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

case-by-case basis, based on verified impacts. See » G1-1 Policies for more information about handling concerns. Diversity and inclusion All UPM employees are responsible for creating a diverse and inclusive working environment. It is important to employ people with different competences, backgrounds, and experience, as well as different genders, ages, and nationalities, to bring together different views and improve decision-making and business success. All UPM employees are expected to build and encourage a culture that allows for different views, and where everyone has the opportunity to contribute. UPM is committed to a European-wide diversity charter initiative to develop a diverse and inclusive workplace. UPM promotes equal opportunities and does not tolerate direct or indirect discrimination against anyone based on gender, age, ethnicity, race, nationality, family ties, religion, sexual orientation, disability, political opinion, trade union affiliation, or any other similar aspect related to a person. There shall be no direct or indirect discrimination in relation to selection criteria in resourcing. In personnel planning and recruitment, the selection criteria will be based on a person’s skills and competences. Application and recruitment processes shall be open and transparent when applicable. The working environment and facilities shall be developed so that they do not prevent equality between employees. All employees shall have a chance to develop in their work. Employees are given equal career opportunities based on their qualifications and business needs. Sexual or other forms of harassment – whether verbal, physical, or visual -, harsh or inhuman treatment, is not tolerated. UPM does not engage in behavior that could be characterized as offensive, intimidating, threatening, malicious, or insulting. The UPM Code of Conduct, UPM's values, and the UPM HR Rules address these topics. Processes Processes for workforce engagement Every year, UPM's Employee Engagement Survey (EES) is available for all employees across the company to evaluate various aspects of their working environment. It is an important way of measuring the company's success in developing as an employer and progress in achieving the social responsibility targets that are important to UPM, such as safety, diversity and inclusion, learning and growth, and leadership. The EES provides an opportunity to monitor long-term trends and progress on agreed development activities annually. This progress is followed up and evaluated to enable continuous development of the workplace at both organizational and team levels. S1-2

highlights good practices, as well as any shortcomings or actions needed to meet UPM's H&S expectations. The UPM Code of Conduct, UPM HR Rules, and UPM Safety Rules apply to all UPM's own workforce. UPM and human rights Commitments UPM is committed to respecting human rights in line with the United Nations Guiding Principles on Business and Human Rights. UPM respects the UN Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises. UPM also promotes the human-rights-related principles of the UN Global Compact. The UPM Code of Conduct, the UPM Sustainability Policy Statement, and the UPM Supplier and Third-Party Code are aligned with these internationally recognized standards. Compliance system UPM's compliance system is the risk management system used to manage UPM's human rights and environmental risks. UPM's compliance system is embedded in its governance model and is designed to strengthen corporate performance and a culture of integrity at all levels. Risk analysis UPM regularly assesses human rights risks at business area, function, and corporate level. This includes identifying actual and potential risks and impacts, evaluating their severity and likelihood, and prioritizing the most significant issues for action. Refer to » G1-2 Responsible sourcing Business areas and functions are responsible for identifying risks within their own operations and activities. The prioritization and determination of the materiality of the risks are assessed in connection with UPM’s corporate salient human rights assessment. The procedure is integrated into existing management systems to the extent possible and applied in investment processes. Training and engagement UPM's Code of Conduct training is mandatory for all UPM employees, and participation is measured and reported annually. The training covers the protection of human rights and the environment, and the identification of human rights and environmental risks. In addition, there is a separate e-learning course on the requirements of the UPM Supplier and Third-Party Code for UPM's employees who deal with suppliers. The link between human rights violations and corruption is also covered in UPM's anti-corruption training, which is mandatory for all salaried employees. UPM's Sourcing function organizes additional training for its employees on sustainability principles and supplier requirements. Remediation UPM monitors and works to remedy adverse impacts on human rights of which it is aware, and which its activities have caused or contributed to. In the event of a violation of a human rights or environmental obligation, UPM determines the necessary and appropriate remedy measures on a

To complement the EES, a UPM Health and Well-being pulse survey has been conducted for the last four years. The pulse focuses on the main elements of the UPM's health and well-being approach. UPM aims to empower and engage employees at all levels through responsible leadership, with different forums to facilitate continuous dialogue between employees and business management, for example. UPM engages in both formal and informal consultations with trade unions and actively promotes employee participation and consultation in accordance with international and national rules and regulations. To promote employee participation, consultation and dialogue between UPM's business areas and country management, and employee representatives and employees at national level, UPM's countries have cooperative bodies that operate based on country-specific rules, regulations, and UPM's practices. In addition, to promote an open international dialogue between management and employee representatives, UPM has a cooperative body, the UPM European Forum, which focuses on issues related to changes in the company and the business environment in general. The Forum organizes regular meetings for employee representatives from business units operating in Europe. The Human Resources function and the Executive Vice President of Human Resources have operational responsibility for ensuring that employee engagement takes place. The effectiveness of UPM's engagement with its own employees is assessed through the EES and individual target setting and follow-up discussions. Processes for raising and handling concerns UPM has implemented processes for reporting, identifying, and investigating concerns and for handling incidents, including remediation and protection against retaliation. These processes cover all stakeholders, including UPM's own workforce. Refer to » G1-1 Reporting and identifying concerns, Investigating concerns and incident handling for detailed information . UPM does not yet systematically gather feedback from employees on their level of trust in, or awareness of, the company’s grievance mechanisms. However, the perception of the management on these topics is gathered annually. UPM also regularly gathers feedback on the Code of Conduct training, and a dedicated Code of Conduct Helpline is in place to support employees and address questions related to the Code, including the use of our grievance channels. In addition, the annual Employee Engagement Survey includes questions related to company ethics, providing further insight into employees’ perceptions of the company's ethical culture. S1-3

Policies

S1-1

UPM's decision-making, management and operations are guided by UPM's values and the UPM Code of Conduct. Compliance with the laws and responsible practices are the basis of all UPM's operations and create long term value for both UPM and its stakeholders. The UPM Code of Conduct underlines UPM's commitment to business integrity and responsible business operations and reflects the company's guiding principles. UPM works to ensure that human rights are respected by all UPM employees throughout the operations and business relationships and expects its suppliers and business partners to do the same. UPM wants to ensure that all raw materials and services are purchased from responsible sources. Refer to » G1-1 Policies UPM's Human Resources and Safety Rules UPM's human resources management is based on the company's values and is an important part of UPM's corporate social responsibility. The UPM HR (Human Resources) Rules complement the UPM Code of Conduct by defining in more detail the principles of working conditions, labor practices, and decent work as described by the International Labour Organization (ILO), what UPM is committed to, and what is expected of its employees. The UPM HR Rules are owned by UPM's Human Resources function and approved by the Group Executive Team. The UPM HR Rules apply to all UPM's employees and executives. The UPM HR Rules do not apply directly to suppliers and other third parties and their representatives, as they are bound by similar principles by the UPM Supplier and Third-Party Code. UPM complies with international, national, and local safety laws, regulations, and rules. UPM does this by implementing and complying with UPM's safety standards and local procedures. UPM promotes fair working conditions and respects the right of employees to form and join associations, bargain collectively, and assemble peacefully. UPM does not tolerate modern slavery, child labor, forced labor, or human trafficking in any form in its operations or in any part of its value chain. UPM Safety Rules set and communicate clear safety expectations and targets at all levels of UPM's organizations.The UPM Safety Rules are owned by UPM's Human Resources function and approved by the Group Executive Team. UPM's occupational health and safety management systems ensure that the targets are met. This is reinforced by UPM's safety standards, in particular the safety standard on roles and responsibilities, which also defines the business line organization's responsibility for ensuring the safety standards are implemented. All UPM employees apply UPM's Safety Rules in a disciplined manner. In addition, UPM's business partners and their employees at UPM's sites are required to adopt safe working practices and comply with UPM's Safety Rules and standards. If a safety violation is detected, UPM intervenes and takes the necessary measures in a timely manner. UPM has an internal health and safety (H&S) audit program for each business area to monitor and check compliance with UPM's safety standards. This