UPM Annual Report 2024

WE ARE UPM

GOVERNANCE

ACCOUNTS AND PERFORMANCE

Our strategy

Our businesses

Sustainability

OUR COMMITMENTS Compliance

OUR PRIORITIES Risk assessment forms the basis of our compliance programme Each business area, unit and function is respon sible for identifying and managing its compli ance risks. Annual and ad hoc risk assessments guide our compliance activities and mitigation actions, which are updated throughout the year to reflect changes in the risk environment. Policies and procedures document what is expected of all employees The compliance system is embedded in our governance model and is designed to promote a culture of integrity at all levels. To remain relevant, we review the need to update policies and procedures annually as part of our policy management process. Ongoing training and communication help us make the right choices Our e-learning modules on policies and procedures are easily accessible to employees on a global e-learning platform, and complet ing these mandatory e-learning courses is a prerequisite for short-term incentive payments. Training is also extended to the employees of

our business partners who work for UPM. Com pliance e-learning modules are supported by tailored training and active communication. Comprehensive monitoring helps us take action Our monitoring activities are based on a risk matrix that considers country risk, complexity and the scale of our operations in each country. In addition, we conduct risk-based reviews on specific topics such as competition law or anti-corruption, and ongoing counterparty screening activities. Key findings and recom mendations from compliance reviews are reported to the Audit Committee of the Board of Directors and to the businesses, and any neces sary follow-up action is taken with the relevant business unit. Response and remediation contribute to organisational justice We encourage employees to report any mis conduct or unethical behaviour without fear of retaliation. We maintain procedures to inves tigate business conduct incidents in a timely, independent and objective manner.

We are committed to complying with applicable laws, regulations, our Code of Conduct and our values – Trust and be trusted, Achieve together, Renew with courage. Our Code of Conduct reflects our respect for people, the environment and ethical business practices. Building a culture of integrity We do not compromise our standards of integ rity in any circumstances. We aim to continu ously improve how we work and further embed a culture of business integrity. Accountability Accountability for compliance extends down from the Board of Directors and senior manage ment to all employees. Voicing concerns We strive to create an environment in which em ployees feel comfortable voicing their concerns without fear of retaliation.

Compliance monitoring

REGULAR DISCUSSIONS WITH MANAGEMENT , monitoring significant projects, training rate monitoring, implementation of risk mitigation plan

CASE STUDY

ENSURING EUDR COMPLIANCE

In 2023–2024, UPM’s businesses have been actively working to comply with the EU Deforestation Regulation (EUDR), which aims to reduce the EU’s impact on global deforest ation and forest degradation, thereby lowering greenhouse gas emissions and preventing biodiversity loss. Key developments include enhancing due diligence processes and managing data flows in an EU-provided IT system as proof of no de

forestation. The regulation was originally due on 30 December 2024. As per the amendment regarding the date of application the EUDR enters into application on 30 December 2025. UPM has been developing its due diligence and IT systems to meet the requirements of the EUDR in the original schedule and aims to begin application of the regulation as soon as possible already during the transition period.

REGULAR COMPLIANCE REVIEWS based on Group company risk matrix

UPM BUSINESS AREAS AND OTHER OPERATIONS

REGULAR DISCUSSIONS WITH EMPLOYEES , third-party due diligence and risk monitoring, reports through UPM Report Misconduct channel, EES and other employee surveys

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UPM ANNUAL REPORT 2024

UPM ANNUAL REPORT 2024