UPM Annual Report 2025

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We are UPM

Governance

Accounts and performance

Sustainability Statement

Report of the Board of Directors

Financial Statements

Auditor's Report

Sustainability Assurance Reports

operations. The results of annual risk assessments are used to guide compliance activities and risk mitigation actions in businesses and functions. Together, the Compliance Team and the businesses update compliance risk assessments and mitigation actions throughout the year to respond to changes in the risk environment. Progress on mitigation actions is reported to the Audit Committee and businesses on a quarterly basis. Leadership in responsible business conduct The UPM Code of Conduct underlines UPM's commitment to business integrity and responsible business operations and reflects the company's guiding principles. The UPM Code of Conduct is approved by the Board of Directors as UPM's highest governance body. It is complemented by more detailed policy statements, policies and rules approved by the Board of Directors, the Group Executive Team, business areas, or global functions. The UPM Code of Conduct and UPM's values help UPM's employees to make the right choices and guide UPM's work in a changing business environment. This lays the foundations for long-term success. UPM strives to ensure compliance with the Code of Conduct, policies and rules by implementing a company-wide compliance program through the UPM compliance system. The compliance system is embedded in the company's governance model and is designed to bolster company performance and a culture of integrity at all levels. The Audit Committee receives a quarterly compliance report from the company's Chief Compliance Officer. Information provided and sustainability matters addressed by the Board of Directors and the President and CEO The President and CEO, or other members of executive management, reports to the Board or its committees at least annually on decisions and progress made related to risks, impacts and opportunities, and their management, as well as on targets and actions. In addition, the Audit Committee receives a quarterly compliance report. Refer to paragraph » Compliance controls and procedures The President and CEO chairs the Group Executive Team, the Strategy Team and the Business Area Boards and receives regular and detailed information about the relevant sustainability matters at their meetings. Sustainability is integrated into the company strategy and UPM's goal is to ensure that sustainability-related aspects are taken into account in strategic decision-making. UPM's Strategy Team prepares proposals for updating UPM's strategy and strategic plans and is responsible for identifying and managing UPM's key strategic risks. In 2025, the Board of Directors and the Audit Committee oversaw the company's key sustainability focus areas and targets, the company's double materiality assessment process and the management of material sustainability impacts, risks and opportunities. When reviewing the Sustainability Statement draft they addressed material impacts, risks and opportunities covered by the disclosure. GOV-2

The mapping in this table covers the core elements of a due diligence process in accordance with the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, as well as the main processes and measures of UPM's sustainability due diligence. Details are described in the relevant disclosures of this Sustainability Statement.

The Remuneration Committee conducted an annual review of selected material social sustainability topics related to UPM workforce in their December meeting. The GET approved in their December meeting the outcome of the double materiality assessment (DMA) and reviewed sustainability focus areas and targets.

Sustainability due diligence

GOV-4

Integration of sustainability-related performance in incentive schemes

Core elements of due diligence

UPM's main due diligence processes and measures

Paragraphs in this sustainability statement

Embedding due diligence in governance, strategy and business model

• Implementation of policy documents to ensure integration throughout UPM and its value chain

G1-1 Policies S1-1 Policies E2-1 Policies

GOV-3

Engaging with affected stakeholders in all key steps of due diligence

• Stakeholder dialogue

ESRS2-SBM2 Interest and views of stakeholders S1-2 Processes for workforce engagement S2-2 Processes for engaging with value chain workers S3-2 Processes for engaging with communities ESRS2-SBM3 Impacts, risks and opportunities S2-SBM3 Impacts, risks and opportunities S3-SBM3 Impacts, risks and opportunities G1-3 Anti-corruption and bribery

Since 2022, the Board of Directors has included measures related to environmental, social and governance (ESG) issues in the company's Performance Share Plan (PSP), one of UPM's long-term incentive plans. The PSP is targeted at the President and CEO, the Group Executive Team and other selected members of senior management. The remuneration of the Board of Directors and its committees is resolved by the Annual General Meeting. The members of the Board of Directors do not belong to the company's short- or long-term incentive plans, and their remuneration is not linked to sustainability. The PSP consists of annually commencing individual plans approved by the Board with a minimum performance period of three years. The performance measures, related targets and weightings are set annually by the Board for each commencing plan and can vary from plan to plan to promote the company's long-term value creation and financial growth without encouraging excessive risk-taking. Measures may include among the others financial, share price, and sustainability targets. For the PSP 2023–2025, PSP 2024–2026, and PSP 2025-2027, the Board has set absolute total shareholder return (TSR) as a performance measure, and the weighting of this measure accounted for 80% of all measures. The Board has also set up three separate ESG performance measures and the total weighting of these measures accounted for 20% of all measures. Two of the ESG performance measures are environmental: reducing fossil CO 2 emissions from UPM's on-site combustion and purchased energy by 65% by 2030 from the 2015 level (10% weighting); and achieving a net positive impact on biodiversity in UPM's own forests in Finland (5% weighting). The third ESG performance measure is a social measure: achieving gender pay equity (5% weighting). The ESG performance measures are based on UPM's sustainability targets for 2030. These sustainability performance measures are covered by UPM's Remuneration Policy in the case of the President and CEO. The Board of Directors annually approves the commencement of new long-term incentive plans within the company's long-term share incentive arrangements, including the terms and conditions, performance measures, related targets, and weightings.

Identifying and assessing adverse impacts

• Business-area-specific human rights risk assessments and integration into management systems, as feasible • High sustainability risk supplier process and enhanced due diligence assessment • 24/7 counterparty screening • Environmental and social/human rights impact assessments • Corporate human rights saliency assessment • Supplier and Third-Party Code and contractual requirements • Commodity-specific supplier requirements • Forest certification • EcoVadis assessments, contractor reviews and supplier audits • ISO-certified management systems • UPM Clean Run process • Remediation where appropriate • UPM's compliance system • Human rights workshops in business areas • UPM Report Misconduct channel and other local grievance channels

Taking actions to address these adverse impacts

G1-2 Responsible sourcing E2-2 Actions - UPM Clean Run concept S2-4 Actions

Tracking the effectiveness and progress of these efforts

G1-1 Reporting and identifying concerns, Investigating concerns and incident handling G1-3 Risk assessments, Monitoring, Investigation S1-1 UPM and human rights

Communicating these efforts

• UPM Annual Report • EMAS reports from UPM's pulp and paper mills • UPM Human rights review report • UPM Forestal Oriental Annual Report