UPM Annual Report 2024

WE ARE UPM

GOVERNANCE

ACCOUNTS AND PERFORMANCE

Report of the Board of Directors

Sustainability Statement

Financial Statements

Auditor's Report

Sustainability Assurance Reports

IMPACTS, RISKS AND OPPORTUNITIES

POLICIES

Description of UPM's own workforce UPM's own workforce consists of the following groups: • Own employees: people directly employed by UPM • Non-employees, further divided into two sub-groups • Agency hires: persons employed by employment agencies or labour providers working at UPM's sites under the direct supervision of UPM. Agency employees are not directly employed by UPM. • Independent contractors: self-employed individuals who provide services or labour to UPM and are bound by a direct contractual arrangement other than a contract of employment. The number of such independent contractors is currently estimated to be so small that reporting on them is not material for UPM. All people in UPM's own workforce who could be materially affected by UPM are included in the scope of disclosure. None of the identified material risks and opportunities relate to a specific group within own workforce but concern all employees equally. UPM ensures equal and adequate pay through its third-party verified annual review process and correction of identified gaps. UPM is continuously developing its employee experience and leadership culture, evaluating its recruitment, compensation policies and career development opportunities. Changes in the business environment and market demand may lead to restructuring measures to ensure UPM’s cost-competitiveness. Active measures are taken to mitigate the effects on employees, e.g. by promoting employment and retraining. The success of UPM's businesses depends largely on the ability to build and maintain the necessary new capabilities required for future growth. UPM continuously develops its employee experience and leadership culture, evaluates its recruitment, compensation policies and career development opportunities, and takes measures to attract and retain diversely skilled personnel and individuals with rare and critical specialist knowledge for current and future growth areas. In addition to UPM's targets for female representation in management and equal pay, UPM’s commitment to inclusion and diversity is underlined by active training, dialogue and cooperation. The latest example is UPM's global and employee-led BeU network. UPM's Group-wide safety project aims to give a new boost to UPM's safety culture and address the changes needed throughout the organisation. The aim is to empower employees and teams and give them a mandate to improve safety. Although several measures are taken to prevent injuries and accidents to employees and contractors at UPM's production sites, a risk remains. The importance of health and safety is also discussed and followed up with suppliers, but negative impacts can occur. These negative impacts are related to individual incidents. Failure to maintain a high level of safety management could result in injury, illness or liability to UPM's employees, contractors or third parties. These risks are managed through established management procedures, health and safety precautions, and loss prevention programmes.

The UPM Code of Conduct, UPM HR Rules and UPM Safety Rules apply to all UPM's own workforce. UPM and human rights Commitments UPM is committed to respecting human rights in line with the United Nations Guiding Principles on Business and Human Rights. UPM respects the UN Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. We also promote the human-rights-related principles of the UN Global Compact. The UPM Code of Conduct, the UPM Sustainability Policy Statement, and the UPM Supplier and Third-Party Code are aligned with these internationally recognised standards. Compliance system UPM's compliance system is the risk management system used to manage UPM's human rights and environmental risks. UPM's compliance system is embedded in its governance model and is designed to strengthen corporate performance and a culture of integrity at all levels. Risk analysis To assess human rights risks in its own operations, UPM has adopted a procedure that is regularly applied at the business area or unit level. The procedure aims to ensure an analysis of actual and potential human rights risks and impacts specific to the business area and/or operating context, and recognises that risks may change over time. In practice, this means that UPM's business areas regularly identify human rights risks and impacts, assess the severity and likelihood of these risks and impacts, and prioritise the most severe issues for further focus and action. » Refer to G1-2 Responsible Sourcing The human rights risk assessment and management process is integrated into UPM's existing guidelines and management systems. In addition to the business-area-specific risk assessment procedure described above, human rights considerations and due diligence requirements are integrated into UPM's global processes, e.g. those related to investments and the corporate salient human rights assessment. Training and engagement UPM's Code of Conduct training is mandatory for all UPM employees, and participation is measured and reported annually. The training covers the protection of human rights and the environment and the identification of human rights and environmental risks. In addition, there is a separate e-learning course on the requirements of the UPM Supplier and Third-Party Code for UPM's employees who deal with suppliers. The link between human rights violations and corruption is also covered in UPM's anti-corruption training, which is mandatory for all salaried employees. UPM's Sourcing function organises additional training for its employees on responsibility principles and supplier requirements. Remediation UPM monitors and works to remedy adverse impacts on human rights of which it is aware, and which its activities have caused or contributed to. In the event of a violation of a human rights or environmental obligation, UPM determines the necessary and appropriate measures on a case-by

S1-1

ESRS 2 SBM-3

UPM's decision-making, management and operations are guided by UPM's values and the UPM Code of Conduct. Compliance with the laws and responsible practices are the basis of all UPM's operations and create long-term value for both UPM and its stakeholders. The UPM Code of Conduct underlines UPM's commitment to business integrity and responsible business operations and reflects the Company's guiding principles. UPM works to ensure that human rights are respected by all UPM employees throughout the operations and business relationships and expects its suppliers and business partners to do the same. UPM wants to ensure that all raw materials and services are purchased from responsible sources. » Refer to G1-1 Policies UPM's Human Resources and Safety Rules UPM's human resources management is based on the Company's values and is an important part of UPM's corporate social responsibility. The UPM HR (Human Resources) Rules complement the UPM Code of Conduct by defining in more detail the principles of working conditions, labour practices and decent work as described by the International Labour Organization (ILO), what UPM is committed to, and what is expected of its employees. The UPM HR Rules are owned by UPM's Human Resources function and approved by the Group Executive Team. The UPM HR Rules apply to all UPM's employees and executives. The UPM HR Rules do not apply directly to suppliers and other third parties and their representatives, as they are bound by similar principles by the UPM Supplier and Third-Party Code. UPM complies with international, national and local safety laws, regulations and rules. UPM does this by implementing and complying with UPM's safety standards and local procedures. UPM promotes fair working conditions and respects the right of employees to form and join associations, bargain collectively, and assemble peacefully. UPM does not tolerate modern slavery, child labour, forced labour or human trafficking in any form in its operations or in any part of its value chain. UPM Safety Rules set and communicate clear safety expectations and targets at all levels of UPM's organisations.The UPM Safety Rules are owned by UPM's Human Resources function and approved by the Group Executive Team. UPM's occupational health and safety management systems ensure that the targets are achieved. This is reinforced by UPM's safety standards, in particular the safety standard on roles and responsibilities, which also defines the business line organisation's responsibility for ensuring the safety standards are implemented. All UPM employees apply UPM's Safety Rules in a disciplined manner. In addition, UPM's business partners and their employees at UPM's sites are required to adopt safe working practices and to comply with UPM's Safety Rules and standards. If a safety violation is detected, UPM intervenes and takes the necessary measures in a timely manner. UPM has an internal occupational health and safety (OHS) audit programme for each business area to monitor and check compliance with UPM's safety standards. This highlights good practices, as well as any shortcomings or actions needed to meet UPM's OHS expectations.

UPM is committed to being a responsible and attractive employer now and in the future. UPM wants to strengthen its employees’ sense of belonging and the feeling that they are doing meaningful work. This promotes productivity, engagement and wellbeing. UPM's values are the foundation of who we are. Building a culture of Aiming Higher is essential to UPM's success in today’s rapidly changing world. UPM's employees are accountable, performance-driven, human centric, and eager to learn and grow. UPM's aim is to further increase employee motivation and make growth opportunities more visible and accessible. In an increasingly complex business environment, enhancing employees' skills and wellbeing is important for both business success and sustained employability. UPM's long-term goal is to ensure high performance and continuous professional development.

Overview of material impacts, risks and opportunities

MATERIAL TOPICS IMPACTS, RISKS AND OPPORTUNITIES DESCRIPTION Decent work and fair rewarding Positive impact: Ensuring equal and adequate pay, training and development

Potential negative impact*: Job losses due to closing of operations or restructuring

Risk: Lack of skilled workforce

Opportunity: Being the employer of choice

Positive impact: Enhancing diversity and inclusion with a positive impact on the workforce

Diversity and inclusion

Positive impact: Increased focus on health and safety measures for people working at all UPM sites Negative impact*: Health and safety incidents, including serious accidents and fatalities for UPM workforce

Health and safety

Risk: Potential Injury to UPM workforce

* UPM's identified material negative impacts are not seen as widespread or systemic but are related to potential individual incidents.

No risks of forced or compulsory labour or child labour identified for UPM's own operations. As part of UPM's ongoing human rights due diligence, the Company has identified groups who are at higher risk of experiencing potential adverse human rights impacts. Based on UPM's assessments and

dialogue with various stakeholders, UPM has defined migrant workers, women, young workers, and temporary and contractor workers as groups with a higher risk of potential adverse human rights impacts across UPM's value chain.

UPM FINANCIAL REPORT 2024

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UPM FINANCIAL REPORT 2024

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UPM ANNUAL REPORT 2024

UPM ANNUAL REPORT 2024