UPM Annual Report 2025

We are UPM

Governance

Accounts and performance

Sustainability Statement

Report of the Board of Directors

Financial Statements

Auditor's Report

Sustainability Assurance Reports

Table of contents

List of ESRS disclosure requirements

Page

Workers in the value chain 222 Impacts, risks and opportunities ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model 223 Policies S2-1 – Policies related to value chain workers 224 Processes S2-2 – Processes for engaging with value chain workers about impacts 225 S2-3 – Processes to remediate negative impacts and channels for value chain workers to raise concerns 226 Actions S2-4 – Taking action on material impacts on value chain workers 226 Targets S2-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities 228 Affected communities ESRS S3 – Affected communities 229 Impacts, risks and opportunities ESRS 2 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model 230 Policies S3-1 – Policies related to affected communities 231 Processes S3-2 – Processes for engaging with affected communities about impacts 232 S3-3 – Processes to remediate negative impacts and channels for affected communities to raise concerns 232 Actions S3-4 – Taking action on material impacts on affected communities 233 Targets S3-5 – Targets related to managing material negative impacts and advancing positive impacts 235 ESRS S2 – Workers in the value chain

General information (ESRS 2) UPM is committed to creating value for its customers by using sustainable, renewable feedstocks, reducing its environmental footprint and enhancing its positive societal impact.

Governance information Business conduct

UPM updated its Code of Conduct in accordance with its three-year update plan.

The first commercial products from the UPM Biorefinery in Leuna (December 2025)

ESRS G1 – Business conduct

236

Double materiality assessment reviewed

Policies

G1-1 – Business conduct policies and corporate culture

237

Responsible sourcing

G1-2 – Management of relationships with suppliers

239

Anti-corruption and bribery

G1-3 – Prevention and detection of corruption and bribery

242

G1-4 – Incidents of corruption or bribery

244

Metrics

G1-5 – Political influence and lobbying activities

244

G1-6 – Payment practices

245

Other sustainability reporting standards and frameworks IFRS S1 and S2

246

Sustainability Disclosure Standards by the ISSB (International Sustainability Standards Board)

TCFD

248

Disclosures according to TCFD (Task Force on Climate-related Financial Disclosures)

TNFD

249

Disclosures according to TNFD (Task Force on Nature-related Financial Disclosures)

UPM Financial Report 2025

136

UPM Financial Report 2025

137

136

137

UPM Annual Report 2025

UPM Annual Report 2025