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

UPM Chemical Management Standard

Policies

The UPM Chemical Management Standard describes the minimum requirements for chemical risk assessment, approval, and safe handling. UPM complies with the relevant international and national legislation applicable to the production site and for the product. In addition, chemicals approved for use should have minimal negative effects on human health, the environment, and the safety of UPM's products. The least harmful alternative should be selected. Chemicals that are classified as or contain a component that is fatal to humans, carcinogenic, mutagenic, harmful to reproduction, toxic for single organs, skin or respiratory sensitizing, toxic to aquatic life with chronic effects, hazardous to the ozone layer, persistent or that are on the list of substances of very high concern (SVHC) of the European Chemicals Agency (ECHA), or that are considered to have endocrine disrupting properties, must not be used if technically feasible safer alternatives are available. UPM Risk Management Standard The purpose of the UPM Risk Management Standard is to describe the company's HS&E (Health and Safety & Environment) risk management process in detail. The standard provides a systematic and standardized approach for conducting risk assessments, which are recorded in UPM's One Safety tool. The standard defines that management at all UPM units (sites, mills, offices, etc.) are expected to: 1. Identify all foreseeable hazards and evaluate their risk levels with respect to health, safety, environment, products, and company reputation; 2. Effectively control risks to a level as low as reasonably practicable; 3. Effectively communicate risk assessment findings to all relevant employees so they can work safely and in an environmentally responsible way; 4. Review and prioritize the risks in their area of responsibility. Further standards such as the UPM Process Safety Standard or UPM Management of Change Standard are also addressing aspects relevant for the management of environmental performance. UPM Incident Investigation and Reporting Standard The UPM Incident Investigation and Reporting Standard applies to HS&E. It defines UPM's effective incident investigation process to include how to notify, investigate, and assign preventive and corrective actions, report the findings, and share the lessons learned with other UPM organizations. The UPM incident investigation process starts when an incident occurs or is detected. It follows the procedures defined in the standard according to the severity of the incident. Immediately following an incident, the line organization's first task is to stabilize the situation, limit any further consequences, and make the incident site safe and secure.

E2-1

UPM's Code of Conduct expresses the company's respect for people, the environment, and ethical business practices, and includes its commitment to minimizing negative environmental impacts. The Code is complemented by UPM's Sustainability Policy Statement, which addresses the issue in more detail. The UPM Supplier and Third-Party Code sets out minimum requirements for the value chain. Refer to » G1-1 Policies for more information about these policy documents. In addition, specific aspects are addressed in the following policy documents: • UPM Sustainable Supply Chain Program; Refer to » G1-2 Responsible sourcing • UPM Clean Run Standard • UPM Chemical Management Standard • UPM Risk Management Standard • UPM Incident Investigation and Reporting Standard UPM's high-level commitment to mitigating, preventing, and controlling negative impacts related to pollution is stated in the UPM Code of Conduct: "We aim to minimize any direct or indirect negative impacts on the environment or people in our sphere of influence. On an ongoing basis, we measure and assess the direct and indirect environmental risks and impacts of our operations and promote the use of the best available techniques. We expect our suppliers and business partners to share our commitment to the environment." This is complemented by UPM's Sustainability Policy Statement: "UPM pays close attention to the impact of its operations on the air, climate, water, and soil and aims to minimize any adverse effects. This means reducing emissions to air and water, avoiding emissions to soil, and minimizing both non-hazardous and hazardous waste." All relevant pollutants and substances from UPM's operations are covered by UPM's policies. The reduction targets for most material pollutants at Group level, NO X , SO 2 , COD and landfill waste, are included in UPM's sustainability targets for 2030. UPM's commitment to the continuous improvement of environmental impacts is specified in the UPM Sustainability Policy Statement. UPM Clean Run Standard The UPM Clean Run Standard formalizes UPM's Clean Run concept. It aims to ensure that all businesses and operations of UPM implement the processes falling under Clean Run as intended in UPM's Sustainability Policy Statement, and to ensure continuous improvement of environmental performance and compliance with all applicable laws and other regulatory obligations. Refer to » E2-2 UPM Clean Run concept

Pollution (ESRS E2) UPM pays close attention to the impact of its operations on the air, climate, water, and soil and aims to minimize any adverse effects. This means reducing emissions to air and water, avoiding emissions to soil, and minimizing both non-hazardous and hazardous waste.

Reduction in acidifying flue gases (NO X /SO 2 ) achieved for a UPM average product Reduction in chemical oxygen demand (COD) achieved for UPM's average product -20% -43%

41 environmental deviations from permit, contractual, or other legal obligations

2,100 preventive observations and near misses reported

Compared to 2015 (2030 target: -20%)

Compared to 2008 (2030 target: -40%)

UPM Financial Report 2025

176

UPM Financial Report 2025

177

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UPM Annual Report 2025

UPM Annual Report 2025