Health and Safety Country Manual

HSSE Operations - India Market

Author Mohamed Rasheel, Health, Safety Sec and Environment

Owner Mohamed Rasheel, Health, Safety Sec and Environment
Organization HSSE- Health, Safety, Security & Environment
Approver Marcus Parry, Head of HSSE, India & APJ Market
Document ID 34ILPQMI5LNL-1379666895-336
Document location 34ILPQMI5LNL-1379666895-336

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 Change History :
Reviewed Reviewed Approval
Version Status Date Author Owner by date
Approver
date
Description of changes
1.0 Approved 30-05- Dhananjay Dhananjay Dhananjay 30-05- Marcus 30-05- Drafted & Approved final version after India
2012 Vyawahare Vyawahare Vyawahare 2012 Parry 2012 OHS Meeting

2.0 Approved 09-08- Dhananjay Dhananjay Dhananjay 09-08- Marcus 09-08- Nokia Solutions and Networks – branding &
2014 Vyawahare Vyawahare Vyawahare 2014 Parry 2014 organisation changes

3.0 Approved 15-12- Mohamed Mohamed Dhananjay 18-12- Marcus 19-12- Leveling the workbook – manual (basics in
2016 Rasheel Rasheel Vyawahare 2016 Parry 2016 place / Mature aligned with H&S standards
4.0 Approved 04-10- Ismail Ismail Shyam 04-10- Marcus 10-10- Amended manual in line with Global 18001
2017 Chalimannil Chalimannil Swami 2017 Parry 2017 Management System

5.0 Approved 23-05- Mohamed Mohamed Shyam 27-05- Marcus 03-06- Included Life Saving Rules & other global key
2018 Rasheel Rasheel Swami 2018 Parry 2018 standards implementation requirements
including Consequence management &
Refusal to Work.
6.0 Approved 12-12- Mohamed Mohamed Shyam 15-12- Marcus 19-12- Nokia rebranding & medical Centre task
2018 Rasheel Rasheel Swami 2018 Parry 2018 modifications & set-up requirements

7.0 Approved 20-04- Mohamed Mohamed Shyam 21-04- Marcus 22-04- Modified emergency protocols, inclusion of
2019 Rasheel Rasheel Swami 2019 Parry 2019 SIRC control room & other services

9.0 Approved 13-01- Mohamed Mohamed Shyam 14-01- Marcus 18-01- Review,update and alignment with existing
2020 Rasheel Rasheel Swami 2020 Parry 2020 Nokia Management Systems documentation
and ISO 45001 – approved

9.0 Approved 26-05- Mohamed Mohamed Shyam 28-05- Marcus 01-06- Included new ‘Identified’ Training matrix-
2020 Rasheel Rasheel Swami 2020 Parry 2020 tracking sheet requirements, COVID-19
controls, HSSE New Organization Chart, Covid
War Room & SIRC inclusion & related
precautionary measures along with office
acessing protocols.

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Contents
1 Purpose ................................................................................................................... 5
2 Health & Safety Management at Nokia (context of the organization) ....................... 6
Understanding the needs and expectations of workers and other interested parties 7
Scope – Health and Safety management ................................................................ 7
3 Leadership and commitment ................................................................................... 8
Health Safety and Labour Conditions Policy ............................................................ 8
Country Level Organizational Roles, Responsibilities and Authorities...................... 9
Consultation and participation.................................................................................. 12
4 Planning .................................................................................................................. 13
Hazard identification and assessment of risks and opportunities ............................. 13
Legal requirements and other requirements ............................................................ 14
Health and safety objectives and planning ............................................................... 14
5 Support.................................................................................................................... 15
Competence, training and awareness...................................................................... 15
Awareness............................................................................................................... 16
Internal communication and awareness................................................................... 17
External communication .......................................................................................... 17
Documented information, Control of documents ...................................................... 18
6 Operation ................................................................................................................ 19
Operational planning, control and change management .......................................... 19
Eliminating hazard and reducing H&S risks. ............................................................ 20
Procurement ............................................................................................................ 20
Emergency preparedness and response ................................................................. 21
7 Performance evaluation ........................................................................................... 22
Monitoring, measurement, analysis and perfromance evaluation............................. 22
Internal audit programme......................................................................................... 22
Management review ................................................................................................ 23
8 Improvement ........................................................................................................... 24

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 Incident, nonconformity and corrective action .......................................................... 24
Continual improvement ............................................................................................ 25
9 References’ / links ................................................................................................... 25

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1 Purpose
The purpose of Country Health and Safety Management System Manual is to provide information
and guidance to all who work for and on behlf of Nokia at India Market level to implement the
Nokia Health & Safety Management System (H&S MS) across all Nokia India businesses including
offices, delivery sites, research centers & customer-manufacturing units.

This document should be read in conjunction with the Nokia Health & Safety Standard Operating
Procedure and global standards and procedures will be followed unless localized procedures are
required to comply with local H&S legislation or other relevant requirements to which Nokia
subscribes.

Further information relating to the Nokia health and safety management activities are available
from the company intranet and internet pages and from the annual Nokia Sustainability Report

 All key Health and Safety global documents are stored in Nokia Global SharePoint folder
https://nokia.sharepoint.com/sites/healthandsafetyservices
 People and Planet Report

For the purposes of this document the following definitions apply:

Table 1 Definitions

Term Definition

‘the country’ India

Business groups and functional areas, e.g. GS, NSW, HSS, IT, MN, FN,
‘relevant organization’ ION, NOPS, Customer Operations, RE, MCA, Legal & Country
Management

Those persons assigned responsibility within their organization for

‘nominated persons’
health and safety management.

H&S Health and Safety

HSE Health, Safety and Environment

Person at an individual site, nominated by the relevant Country

‘health & safety
Management Team, and assigned responsibility for health & safety
representative’
management at that site

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 Term Definition

‘Health & Safety Individuals with responsibility for health & safety management within
Operations’ Nokia

Team comprising the health & safety operations, health and safety
‘Health & Safety
representatives and the nominated persons from the relevant
Management Team’
organizations

Anyone who works for or on behalf of Nokia at all levels in the

‘Workers’
organization

‘reportable Health & Any incident that results in, or could potentially have lead to an injury,
Safety incident’ Illness and product safety

‘COVID-19’ Corona Virus Disease 2019

2 Health & Safety Management at Nokia

(context of the organization)
Nokia health & safety activities are based on Risk management thinking and
sustainable development.

The goal is to build

 A Nokia where everyone goes home safely at the end of the day by managing risk
and opportunities to prevent work related injuries and ill health to workers.

 To continually reduce the incidents and injuries associated with our business and
processes including design, operations, distribution, installation and support of
our product and systems.

Focus areas / specific programs of work to support these goals include, but are not
limited to:

 Nokia Life Saving Rules (LSR)/Non-negotiable standards

 Product Safety; serving our customers with safe products that do not endanger
life, health or property is fundamental and self-evident for our business success.
The implementation of Product Safety, concerns everyone within Nokia and all

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 Nokia business organizations are responsible for providing products that do not
endanger life, health or property during the entire product lifecycle.
 Where Nokia are installing, maintaining or operating our products and services the
process addresses all aspects of the process to minimize the health & safety risk
associated with these operations.
 Supply Chain/Procurement; The same sound health & safety and ethical principles that
are followed within Nokia operations are reflected in business relationships with Nokia
suppliers. The Nokia Supplier requirements include requirements relating to suppliers'
health & safety management and labor conditions. The implementation of these
requirements is done through contractual agreements, contractor management,
monitoring practices such as on-site and self-assessments, training and awareness
building.
 H&S Deep Dive; Nokia identifies those markets that are key business areas or have
higher than average incident rates and perform in-depth reviews with a view to
implementing actions to effectively, and efficiently, improve health & safety
performance.

Collectively these activities underpin the Nokia commitment to health & safety as
documented in the Health, Safety and Labor Conditions Policy (available from the
company intranet and internet sites and got displayed at all receptions, main notice
board display areas of Nokia India office facilities).

Required health & safety management activities are detailed in this document and the health
& safety management system. The objective of the document is to provide sufficient
information for persons with health & safety responsibility to implement the
necessary controls into their work activities.

Understanding the needs and expectations of workers and other interested parties

Nokia shall seek input of key stakeholders and seek input regarding health and safety relating to
internal and external issues. Key stakeholders of Nokia health and safety are those who work for
and on behalf of Nokia, customers, public authorities, suppliers, contractors, investors, general
public, NGO’s, etc. Understanding needs and expectations is done through consultation and
participation to include evaluation of risks and opportunities. Concerns, requirements and
suggestions shall be directed to the Nokia Global Health, Safety and Environment team.

Scope – Health and Safety management

The Health and Safety management activities of Nokia (as defined by this document and those to
which it refers) apply country wide including India.

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The Nokia Executive Board has determined that global Health and Safety Management
certification is maintained for the business Current certification is for OHSAS 18001:2007. In
2020 Nokia is transitioning for certification to the new ISO 45001:2018 Occupational Health and
Safety Management System standard. India facilities will start implementation of this new
standard requirements & further face audits as par Global Audit Plan.

Alongside internal and external issues, needs and expectations, health and safety regulatory
requirements and risks and opportunities are included in the Nokia health and safety
management system.

3 Leadership and commitment

India Country Management [CMT] has overall responsibility and accountability for the health and
safety management system. The CMT along with every BU heads across the Nokia India
organization are responsible for ensuring that the resources required to meet health and safety
needs within their area of responsibility are in place.

Nokia India Leadership

 Takes accountability for the effectiveness of the health & safety management system
 Ensuring that the Health, Safety and Labor Condition Policy and health & safety objectives
are established and are compatible with the strategic direction and the context of the
organization all across Nokia India facilities.
 Responsbility for integration of the Health and Safety management system requirements
into the business processes
 Ensuring that the resources needed for the health and safety management system are
available at all Nokia India based businesses.
 Communicating the importance of effective health & safety management and conforming to
the health and safety management system requirements
 Ensuring that the health and safety management system achieves its intended outcomes;
 Directing and supporting workers’ consultation and participation in contributing to the
effectiveness of the health and safety management system
 Promoting continual improvement;
 Protect workers from reprisals (report incident, refusal to work in hazardous condition)

Health Safety and Labour Conditions Policy

Nokia has publicly stated its commitment to health & safety in the Nokia Health, Safety and Labor
Conditions Policy (available from the company intranet site) and the Nokia Code of Conduct. The

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Policy is authorized by the Executive Board and should be communicated to all persons working
for, or with Nokia.

The Health, Safety and Labour Conditions Policy is binding for all persons when acting on behalf of
Nokia India. And further it got displayed at all prominent locations including receptions, main notice
board display areas of Nokia India office facilities).
India HSSE team supported by India CMT Head will ensure communication of the Global H&S Policy
to all employees in accordance to internal communication policy. H&S policy is also included with
employees Health & Safety Induction modules and with all other basic H&S trainings. The Global
Policy will be available to the public upon request and also ensured it got communicated to all
suppliers & vendors who are working with Nokia India businesses.

Country Level Organizational Roles, Responsibilities and Authorities

Nokia India leadership has overall accountability for the health & safety management
system and for ensuring that the resources required to meet the health & safety
needs within their area of responsibility are in place across businesses of Nokia India.

Here are the main roles and responsibilities across Nokia India businesses when setting up the H&S
management system. Depending of the H&S related roles listed in this chapter may be dual roles,
which can be appointed to suitable persons in the organization. If Country Senior Officer or CMT
will not officially nominate CMT H&S responsible and/or Country H&S Management System
Manager then by default is treated as Country H&S Management System Manager

Country Senior Officer, CMT Head:

 Accountable for the H&S of Nokia activities within the country.

 Country Director is allowed to appoint H&S nominated person and delegate H&S related duties
 Ensures that local H&S laws and employment standards are identified and complied with
 Ensures that there are sufficient resources for H&S management i.e. there is an H&S budget
and headcount to meet the legislative and other relevant country specific requirements.
 Ensures that adequate local H&S arrangements and related monitoring are undertaken to
meet the Nokia global and local standards.
 Ensures that reports on the performance of the H&S management system are presented to
senior management for periodical review and used as a basis for improvement of the H&S
management system
 Together with CMT sets the Key Performance Indicators (KPI) for H&S management and
regularly follows-up these KPI’s at country management meetings and reports them to the
regional head of H&S.

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India Country Management Team, CMT

 Regularly review the H&S matters with the CMT India H&S Manager.
 Country Management System Manager to be responsible for management system and inform
CMT about system performance results
 Makes strategic decisions over the management of H&S at a country level.
 Ensures that the KPI’s for H&S are set and achieved.
 Ensures that each function allocates sufficient resources for H&S (headcount, budget).
 Ensures that the H&S risks of Nokia activities are assessed.
 Ensures that Nokia global H&S guidelines and Nokia good practices are followed and that local
legal requirements are met.

Country H&S Management Team

 Has accountability for H&S management system on country level

 Ensures that H&S management system is established, implemented and maintained on
country level in accordance to global management system requirements and ISO
45001:2018
 Ensures that reports on the performance of the H&S management system are presented to
senior management for periodical review and used as a basis for improvement of the H&S
management system
 Ensures regular performance review and track together with local team that H&S
management system is continuously improved and adapted to changing business conditions

Nominated Persons-HSE

 Ensure that suitable personnel resources within their organization are appointed to address
H&S matters
 Ensure that there is a sufficient BU / function specific budget for H&S as well as systematic
follow-up of H&S related costs.
 Ensure that the BU / function country organization implements appropriate health and safety
procedures and that regular monitoring is undertaken to maintain Nokia global and India
localised H&S standards.
 Have a key role in ensuring that the organization, collaborators and contractors meet the H&S
standards and other relevant requirements, such as customers’ expectations.

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 Executes internal H&S audits and coordinates external audits
 Implementation & support towards Global Key standards implementation & focus areas
 Defines the H&S objectives and related KPIs for the organization and reports regularly the
H&S performance to India H&S Manager.
 Conduct Supplier Maturity Assessments (SMA) for all the High Risk activities based
contractors working across Nokia India businesses.
 Ensure supports with adequate resources for implementation of Life Saving Rules, H&S
global standards and management system requirements across span of control
 Incident notification & investigation processes.
 Ensures documentation control, periodical review including risk register, legal register etc,…

Human Resources

 Provide H&S information during employee induction activities

 Exercise, when required, disciplinary measures for HSE non-compliance

Line Manager

 Follow H&S rules, policies, LSR, H&S procedures and H&S management system requirements
 Ensure resources for implementation of Life Saving Rules, H&S management system
requirements across span of control

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 Provide project information to nominated persons
 Ensures that H&S performance monitoring of suppliers is undertaken (where applicable)
 Communicate accidents/incidents to Country HSE Manager and provide necessary support
within accident/incident investigation process

Workers – Those who work for and on behalf of Nokia

 Follow LSR, H&S rules, policies, procedures, Global standards requirements and guidances
and H&S management system requirements
 Provide support in development and maintenance of H&S management system
 Communicate accidents/incidents to nominated persons, Country HSE manager or through
Archer GRC reporting available through Nokia intranet main Tools and Resources and provide
necessary support within accident/incident investigation process

Consultation and participation

Ensure a process for consultation and participation of workers at applicable levels and functions
for understanding of needs and expectations and the development, planning, implementation
and evaluation of the health and safety management system. A form of HSE committee shall to
be organized and periodical meetings to be done towards HSE implementation and progresses
for individual facilities/businesses.

Where applicable Nokia India shall seek input from various internal and external
stakeholders; e.g. those working for or on behalf of Nokia, Suppliers, Builders, medical
tie-up professional, Landlords & industry associations etc.
.

Country management teams shall determine the stakeholders required to participate

in consultation activities, also in line with local legislative and other country specific
requirements. Local legislation may also stipulate certain requirements for the number
of health & safety nominated persons and their required knowledge/competencies.

Participation and consultation will be undertaken through:

 Review local legislation to ensure that any participation and consultation process is fully
compliant
 Identify H&S SPOCs / representatives from every local BUs of businesses, team including
support functions and other contractor aligned parties, establish a H&S Committee that
has members from BGs, relevant functions as well as employees’ representatives or
determine other arrangements in agreement with employees

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  Determine the roles and responsibilities of the H&S Committee for the involvement of
employees towards HSE awareness, trainings & incident notification including near-
misses.
 Consult with suppliers and contractors if there are changes that could affect their H&S.

4 Planning
Hazard identification and assessment of risks and opportunities

Nokia has a global level Risk Assessment that shall be used for hazard identification, risk
assessment and determining controls. Determining controls and actions against the hierarchy of
controls (eliminate, substitute, engineering controls, administrative controls, personal protective
equipment). At a global level the main health and safety risks and opportunities have been
assessed through a review of the incident data and input from assessments provided by
relevant stakeholders.

At India market level, the global H&S Risk Register shall be reviewed and amended to reflect the
country specific hazards, risks, assessment, and subsequent controls pertaining to local
facility/businesses involving respective personnel.
The Risk Register should be reviewed regularly to ensure it remains current; taking into
consideration routine, non-routine activities, emergency situations and should be updated if any
new hazards are identified through hazard reporting, workplace inspections, incident
investigations or operational changes etc…
Similarly, Review the potential and barriers to implementing opportunites and follow the
opportunities matrix - Evaluate and communicate opprotunites for implementation.
Further this Risk & Opportunities assessment once finalised after taking relevant inputs from every
stakeholders, it shall need to get communicated to employees through awareness sessions and
trainings.

Nokia has established a process to review and assess the potential for health and safety
opportunities to eliminate hazards and reduce health and safety risk and to enhance health and
safety performance. Health and Safety opportunities have been assessed at the country
businesses/facility level with opportunities to adapt work and reduce health and safety risks.
Opportunities can be identifed through hazard reporting, workplace Inspections, evaluation or
processes, Incident Investigations and organizational change.

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At the country level the global H&S Opportunities Analysis and Register shall be reviewed and
amended to reflect the country health and safety opportunities and their potential. Opportunites
should be reviewed regularly as organizations and technology changes.

Legal requirements and other requirements

 Nokia India identifies and reviews legal legislation (local level) including other relevant
requirements of authorities, such as customers and industry bodies.
 The global health & Safety team, and where appropriate product related teams, regularly
review the global legal situation and disseminate relevant information through the
appropriate communication channels.
 Local legal requirements are monitored and checked by the country management teams on
a regular basis as below..
 Identify, assess and document the applicable regulatory requirements, including the
corrective actions and follow-up if the requirements are not met in a dedicated ‘Local Legal
Register’. This should to be aligned with YGP-Global Legal tool for Country Legal accessing
updates and amendments.
 Check the system in place contains identification of issues to be reported to the relevant
authorities.
 Keep this legislation data base up-to-date
 Find out and understand what laws and requirements mean to your organization or BG in
practice
 Implement the required arrangements to comply with the relevant H&S requirements.
 Ensure that the organisation has obtained the relevant external authorisation to operate
(permits to work) and that these requirements are met.

Health and safety objectives and planning

Nokia India has established global level objectives and KPIs that are measurable, consistent
with the Global H&S Focus Areas and their Objectives-KPIs, Health safety and Labor
Conditions Policy and communicated through the appropriate communication channels and
on the SharePoint.

The Country Management Team have determined and documented country level H&S
objectives and targets that will positively impact the global H&S objecitves and KPI.

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5 Support
Competence, training and awareness

Nokia India shall ensure workers under its control performing tasks that can impact health
& safety are competent on the basis of appropriate education, training or experience,
and retains the associated documents. Employees are trained to identify hazards risks
and understand how to work safely.

Nokia India provides, as a minimum, the following health & safety training opportunities:
 Mandatory training to include Code of Conduct / Ethical Business Training (mandatory for all
Nokia employees) included Health and Safety module.
 Health and Safety awareness training
 Health and Safety standards
 Health and safety training through Nokia EDU and Sharepoint.
 COVID-19 Precautionary measures & protocol for Office access needs to be followed –
Relevant trainings to be mandated as & when needed by individual location businesses.

A Country specific training matrix has been developed and can be located here.

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 Awareness

Nokia India Employees should be made aware of Health, Safety and Labor Conditions policy, health
& safety objectives, Life Saving Rules [LSR], hazards, risks and actions, effectiveness of the health
and safety management system, consequences for non conformance, incident investigation
outcomes that relate to them, and ability to refuse to work in unsafe conditions without retaliation.

Awareness:
 H&S posting in/at the Nokia office sites: H&S Policy, LSR, emergency procedures,
Posters on Ergonomic related tips, control measures etc…
 Ability to identify hazards, control H&S risks, take action and understand implication and
consequences of not conforming to H&S requirements.
 Employees understanding of the policy and non-negotiable standards, refusal to work &
consequence management system.
 Awareness of health and safety objectives set targets with their contribution
expectations.
 Awareness through health and safety campaigns, meetings, town halls, health and safety
teams. toolbox talks, trainings, and workshops.

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 Note: Can be assessed through interviews, drills, tabletop exercises, H&S key performance
indicators, H&S incidents reporting.

Dedicated COVID-19 War room team is committed to provide periodical updates on Pandemic
situation & also further to re-instate the control measures / awareness to all India employees thru
country wide e-mailers distribution.

Internal communication and awareness

Internal communications relating to the health & safety activities of Nokia India, taking into
account diversity aspects and communication needs, are maintained for access by all personnel
on the health & safety intranet and SharePoint.

https://nokia.sharepoint.com/sites/healthandsafetyservices

Internal news channel, Nokia intranet, NokiaEdu, and internal social media, Health, Safety and
Environment Yammer, GDC SharePoints, bulletin boards, internal training, workshops, meetings
and email are used in communicating health and safety activities and raise awareness.

Nominated persons within the relevant organizations, and those individuals responsible
for the various health & safety focus areas shall also communicate issues related to
their health & safety activities, as required to ensure that all workers are aware of, and
have access to, the relevant information associated with their scope of work.

External communication

External communications relating to the health & safety activities of Nokia are
maintained for public access on the company health & safety internet pages including
the Sustainability Report (People and Planet), Nokia Health Safety and Labor Conditions
Policy.

Nokia External Health and Safety Internet Page:

https://www.nokia.com/resources/health-safety/

External reporting to regulatory entities, licensing, external inquiries may be required.

If required, further external health & safety communications shall be managed by the
Nokia Communications team; globally individuals are nominated to represent Nokia India
in external communications.
 Communication must include employees, visitors, vendors, suppliers, contractors,
organizations and others interested parties.

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  Communication to external parties such as reporting to regulatory authorities, and
customers.
 Check and adapt the content,frequency, and distribution of communication to country
specific requirements
 Concerning the identification, elimination and reduction of hazards and risks,
 About OHS objectives and other opportunity activities for continual improvement
 Relating to incident reporting, investigation, and evaluation.
 H&S initiatives and awareness campaigns
 H&S Signage for hazards

Documented information, Control of documents

The Nokia India Health and Safety Management System consists of:

 Nokia Management Systems Global Manual providing a broad overview of the main principles
and processes applied within Nokia

 Nokia Health, Safety and Labor Conditions Policy publicly states the health &
safety goals and objectives of Nokia (as determined by the Executive Board)
 Nokia level health & safety standards and guidelines application throughout Nokia
globally
 Nokia Health and Safety Standard Operating Procedure outlining the Health and Safety
management activities of Nokia
 Relevant Health and Safety Guidelines and other documents that outline, in conjunction with
the company level documents and inputs from planning activities, the health and safety
activities and responsibilities for individual relevant organizations.

 Country level documentation (i.e. India H&S Manual with all associated
documentation) which details the health and safety related activities to meet all
relevant country legal requirements as well as other country specific
requirements to which Nokia subscribes
 Records which allow monitoring of Health and Safety performance

The Health and Safety Management System documents shall be reviewed at regular
intervals to ensure it remains valid and relevant.

Health and Safety documentation shall be managed in compliance with the

requirements of the Nokia Document and Records Management Policy, and Nokia
Document Management SOP.

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All relevant health & safety documents and records shall be created, retained and
disposed of in line with the relevant Nokia India requirements, whilst taking into
consideration any further local legislative or customer requirements.

 A nominated person should be responsible for the update and maintenance of the H&S
Management System
 Ensure that standards are localized where required.
 Ensure local legislation compliance
 Nokia global H&S requirements are the minimum standard
 The minimum H&S Documents that need to be in produced locally include:
 Country H&S Manual (this document)
 Risk Register
 Opportunities Register
 Legal Register
 Training and Competency Matrix
 H&S Auditor Qualification Records

Note: Suggest communications log

 Document retention and disposal as per Nokia Document and Records Management
 Documents identified Proprietary, Internal Use, Public
 Document ID
 Distribution, access, retrieval, control of changes and document approvals

6 Operation
Operational planning, control and change management

As the Health & Safety Management System is implemented with matrix responsibility the
management of health & safety tasks are integrated into India business level activities (routine,
non-routine) to ensure the provisions of the Health & Safety Management System are
appropriate for the scale of the business hazards and risks for planned and planned temporary
changes.

Established processes on how to control visitors in Nokia India premises as well as topics related
to control of work areas, equipment and measurement equipment (proper maintenance and
calibration if applicable). Due to COVID-19 pandemic, certain restrictions including prohibition of
vendor & other general visitors accessing to Nokia office facilities are ensured. Local CCMT

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members are aligned and having adequate control mechanism in order to maintain strict
adherence to set COVID-19 controls including ‘Restricted lean access to office-Only for busines
critical personnel, Self declaration, Body tempearture checking by Hand-held or Visual-NAAS
thermometers concept, mask management, social distancing and hand-hygiene protocols etc..
This is also monitored and periodically ensured by regular patrolling and reminders through Public
addressing (PA) systems.

Eliminating hazard and reducing H&S risks.

The hazards that are identified in H&S Risk Register, shall be addressed. The organization shall
pursue identification and control of hazards and risk following the hyrarchy of controls (eliminate,
substitute, reduce to acceptable level using engineering and administrative controls, use of
adequate PPE).

Global H&S documentation, including Contractor Management/Health & Safety in Customer

projects is located here.

Procurement

In Nokia India Procurement the same sound health & safety and ethical principles that are
followed within Nokia India operations are reflected in business relationships to ensure
suppliers, contractors and other business partners follow the same standards and place
equally high priority on health, safety and labour conditions in their operations.

The Nokia India supplier requirements include requirements relating to suppliers' health &
safety management and labor conditions. The implementation of these requirements is
done through contractual agreements, contractor management, monitoring practices such
as on-site and self-assessments, training and awareness building.

Most of the high-risk work conducted as part of Nokia India business are delivered by our
suppliers. The control of our projects and suppliers is an integral part of managing the health
and safety in Nokia India.

 High-risk activities are identified, the hazards are highlighted and evaluated,
appropriate controls are defined and implemented
 Adequate resources budgeted and assigned to ensure project safe delivery
 Suppliers are evaluated and qualified prior appointment-SMA process at Archer for
facility management & other high risk based suppliers.
 Nokia H&S requirements, rules and expectations are communicated and apply
equally to any supplier
• H&S performance monitoring alongside with operational performance
• H&S poor performances, LSR Violations are linked to consequences
 Contractor Management

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  For projects
• SMA- Ensure compliance to Global Supplier Management Assessments SOP and
Maintain status of High Risk Suppliers
• HRPIA
• H&S safety plan for procedures and controls required to address hazards and risks

Emergency preparedness and response

Emergency preparedness and response management and personnel security issues

are managed at the country level.
Nokia India HSSE team has developed a country specific Emergency Response Plan
(ERP) with provision of first aid to prevent or mitigate the health & safety
consequences. The ERP is compliant with country legislation and identifies potential
emergency situations and response across India including COVID-19 Pandemic.

Emergency plans are documented, communicated, tested yearly once,

reviewed and revised within determined intervals and reviewed after an emergency
situation has occurred.

 Identify the need, appoint and train the first aid persons and provide first aid supplies.
 Identify the need, appoint and train the evacuation ERT members for the location and
provide relevant equipment (i.e. fluorescent vests)
 Create roster with listed names and contact details of first aiders and evacuation ERT
members.
 Keep records from trainings given to first aiders and evacuation ERT members.
 Provide evacuation training for all staff and keep records from training completed.
 Test the emergency plans/drill periodically-Once in a Year. Involve interested parties if
necessary.
 Document debrief of a test of plan or emergency situation
 Review and revise emergency preparedness plan after emergency situation
 COVID-19 War room & 24*7 SIRC support services numbers identified and communicated
across all India employees.

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7 Performance evaluation
To verify the effectiveness of the company Health & Safety Management System objective
inspection is required, this section describes the required activities.

Monitoring, measurement, analysis and perfromance evaluation

Health & safety key performance indicators are set to both reflect strategic direction
and drive continual improvement across the organization.

The health & safety key performance Indicators are managed in conjunction with the
Health & Safety Management System and provide numeric results and targets to
monitor and drive improved performance at both company and relevant organization
levels

Health & safety key performance indicators are authorized by the Head of Health,
Safety and Environment and reviewed and communicated by the Health, Safety and
Environment Management Team to the Relevant Organizations.

Local key performance indicators are aligned with the Global H&S Objectives which
are aligned with global H&S KPI in place.

There will be regular evaluation of compliance to the country specific health & safety
legislation and other relevant requirements from authorities, customers and industry
bodies, to which Nokia subscribes.

Regular evaluation of compliance to global internal requirements and to global customer

specific requirements will be undertaken by the Health & safety management team..

Regular evaluation will be undertaken periodically based on location/business’es decision.

Internal audit programme

The implementation and effectiveness of the Heath & Safety Management System and legal
compliance requires regular surveillance, and the nominated person shall instruct suitably
qualified workers to act as follows:

• Document an internal audit schedule with a sufficient number of internal audits per year to
give confidence in the performance of the Health and Safety Management System, this with
regard to the Nokia Internal Audit Process.

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• Ensure internal audits are conducted according to the plan and that the results are
documented to establish the fitness for purpose of the Health & Safety Management System
and this Mode of Operation with regard to the requirements of ISO 45001.
• Document identified non conformities and opportunities for improvement and that
appropriate actions are initiated to close identified findings.

Management review

Nokia seeks to continually improve its business processes, this includes a commitment to review
and improve the company health and safety management performance.

The overall management review of the Nokia health & safety management system shall take place
globally. H&S performance review will be undertaken every year.
The country level review review and report shall be conducted with regard to the following:

• Changes in external and internal Issues, including developments in legal and other
requirements and needs and expectations from those who work for and on behalf of Nokia and
interested parties
• Changes in health & safety risks and opportunities
• The health & safety performance of the organization to include incidents, non-conformities,
corrective actions, monitoring and measurement and continual improvement
• Monitoring and measurement results
• Results of internal audits and evaluations of compliance with legal requirements and with other
requirements to which the organization subscribes
• Status of corrective and preventative actions • Follow-up of previous management
reviews,
• Opportunities for improvement.
• Recommendations for improvement
The outputs from the management reviews shall document any decisions and actions related to
possible changes to health and safety policy, objectives, targets and other elements of the health
and safetyl management system, consistent with the commitment to continual improvement.
This review shall involve nominated persons of relevant organizations and other
members of the health & safety management team. The results of the review shall be
communicated to the heads of relevant organizations.

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8 Improvement
Relevant organizations shall look for opportunities to improve their implementation of the health
& safety management system and management of the health and safety hazards, risk and
opportunities.

Incident, nonconformity and corrective action

It is the responsibility of all employees to report suspected or identified health &

safety incidents to Health, Safety and Environment contacts at their location
(Identified Local HSE SPOCs) or online through the Archer tool.

When an incident occurs the H&S responsible person shall:

 Report and Document, put the H&S Incident into HSSE Archer Incident Reporting Tool.
 Ensure that incidents are fully investigated.
 Take immediate steps to control the incident to mitigate against further harm and
Initiate an investigation to establish the cause.
 Notify local authorities / other stakeholders if appropriate
 Evaluate with nominated person, relavent workers and interested parties, the need for
corrective action to eliminate root cause in order to prevent reoccurance. Consider the need
for specific training.
 Require preventative measures be implemented to prevent reoccurrence at the site of the
incident or at other similar locations controlled by Nokia.
 Communicate to impacted stakeholders the details of the incident and actions taken
 Review effectiveness of corrective action and close out of the action plans
 Review existing health & safety risk assessments as appropriate.
Non-conformity
Once any nonconformity is identified, it should be investigated to determine the cause(s), so that
suitable corrective actions can be focused on the appropriate part of the system. The response
and timing of such actions should be appropriate to the nature and scale of the nonconformity
and the health & safety risk. Corrective/preventive actions will assign responsibility, and targeted
completion dates.

All identified non-conformities shall be managed in accordance with the Nokia nonconformity and
corrective action processes and tracked and manageed within the JIRA tool. Analysis of
nonconformities raised across all relevant organizations will be carried out on a regular basis to
identify any systemic issues, patterns and opportunities for improvement.

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 Continual improvement

Relevant Organizations shall look for opportunities to improve the suitabiity and effectiveness of
the health and safety management system.
Health and safety key performance indicators are set to both reflect strategic direction and drive
continual improvement across the organzations.
Improvement takes into account the results analysis, evaluation of health and safety performance,
evaluation of compliance, audit results, management review, when actions to improve are taken
with communication of relevant results to workers.IMPROVEMENT

9 References’ / links
Nokia Systems Manual
https://nokia.sharepoint.com/:w:/r/sites/NokiaQMS/NokiaView/_l
ayouts/15/Doc.aspx?sourcedoc=%7B2f4dd5cb-e769-412b-
8d00-5f1c5be63739%7D&action=default&cid=702183d4-10ac-
4746-9a77-3b5fe2c6aa79

Health & Safety Intranet https://nokia.sharepoint.com/sites/healthandsafetyservices

Nokia Health, Safety and Labor https://nokia.sharepoint.com/sites/Nokia_Central/SitePages/Poli

Conditions Policy cies-and-SOPs.aspx

Nokia Health & Safety Standard https://nokia.sharepoint.com/:w:/r/sites/HS-

Operating Procedure
Public/_layouts/15/Doc.aspx?sourcedoc=%7B01DA0BDC-048E-
4CA3-8A74-
9120326BAF58%7D&file=Health%20and%20Safety%20Manage
ment%20System%20SOP%202020.docx&action=default&mobil
eredirect=true

Global Health & Safety Risk https://nokia.sharepoint.com/:x:/r/sites/HS-

Register Public/_layouts/15/Doc.aspx?sourcedoc=%7BED47513F-A1D2-
4F0D-AB97-
1721727A8A48%7D&file=H%26S%20Risk%20Register%20Global
%20.xls&action=default&mobileredirect=true

Global Health and Safety https://nokia.sharepoint.com/:f:/r/sites/HS-

Opportunities analysis Public/HSE%20Documents/Management%20system%20docum
ents/Health%20%26%20Safety%20Opportunites%20Analysis?
csf=1&e=rbUFQl

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 Health & Safety Training https://nokia.sharepoint.com/sites/healthandsafetyservices/Site
Pages/H%26S-training.aspx

Nokia Tools and Resources – Nokia https://nokia.sharepoint.com/sites/nokiacentral/default.aspx

intranet page:

• Incident reporting, Archer https://hssearcher.int.net.nokia.com/RSAarcher/apps/ArcherApp

/Home.aspx (connect with VPN)
• NokiaEDU
https://nokialearn.csod.com/client/nokialearn/default.aspx
https://learningstore.nokia.com/employee
• JIRA audits
https://jiradc2.ext.net.nokia.com/login.jsp?os_destination=%2Fd
efault.jsp

• H&S Reports https://nokia.sharepoint.com/sites/HSEReports/SitePages/Hom

e.aspx

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