siemens, a joint venture, were not included in the company's totals here."  From 2000-2009, the company was the recipient of $16.6 million US federal funds.  Their business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010) (http://www.nytimes.com/interactive/2010/03/06/world/iran-sanctions.html)

In 2019 Nokia was removed from the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.   (https://comptroller.texas.gov/purchasing/publications/divestment.php)

Apart from the crackdown on demonstrators, which saw 36 confirmed deaths, Iranian authorities blocked websites such as Twitter and Facebook, jammed and tracked cell phone calls and text messages. They used the so-called monitoring centre acquired from Nokia-Siemens in 2008 to carry out the work."