NOKIA INVESTMENT MANAGEMENT CORPORATION
Nokia Investment Management Corporation (“NIMCO”), a direct wholly-owned subsidiary of Nokia of
America Corporation (referred to hereinafter as “Nokia”) and an indirect wholly-owned subsidiary of
Nokia Corporation, a Finnish corporation headquartered in Helsinki (Espoo), Finland, was created in April
1999 to provide investment advisory and fiduciary services for affiliated US defined benefit, defined
contribution, and other post-employment benefit plans and trusts maintained by Nokia and certain of its
subsidiaries (the “Plans”). NIMCO was formed as a Delaware corporation and registered with the US
Securities and Exchange Commission (“SEC”) in 1999. The Plans are NIMCO’s only investment advisory
clients. Some of the Plans are subject to the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”), and are qualified under section 401 of the Internal Revenue Code of 1986, as
amended. NIMCO is qualified as an in-house asset manager (“INHAM”) under the Department of Labor’s
Prohibited Transaction Class Exemption 96-23, a class exemption that provides relief for transactions
between the INHAM and certain service providers. As a requirement of the INHAM exemption, NIMCO is
required to be registered with the SEC as an investment adviser under the Investment Advisers Act of
1940.
NIMCO may provide non-discretionary investment consulting services from time to time on an as-
needed basis with respect to the investment activities of Nokia’s non-U.S. pension plans, and with
respect to certain non-pension investments held by Nokia. NIMCO also provides administrative and
fiduciary services to a single-employer Taft Hartley plan sponsored by a Board of Trustees that consists
of two individuals designated by Nokia and two individuals designated by certain labor unions.
The advisory services NIMCO provides to the Plans are those customary for a named fiduciary with
overall responsibility for managing an investment program,…
Nokia Investment Management Corporation ( “ NIMCO ” ), a direct wholly-owned subordinate of Nokia of America Corporation ( referred to hereinafter as “ Nokia ” ) and an indirect wholly-owned auxiliary of Nokia Corporation, a finnish pot headquartered in Helsinki ( Espoo ), Finland, was created in April 1999 to provide investment advisory and fiduciary services for affiliated US defined profit, defined contribution, and other post-employment benefit plans and trusts maintained by Nokia and certain of its subsidiaries ( the “ Plans ” ). NIMCO was formed as a Delaware pot and registered with the US Securities and Exchange Commission ( “ SEC ” ) in 1999. The Plans are NIMCO ’ s alone investment advisory clients. Some of the Plans are submit to the Employee Retirement Income Security Act of 1974, as amended ( “ ERISA ” ), and are qualified under section 401 of the Internal Revenue Code of 1986, as amended. NIMCO is qualified as an in-house asset coach ( “ INHAM ” ) under the Department of Labor ’ s Prohibited Transaction Class Exemption 96-23, a course exemption that provides easing for transactions between the INHAM and certain avail providers. As a necessity of the INHAM exemption, NIMCO is required to be registered with the SEC as an investment adviser under the Investment Advisers Act of 1940.NIMCO may provide non-discretionary investment consult services from time to time on an as- needed basis with deference to the investment activities of Nokia ’ s non-U.S. pension plans, and with respect to sealed non-pension investments held by Nokia. NIMCO besides provides administrative and fiduciary services to a single-employer Taft Hartley plan sponsored by a Board of Trustees that consists of two individuals designated by Nokia and two individuals designated by certain department of labor unions.The advisory services NIMCO provides to the Plans are those accustomed for a named fiduciary with overall province for managing an investment course of study, … please read to get more information
Reimbursement for costs incurred
NIMCO has entered into written investment management and fiduciary services agreements for the
Plans under which NIMCO deducts Plan accounts directly for reimbursement of actual costs incurred by
NIMCO in connection with the investment advisory and fiduciary services it provides.
Such categories of expenses include staff salaries and benefits, legal, consulting, travel, training, and
other costs. The investment management and fiduciary se…
NIMCO has entered into written investment management and fiduciary services agreements for the Plans under which NIMCO deducts Plan accounts immediately for reimbursement of actual costs incurred by NIMCO in connection with the investing advisory and fiduciary services it provides.Such categories of expenses include staff salaries and benefits, legal, consulting, locomotion, educate, and other costs. The investment management and fiduciary selenium … please register to get more information
NIMCO receives as complete compensation for advisory and fiduciary services rendered reimbursements
of its costs, including employee salaries, bonuses, benefits costs, and operating expenses.
NIMCO receives as arrant recompense for advisory and fiduciary services rendered reimbursements of its costs, including employee salaries, bonuses, benefits costs, and operate expenses. please read to get more information
NIMCO provides investment advisory and fiduciary services for defined benefit, defined contribution, and
other post-employment benefit plans maintained by Nokia and certain of its subsidiaries. The Plans are
NIMCO’s only investment advisory clients.
In addition, NIMCO may provide non-discretionary, investment consulting services from time to time on
an as-needed basis with respect to the investment activities of Nokia’s non-US pension plans, and with
respect to certain non-pension in…
NIMCO provides investing advisory and fiduciary services for define benefit, defined contribution, and other post-employment benefit plans maintained by Nokia and certain of its subsidiaries. The Plans are NIMCO ’ s merely investing advisory clients. In accession, NIMCO may provide non-discretionary, investment confer services from meter to time on an as-needed basis with respect to the investment activities of Nokia ’ s non-US pension plans, and with respect to certain non-pension in … please register to get more information
Defined Benefit and Other Post Employment Benefit Plans
In accordance with asset allocation policies set by the Nokia Pension and Benefits Investment
Committee, NIMCO allocates the Plans’ assets among various types of equity, debt, and partnership
investments but does not provide day-to-day portfolio management services with respect to any
investments. Instead, NIMCO engages and monitors third-party investment managers that provide day-
to-day portfolio management services for v…
In accordance with asset allotment policies set by the Nokia Pension and Benefits Investment Committee, NIMCO allocates the Plans ’ assets among versatile types of equity, debt, and partnership investments but does not provide daily portfolio management services with esteem to any investments. alternatively, NIMCO engages and monitors third-party investment managers that provide day- to-day portfolio management services for five … please register to get more information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of NIMCO or the integrity of NIMCO’s
management. NIMCO has no information applicable to this Item.
Regulatory proceedings and actions relating to affiliates of NIMCO are disclosed, as required, in Part 1 of
Form ADV.
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of NIMCO or the integrity of NIMCO ’ randomness management. NIMCO has no information applicable to this Item. Regulatory proceedings and actions relating to affiliates of NIMCO are disclosed, as required, in Part 1 of Form ADV. please record to get more information
NIMCO has no relationship or arrangement with a related person that is material to its advisory business
or creates a material conflict of interest with clients.
NIMCO has no relationship or placement with a refer person that is material to its advisory clientele or creates a material conflict of sake with clients. please register to get more information
NIMCO maintains a Code of Ethics which applies to all officers of NIMCO, all other persons occupying a
similar status or performing similar functions as the officers of NIMCO, all employees of NIMCO, all other
Nokia group employees or non Nokia group individuals (e.g., temporary on site staff, consultants, or
independent contractors) who are subject to NIMCO’s supervision and control2, all members of NIMCO’s
board of directors, and all members of the PBIC and the 401(k) Committee.
T…
NIMCO maintains a Code of Ethics which applies to all officers of NIMCO, all other persons occupying a similar status or performing similar functions as the officers of NIMCO, all employees of NIMCO, all early Nokia group employees or not Nokia group individuals ( for example, temp on locate staff, consultants, or independent contractors ) who are subject to NIMCO ‘s supervision and control2, all members of NIMCO ‘s board of directors, and all members of the PBIC and the 401 ( thousand ) Committee.T … please register to get more information
NIMCO retains fully discretionary investment managers to manage assets in the Plans. These
unaffiliated, discretionary investment managers exercise discretion in the choice of brokers for
transaction execution within the accounts. NIMCO monitors third-party investment managers in these
aspects of the performance of their duties.
The Plans’ investments in private fund investments are not conducted through broker-dealers.
The Nokia Savings/401(k) Plan offers its participants the a…
NIMCO retains fully discretionary investment managers to manage assets in the Plans. These unaffiliated, discretionary investment managers exercise delicacy in the choice of brokers for transaction execution within the accounts. NIMCO monitors third-party investment managers in these aspects of the performance of their duties.The Plans ’ investments in private fund investments are not conducted through broker-dealers.The Nokia Savings/401 ( potassium ) plan offers its participants the a … please register to get more information
The advisory services NIMCO provides to the Plans include, as applicable, (a) establishing and amending
objectives, strategies, guidelines and benchmarks for investments by the Plans in asset classes ranging
from traditional equity and fixed income investments to alternative asset classes, including real estate,
private equity, and absolute return; (b) determining, monitoring, and adjusting the allocation and
diversification of assets within asset classes; (c) engaging and removing unaff…
The advisory services NIMCO provides to the Plans include, as applicable, ( a ) establish and amending objectives, strategies, guidelines and benchmarks for investments by the Plans in asset classes ranging from traditional equity and fixate income investments to alternative asset classes, including real estate of the realm, private equity, and absolute render ; ( b ) decide, monitor, and adjusting the allocation and diversification of assets within asset classes ; ( coke ) engage and removing unaff … please register to get more information
Other than the compensation described in Item 5, NIMCO does not receive an economic benefit from
anyone other than the Plans for advisory services.
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early than the compensation described in Item 5, NIMCO does not receive an economic benefit from anyone early than the Plans for advisory services .
NIMCO does not provide custodial services to the Plans. NIMCO is deemed to have indirect custody of
assets of the Plans because it has the ability to debit fees (i.e., reimbursement of its costs) directly from
Plan accounts. NIMCO, however, does not have physical custody of client assets at any time.
Assets of the Plans, including separate account assets, ownership interests in commingled funds and
limited partnerships, and direct-owned real estate, are accounted for by a trustee…
NIMCO does not provide custodial services to the Plans. NIMCO is deemed to have indirect hands of assets of the Plans because it has the ability to debit fees ( i.e., reimbursement of its costs ) directly from Plan accounts. NIMCO, however, does not have physical detention of client assets at any time.Assets of the Plans, including separate account assets, ownership interests in blend funds and circumscribed partnerships, and direct-owned actual estate of the realm, are accounted for by a regent … please register to get more information
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NIMCO has discretionary authority to invest assets of the Plans in a manner consistent with the stated
investment objectives for the Plans.
The PBIC approves the asset classes for investment by the Plans and the proportions allocated to each in
the defined benefit and other post-employment benefit plans. (Assets in defined contribution plans are
allocated by the plans’ participants.) The PBIC or the 401(k) Committee may impose restrictions on
investing in certain securities or ty…
NIMCO has discretionary agency to invest assets of the Plans in a manner reproducible with the stated investment objectives for the Plans.The PBIC approves the asset classes for investment by the Plans and the proportions allocated to each in the define benefit and other post-employment benefit plans. ( Assets in defined contribution plans are allocated by the plans ’ participants. ) The PBIC or the 401 ( k ) Committee may impose restrictions on investing in certain securities or ty … please register to get more information
Proxies are voted by the discretionary investment managers responsible for day-to-day management of
the Plans’ investment accounts. NIMCO evaluates each investment manager’s proxy voting policies as
part of the hiring process and as part of NIMCO’s ongoing monitoring of the investment manager. NIMCO
also reviews periodic, incident-based reports regarding the investment managers’ proxy voting activities.
NIMCO requires that each investment manager: (1) vote solely in the best economi…
Proxies are voted by the discretionary investment managers responsible for daily management of the Plans ’ investment accounts. NIMCO evaluates each investment coach ’ s proxy voting policies as separate of the hire serve and as part of NIMCO ’ s ongoing monitor of the investment director. NIMCO besides reviews periodic, incident-based reports regarding the investment managers ’ proxy vote activities.NIMCO requires that each investment coach : ( 1 ) vote entirely in the best economi … please register to get more information
NIMCO has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients and has not been the subject of a bankruptcy proceeding.
NIMCO has no fiscal commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the national of a bankruptcy proceed. please register to get more information
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