UPM Annual Report 2024

WE ARE UPM

GOVERNANCE

ACCOUNTS AND PERFORMANCE

Our strategy

Our businesses

Sustainability

CREATING VALUE FOR PEOPLE AND SOCIETY

Committed to compliance

Regardless of the location, circumstances or people involved, we are committed to complying with applicable laws and regulations and our Code of Conduct.

ACTIONS IN 2024 • 99% of active employees completed Code of Conduct training, excl. UPM Raflatac companies acquired in 2024. • Supplier and Third-Party Code updated. • Sustainability Policy Statement renewed. • Compliance reviews in 6 local units or operations in the Americas, the Asia-Pacific region and Europe. • Revision of background check criteria for high-risk business partners.

We are all responsible for building a culture of integrity in everything we do and in every choice we make. Our Code of Conduct and values help us make the right decisions and guide our work in a changing business environment. This is the foundation for long term success.

We monitor the development of this culture through our annual Employee Engagement Survey (EES). In the EES, the average score for ethical behaviour at UPM was 74 (75), while the external benchmark was 79 (79).

See more in Sustainability Statement, ESRS G1 Business conduct on page 236

Compliance and responsible and ethical, practices are the foundation of UPM’s businesses

How we build a culture of integrity

Mindset Tone from the top Lead by example Ethical behaviour Strong speak-up culture Building organisational justice Practices Upholding the Code of Conduct and other standards of integrity Training and communication Proactive advice

PROMOTING A CULTURE OF INTEGRITY

Driving responsible growth...

Strategy

Alleged misconduct cases UPM Code of Conduct section Our commitment on integrity Our people and operations Respect people and human rights

Employee accepted a falsified invoice to hide the true nature of hospitality, violat ing UPM's policies. Written warning.

2024

2023

10

9

FOSTERING ETHICAL DECISIONS

UPM COMPLIANCE

UPM

57

40

A UPM supplier was discovered to be owned by a family member of an employee, who attempted to hide this conflict of interest, violating UPM's policies. The supplied goods were priced significantly above the market rate. Termination of employment.

Taking care of the environmental impact and product safety

3

3

Business integrity Zero-tolerance for corruption and bribery

2

4

Avoid conflicts of interest

8

3

Trust and be trusted Achieve together Renew with courage

...by ensuring integrity every day

Protecting the future Risk identification Risk mitigation and follow-up Remediating and reacting to misconduct

Compliance with competition laws Protect assets and information Our stakeholders Know with whom you trade

1

1

MANAGING COMPLIANCE RISKS

13

12

Employee misused UPM's assets by claiming personal expenses from the company, in violation of UPM's policies. Termination of employment.

5

11

Total

99

83

76

77

UPM ANNUAL REPORT 2024

UPM ANNUAL REPORT 2024