Nokia 2012 Annual Report Download - page 70

Nokia Siemens Networks has made the decision in November 2011 to withdraw from the Iranian
market in a controlled manner and is in the process of winding down its business activities in Iran.
Nokia Siemens Networks expects to cease all revenue-generating activities relating to Iran by June 30,
2013. Other activities relating to the withdrawal—such as dissolution of the local branch, divestment or
discontinuation of certain shareholdings, closing of local bank accounts and resolution of contractual
and legal obligations in Iran—will take longer.
Similarly, we have decided to end the local presence in Iran of our Devices & Services and HERE
businesses. The local Iranian office of these businesses was closed in August 2012 and as of
December 31, 2012 there were no longer any employees based in Iran for these businesses. Other
activities relating to the termination of our local presence in Iran for these businesses will take longer.
Nokia will continue to sell mobile devices, accessories and certain free of charge items such as digital
content and services into Iran through regional distributors based outside of Iran.
In connection with the business activities described above relating to Iran, we have routine contacts
with governmental agencies in Iran as required, for example, to maintain a legal presence in Iran, pay
taxes, employ Iranian nationals and maintain shareholdings in certain Iranian companies as required
under Iranian law and as is customary under Iranian business practices. We expect to cease these
contacts and shareholdings as soon as possible in connection with our withdrawal from Iran as
described above.
We cannot exclude the possibility that third parties acting independently from us have exported our
products to countries from other countries in which we sell them. We also distribute services,
applications and content through the Internet. In terms of these offerings, we have industry standard
systems in place recognizing users’ IP addresses and, if applicable, block the access to our service
offerings if they are not intended for a certain market or country. We cannot exclude the possibility that
our services, applications and content when distributed through the Internet, may be accessed in
markets or countries which they are not intended for if the industry standard protective mechanisms,
such as IP address blocks, are circumvented.
Disclosure pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of
2012 (ITRA)
To our knowledge, none of our sales of mobile devices and services through Devices & Services and
HERE in Iran in 2012 are required to be disclosed pursuant to ITRA Section 219. To our knowledge,
none of our sales of network equipment and services through Nokia Siemens Networks in Iran in 2012
are required to be disclosed pursuant to ITRA Section 219, with the possible exception of the following:
During the year ended December 31, 2012, Nokia Siemens Networks provided 2G Radio, core and
transmission equipment, including related implementation and care services, in Iran under agreements
with Mobile Communications Company of Iran (MCCI) and MTN Irancell. Additionally, during the year
ended December 31, 2012, Nokia Siemens Networks provided optical networks equipment to Sadid
Consultant Connection Developer Company (SCCDC), a privately held reseller for Nokia Siemens
Networks, where the end user was Iranian Gas Transmission Company (IGTC). Furthermore, Nokia
Siemens Networks provided during the year ended December 31, 2012 under an existing care and
maintenance contract a return and repair service to SCCDC, where the beneficiary of the service was
IGTC. During the year ended December 31, 2011 and the year ended December 31, 2012 Nokia
Siemens Networks provided optical networks equipment to Hamkaran Samanehaye Ertebati Pars
(Hamkaran), a privately held reseller for Nokia Siemens Networks, where the end user was
Petrochemical Commercial Co. (PCC) and for which Nokia Siemens Networks received a payment
during the year ended December 31, 2012. Through a branch of its Finnish subsidiary, Nokia Siemens
Networks employs personnel in Iran to perform its contractual and regulatory obligations in Iran. In
connection with these agreements, Nokia Siemens
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