The phone is not operator locked.
From the Software Update FAQ
"Other people can update their software but I cannot. What's wrong?
Update availability is based on many things, including existing Nokia device firmware version, country, and operator. It may be due to one of these variables that your Nokia device isn't eligible for updates.
Please note that your mobile service provider, operator, or carrier may not have approved the latest Nokia device firmware available.
Nokia produces many different variants of each product (for different countries and languages) and not all variants have the latest Nokia device firmware. It is our priority to update all variants as quickly as possible, and we apologize for any delay. New software may become available at a later date, however, so please check again soon."
Nokia Care told me they could not do the firmware update and I had to do it myself. Vodafone said they would not do it. Nokia software updater says, can update the phone due Vodafone not approving the update. So there. Maybe it is a Vodafone thing.